Privacy Policy

Our company respects the privacy of our users and has developed this Privacy Policy to demonstrate its commitment to protecting your privacy. This Privacy Policy is intended to describe for you, as an individual who is a user of CM Connect, the craigmichaelsconnect.com website (the “Site”), the information we collect, how that information may be used, with whom it may be shared, and your choices about such uses and disclosures. By using the Site, you are accepting the practices described in this Privacy Policy.

This Privacy Policy contains informaiton concerning the following:

• What personally identifiable information (“PII”) is collected on the Site, and how the same will be used
• Identity of the party collecting PII
• Sharing of PII with third parties
• Use of tracking technology
• Supplementing of PII is with information from other sources
• Choice options available to users of the Site
• How users can access PII they have provided
• Security measures in place
• Procedures for filing and addressing complaints

CraigMichaels, Inc. (referred to herein as the “Company”), which owns and operates the Site, adheres to the following principles to protect your privacy:

• We will never rent or sell your personally identifiable information to third parties for marketing purposes
• We will never share your contact information with another user, without your consent
• Any sensitive information that you provide will be secured with all industry standard protocols and technology

We reserve the right to modify this Privacy Policy at any time, so please review it frequently. Notice of all changes that materially affect ways in which PII may be used or shared will be posted in updates to the Company’s Privacy Policy, and continued use of the Site shall be deemed your consent to any such changes.

COLLECTION OF PII

General

We may collect personal information that can identify you such as your name and email address and other information that does not identify you.

Setting Up An Account

To become a Member (as such term is defined in the Terms of Use), you must first create an account on the Site, and you must include the following information which you recognize and expressly acknowledge is personal information allowing others, including the Company, to identify you: full name, email address, country, ZIP/postal code, a brief description of your professional background, and choose a user name and password.

Once you become a Member, you may provide additional information in the Profile section describing your skills, professional experiences, and networking objectives. Providing additional information beyond what is required at registration to become a Member is entirely optional, but enables you to better identify yourself and find new opportunities in the CM Connect system to build and leverage your professional network. Any information you provide at registration or in the Profile section that is not personally identifiable may be used in the same manner and extent to which other information that is not personally identifiable is permitted to be used hereunder, including for the purpose of serving advertisements through the service. If you opt-out you may lose the potential benefit of being a Member, including receiving ads that are more targeted to your interests.

Information You Provide

We may collect and store any personal information you enter on the Site or provide to us in some other manner. This includes identifying information, such as your name, address and e-mail address, and, if you transact business with us, financial information such as your payment method (valid credit card number, type, expiration date or other financial information). We also may request information about your interests and activities, hobbies, profession and/or area of expertise, and other demographic information such as your hometown.

Information About Others

We may also collect and store personal information about other people that you provide to us, such as their name, address and email address. If you use our website to send others (friends, relatives, colleagues, etc.) a product as a gift, we may store your personal information, and the personal information of each such recipient in order to process those requests or facilitate future activities.

Contacts Information

In order to invite others to connect with you directly in CM Connect, you may use the CM Connect services to invite them if they are a Member, or enter their names and email addresses. This information will be used by CM Connect to send your invitation including a message that you write. The names and email addresses of people that you invite will be used only to send your invitation and reminders.

You may also choose to manually enter or upload data about your contacts into the private “My Contacts” section of the Site. You may not invite anyone to connect with you whom you do not already know or with whom you have a legitimate desire to network on a professional level. All information entered there will only be viewable by you and will not be searchable by others in the CM Connect network without your permission. All information that you enter or upload about your contacts will be covered by the same terms of this Privacy Policy which cover your own information.

Additional information

Members may provide additional information and content for their Member Pages (as such term is defined in the Terms of Use).

Log files, IP addresses and information collected automatically:

Due to the communications standards on the Internet, when you visit the Site we automatically receive the URL of the site from which you came and the site to which you are going when you leave CM Connect. We also receive the Internet protocol (IP) address of your computer (or the proxy server you use to access the World Wide Web), your computer operating system and type of web browser you are using, email patterns, access times, the name of your ISP, and the content of any undeleted cookies that your browser previously accepted from us (see “Cookies” below). The linkage between your IP address and your PII is not shared with third-parties without your permission or except when required by law.

Cookies and Log Files:

Like most web sites, this Site uses cookies and web log files to track site usage, to facilitate access to our site and to personalize your online experience. A cookie is a tiny data file which resides on your computer which allows the Company to recognize you as a user when you return to our site using the same computer and web browser. Through the use of a cookie, we also may automatically collect information about your online activity on our site, such as the web pages you visit, the links you click, and the searches you conduct on our site. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. If you choose to decline cookies, please note that you may not be able to sign in or use some of the interactive features offered on our website. If your browser settings do not allow cookies, you will not be able to use the Site. As with information you enter at registration and on a Member Page, cookie and log file data is used to customize your experience on the Site.

One type of cookie, known as a “persistent” cookie, is set once you’ve logged in to your Member account. The next time you visit the Site, the persistent cookie will allow the Company to identify you as an existing user so you will not need to log in before using the service. In order to access or change any of your private information (like a credit card number), however, you must log in securely again with your password even if your computer contains your persistent cookie. Additionally, if you log out of the Site you will need to re-enter your password the next time you visit in order to log in to your account. Another type of cookie, called a “session” cookie, is used to identify a particular visit to the Site. Session cookies expire after a short time or when you close your web browser.

Due to the communications standards on the Internet, when you visit the Site we automatically receive the URL of the site from which you came and the site to which you are going when you leave the Site. We also receive the Internet protocol (IP) address of your computer (or the proxy server you use to access the World Wide Web), your computer operating system and type of web browser you are using, as well as the name of your ISP. This information is used to analyze overall trends to help us improve the Site. The linkage between your IP address and your personally identifiable information is never shared with third-parties without your permission or except when required by law.

Web Beacons:

We allow other companies, called “ad” (i.e., advertising) networks, to serve advertisements to the Site’s users. Ad networks include third party ad servers, ad agencies, ad technology vendors and research firms. The Company may “target” some ads to users that fit a certain general profile — for example, “accountants in Mississippi.” The Company does not use PII to target ads.

To deliver these ads properly, the Company may include a file (known as a web beacon) from these ad networks within pages served by the Company so the ad networks may provide anonymized, aggregated auditing, research and reporting for advertisers as well as to target ads to you while you visit other websites.

Because your web browser must request these advertisements and web beacons from the ad network’s servers, these companies can view, edit or set their own cookies, just as if you had requested a web page from their sites.

These general targets may also be used by ad networks to display targeted ads on other websites as a substitute for random, irrelevant ads. The Company never provides personally identifiable information to any advertiser or to any third party.

Information collected by third-parties

We may allow third-parties, including our authorized service providers, advertising companies, and ad networks, to display advertisements on our site. These companies may use tracking technologies, such as cookies, to collect information about users who view or interact with their advertisements. The Site does not provide any personal information to these third parties. This information allows them to deliver targeted advertisements and gauge their effectiveness. Some of these third-party advertising companies may be advertising networks that are members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies (www.networkadvertising.org).

Consent to CM Connect Processing Information About You

Certain information you provide on the Site may reveal, or allow others to identify, your nationality, ethnic origin, religion or other aspects of your private life, and more generally about you. Please be aware that in providing information on CM Connect for the purposes of opening your Member account, you are expressly and voluntarily accepting the terms and conditions of this Privacy Policy and the Term of Use. The supplying of all such information by you to CM Connect, including all information deemed “sensitive” by applicable law, is entirely voluntary on your part. You have the right to withdraw your consent at any time, in accordance with the terms of this Privacy Policy and the Terms of Use, but please note that your withdrawal of consent will not be retroactive.

Children:

Because CM Connect is by invitation only, children are not eligible to use the Site, and the Company requests that minors (under the age of 18) do not submit any PII to us.

INFORMATION USE

The Company offers its online service so as to help all types of professionals to: (i) provide information about themselves for the purposes of developing, maintaining and enhancing a network of professional contacts, and (ii) more effectively connect with one another in the forum of an online community. The PII you choose to provide on this site is used to help you describe yourself to other users. Other information (that does not personally identify you as an individual) is collected by the Company from the Site and is exclusively owned by the Company. This information can be utilized by the Company in such manner as the Company, in its sole discretion, deems appropriate.

We may use information that we collect about you to:

• deliver the products and services that you have requested;
• manage your account and provide you with customer support;
• perform research and analysis about your use of, or interest in, our products, services, or content, or products, services or content offered by others;
• communicate with you by e-mail or postal mail, and/or mobile devices about products or services that may be of interest to you either from us or other third parties;
• develop and display content and advertising tailored to your interests on the Site and other sites;
• verify your eligibility and deliver prizes in connection with contests and sweepstakes;
• enforce our terms and conditions;
• manage our business; and
• perform functions as otherwise described to you at the time of collection.

Financial Information

We may use financial information or payment method to process payment for any purchases made on the Site or at face-to-face meetings and/or events arranged by the Company, enroll you in the discount, rebate, and other programs in which you elect to participate, to protect against or identify possible fraudulent transactions, and otherwise as needed to manage our business.

Communications

CM Connect will communicate with you through email and notices posted on the Site or through other means available through the service, including text and other forms of messaging. If we send any communications to you via the carrier service with which you have a mobile communications subscription or otherwise have access, you understand you will pay any service fees associated with any such access (including text messaging charges for messages to your mobile device). These include a series of up to five welcome emails which help inform new Members about various features of the service. Please be aware that you will always receive certain emails from CM Connect related to the proper functioning of your account, such as email notices when another Member in your network sends you an opportunity. CM Connect may send you promotional information unless you have opted out of receiving such information. You can change your e-mail and contact preferences at any time by logging into your “Account Settings” and amending your email notification choices. If you wish to opt-out of receiving promotional emails, please send a request to info@craigmichaelsconnect.com.

Customized Content

Information you provide at registration of in your Member Page is also used to customize your experience on the Site. For example, when you login to your account we will display the screen names of new Members who have recently joined your network.

Information Sharing

Sharing Information with Others

The Company will not sell, rent, or otherwise provide your PII to any third parties for marketing purposes. We will only share your PII with third parties to carry out your instructions and to provide specific services. For instance, we use a credit card processing company to bill users for subscription fees or upon a request to purchase a good or service. These third parties do not retain, share, or store any PII except to provide these services and are bound by strict confidentiality agreements which limit their use of such information.

CM Connect offers a “public profile” feature which allows Members to publish portions of their CM Connects profile, including their “name”, but not their “email address” to the public Internet. Members may opt-out of this feature by editing their “Account Settings”, however CM Connect does not warrant how often third-party search engines will update their cache.

The Company may provide aggregated anonymous data about the usage of our services to third-parties for such purposes as the Company deems, in our sole discretion, to be appropriate, including to prospective advertisers on CM Connect. The Company may segment our users by role (i.e. product managers, vice presidents), industry, geographic location, or company. If you would like to be excluded from the aggregated research or products based upon aggregated data about our users’ activities on the Site, please email customer service at customerservice@craigmichaelsconnect.com.

Partnering with Other Companies to Offer Combined Services

The Company may partner with other online services to give you the combined results of both services. If the Company offers such combined services, it will be your choice to make use of the combined services or not. In these cases, your personally identifiable information will only be passed from the Company to the partner if you choose to use the combined service.

Communications Between Members

Many emails you initiate through the Site (an invitation sent to a non-Member for instance) will list your email address and name in the header of the message. Emails you initiate may also provide aggregate information about your network (for instance how many people are in your network), but will never list the people to whom you’re directly connected. Other communications that you initiate through the Site, like a request for contact, will list your name as the initiator but will not include your personal contact information. Your contact information will only be shared with another user if both of you have indicated that you would like to establish contact with each other.

Third-Party Websites

There are a number of places on our website where you may click on a link to access other websites that do not operate under this Privacy Policy. For example, if you click on an advertisement or banner on our website, you may be taken to a website that we do not control. These third-party websites may independently solicit and collect information, including personal information, from you and, in some instances, provide us with information about your activities on those websites. We recommend that you consult the privacy statements of all third-party websites you visit by clicking on the “privacy” link typically located at the bottom of the webpage you are visiting.

Forums/Chats/Blogs

If you post on the “Answers” section of CM Connect, or use a bulletin board, import a blog, or participate in a chat room on CM Connect, you should be aware that any PII you choose to provide there can be read, collected, or used by other Members of these forums, as well as Platform Developers and other third parties, and could be used to send you unsolicited messages. CM Connect is not responsible for the personally identifiable information you choose to submit in these forums.

Legal Disclaimer

It is possible that we may need to disclose personal information when required by law, such as responses to civil or criminal subpoenas, or other requests by law enforcement personnel. We will disclose such information wherein we have a good-faith belief that it is necessary to comply with a court order, ongoing judicial proceeding, or other legal process served on our company or to exercise our legal rights or defend against legal claims.

ACCESSING AND CHANGING YOUR ACCOUNT INFORMATION

You can review the personal information you provided us and make any desired changes to the information, or to the settings for your CM Connect account, at any time by logging in to your account on the Site and editing the information on your profile page. Please be aware that even after your request for a change is processed, CM Connect may, for a time, retain residual information about you in its backup and/or archival copies of its database.

CLOSING YOUR ACCOUNT

You can also close your account through the Site. If you close your Company account, we will remove your name and other PII from our publicly viewable data. After you close your account, you will not be able to sign in to the Site or access any of your personal information. However, you can open a new, separate account at any time or re-activate your previous account by following instructions we will give you at the time you close your account. If you close your account, we may retain certain data contributed by you if it may be necessary to prevent fraud or future abuse, collect any fees owed, enforce our terms and conditions, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, to protect the integrity of our website or our users, or if required by law. All retained data will continue to be subject to the terms of our Privacy Policy that you have previously agreed to. In addition, if certain information has already been provided to third parties as described in this Privacy Policy, retention of that information will be subject to those third parties’ policies. To request that we close your account and remove your information from the Site, please send your request to support@craigmichaelsconnect.com. Please send your request using an email account that you have registered with CM Connect under your name. You will receive a response to requests sent to support@craigmichaelsconnect.com within three business days of our receiving it.

SECURITY

In order to secure your personal information from unauthorized access and disclosure, access to your data on the Site is password-protected, and sensitive data (such as credit card information) is protected by SSL encryption when it is exchanged between your web browser and our web site. Only authorized employees are permitted to access personal information, and they may do so only for permitted business functions. To protect any data you store on our servers we also regularly audit our system for possible vulnerabilities and attacks and we use a tier-one secured-access data center.

We want you to feel confident using the Site to transact business. However, no system can be completely secure. Therefore, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information, searches, or other communications will always remain secure. Members should also take care with how they handle and disclose their personal information and should avoid sending personal information through insecure email.

INFORMATION YOU PROVIDE WHILE USING OUR SITE

The Company provides areas on the Site where you can post information about yourself and others and communicate with others or upload content such as text and photographs. Such postings are governed by our Terms of Use. In addition, such postings may appear on other websites or when searches are executed on the subject of your posting. Also, whenever you voluntarily disclose personal information on publicly-viewable web pages, that information will be publicly available and can be collected and used by others. For example, if you post an email address, you may receive unsolicited messages. The Company cannot control who reads your posting or what other users may do with the information you voluntarily post, so the Company encourages you to exercise discretion and caution with respect to your personal information.

INFORMATION YOU PROVIDE AT FACE-TO-FACE MEETINGS

You should also be aware that Members of the Site may reveal other personal information while communicating at face-to-face meetings and/or events arranged by the Company. The Company cannot control and is in no way responsible for the content of such communications, including but not limited to, written or oral statements.

NO RIGHTS OF THIRD PARTIES

This Privacy Policy does not create rights enforceable by third parties or require disclosure of any personal information relating to users of the website.

CHANGES TO THIS PRIVACY POLICY

The Company may update this Privacy Policy. In the event there are material changes in the way we collect, use, share and/or treat your personally identifiable information, we will display a notice on this site. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account. If you use the CM Connect service after notice of changes have been sent to you or published on our site, you hereby provide your consent to the changed practices.

QUESTIONS OR COMMENTS

If you have questions or comments about this privacy policy, please email us at info@craigmichaelsconnect.com or contact us at:

CraigMichaels, Inc.
Attn: Mr. Craig Lehmann
Address: 15 Maiden Lane, 5th Floor, New York, New York 10038