ACCELERATORS & INCUBATORS

Leverage the world's expertise to empower your entrepreneurs

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Background4

Privacy Policy

Our Privacy Policy has been updated 8/8/2014

Leveraging the world’s expertise to empower entrepreneurs is the mission of Two Cents. Our registered users (“Members”) share their professional identities, engage with their network, exchange knowledge and professional insights, post and view relevant content, and find business opportunities. Content on some of our services is also visible to unregistered viewers (“Nonmembers”). We believe that our services allow our Members to effectively compete and achieve their full entrepreneurial potential. This means better management of expertise networks and a better overall flow or knowledge transfer. The cornerstone of our business is to focus on the entrepreneurial ecosystem.

Maintaining your trust is our top priority, so we adhere to the following principles to protect your privacy:

• We protect your personal information and will only provide it to third parties under the following conditions: (1) with your approval or consent; (2) where it is necessary to carry out your instructions; (3) as reasonably necessary in order to provide our features and functionality to you; (4) when we reasonably believe it is required by law, subpoena or other legal process; or (5) as necessary to enforce our User Agreement or protect the rights, property, or safety of Two Cents, its Members and engaged Nonmembers, and the public.

• We have implemented appropriate security safeguards designed to protect your information in accordance with industry standards.

This Privacy Policy applies to all Two Cents domains and the Two Cents mobile application, Two Cents platform technology, and all other Two Cents websites, apps, developer platforms and other products and services (collectively “Two Cents” or the “Services”). We may modify this Privacy Policy from time to time, and if we make material changes to it, we will provide notice through our Service, or by other means so that you may review the changes before you continue to use Two Cents. If you object to any changes, you may close your account. Continuing to use Two Cents after we publish or communicate a notice about any changes to this Privacy Policy means that you are consenting to the changes.

1. What information we collect

1.1. Data Controllers

Our Privacy Policy applies to any Member or visiting nonmember. If you live in the U.S. or if you live outside the U.S., Two Cents controls your information.

The personal information provided to or gathered by Two Cents is controlled by Two Cents Corporation, 3891 S Traditions Dr., Bryan, Texas 77807. If you have any concern about providing information to us or having such information displayed on the Two Cents services or otherwise used in any manner permitted in this Privacy Policy and the User Agreement (together also referred to as Two Cents’ Terms of Service), you should not become a Member of Two Cents, visit our websites, apps or otherwise use our Services. We collect your personal information in the following ways:

1.2. Registration

When you create an account with us, you provide us with information (including your name, email address, and password) that we use to offer you a personalized, relevant experience on Two Cents.

To create an account on Two Cents, you must provide us with at least your name, email address and a password. You can choose to provide further information about yourself during the registration process (for example, your profession and location). We use this information to provide you with more customized services like language-specific profile pages, updates, content, connections, more relevant material, and more valuable business opportunities and relationships, and it may appear on your Two Cents profile that is viewable by others. You understand that, by creating an account, Two Cents and others will be able to identify you by your Two Cents profile, and you allow Two Cents to use this information in accordance with this Privacy Policy. We may also ask for your credit card details if you purchase certain Two Cents services.

1.3. Profile Information

You can add professional details – like your job title, industry, and skills – to your profile. A complete profile helps you be found by other people for opportunities. It also means we can show you relevant content.

After you create an account, you may choose to provide additional information on your Two Cents profile, such as descriptions of your skills, professional experience, and educational background. You may be able to list other attributes such as honors, awards, professional affiliations, Two Cents Group memberships, networking objectives, companies or individuals that you follow, and other information including content. With your approval, your connections may provide recommendations and endorsements of you. Providing additional information enables you to derive more benefit from Two Cents by helping you express your professional identity; find other professionals, opportunities, and information; and help recruiters and business opportunities find you. It also enables us to serve you other relevant content on and off Two Cents.

1.4. Address Book and Other Services That Sync with Two Cents

We collect information when you sync non-Two Cents content with your account. We use this information to improve your experience and allow you and your network to be better connected. You can remove synced information whenever you'd like.

Two Cents makes other tools available to sync information with Two Cents, and may also develop additional features that allow Members to use their Two Cents account in conjunction with other third-party services. For example, Two Cents’ mobile applications may allow you to sync your device’s calendar, email and/or contacts apps with Two Cents to show you the Two Cents profiles of meeting attendees, email correspondents and/or your contacts.

Another example are software tools that allow you to see Two Cents and other public social media information about the people you email or meet with and leverage Two Cents to help you gain insights from and grow your network. If you grant these products (mobile applications or other Two Cents services that sync external email and calendar services) permission to access your email and calendar accounts, they will access and may store some of your email header and calendar history information in order to match it to Two Cents and other public social media profiles. Two Cents’ products that sync with external email services may also temporarily cache message content for performance reasons, in a way that is unreadable by Two Cents and its service providers.

Any information that you upload or sync with Two Cents is covered by the User Agreement and this Privacy Policy. You can remove your information at your convenience using the features Two Cents makes available or in accordance with Section 3. You can remove synced information at any time.

1.5. Customer Service

When you contact our Help Center, we collect information to respond to your questions and better serve you.

When you contact our customer support services (e.g. on Two Cents’ help center), we collect information that helps us categorize your question, respond to it, and, if applicable, investigate any breach of our User Agreement or this Privacy Policy. We also use this information to track potential problems and trends and customize our support responses to better serve you.

1.6. Using the Two Cents Sites and Applications

We collect information when you visit Two Cents and use our mobile applications.

We collect information when you use (whether as a Member or a Visitor) the Two Cents website applications (for example, Two Cents for iPhone or Android), Two Cents platform technology or other Services. If you are logged in on Two Cents.com or another Service or a Two Cents cookie on your device identifies you, your usage information and the log data described in Section 1.10 of this policy, such as your IP address, will be associated with your account. Even if you’re not logged into a Service, we log information about devices used to access our Services, including IP address.

1.8. Cookies

We may use cookies to help personalize your Two Cents experience and show you relevant ads.

We may use cookies and similar technologies, including mobile application identifiers, to help us recognize you across different Services, improve your Two Cents experience, increase security, measure use and effectiveness of our Services, and serve advertising. You can control cookies through your browser settings and other tools. By visiting Two Cents, you consent to the placement of cookies and beacons in your browser and HTML-based emails in accordance with this Privacy Policy and Two Cents’s Cookie Policy.

1.9. Advertising Technologies and Web Beacons

We may in the future target ads to you on and off Two Cents, based on information you included in your profile and your use of Two Cents.

We may target ads to Members and Visitors both on and off Two Cents through a variety of ad networks and ad exchanges, using:

• Advertising technologies like web beacons, pixels, ad tags, cookies, and mobile identifiers as permitted by mobile platforms both on and off Two Cents;

• Member-provided profile information and categories;

• Information inferred from a Member’s profile (for example, using job titles to infer age, industry, seniority, and compensation bracket; or names to infer gender);

• Your use of Two Cents (for example, your Two Cents search history, the content you read, who you follow or is following you, etc.) or clicking on a Two Cents ad;

• Information from advertising partners which we use to help deliver ads more relevant to you.

We do not share personally identifiable information with any third-party advertiser or ad network, although your profile is visible to other Members and through public search depending on your settings.

1.10. Log Files, IP Addresses, and Information About Your Computer and Mobile Device

At times we may collect information from the devices and networks that you use to access Two Cents. This information helps us improve and secure our Services.

When you visit or leave Two Cents sites or apps (whether as a Member or Visitor) by clicking a hyperlink or when you view a plugin on a third-party site, we automatically receive the URL of the site from which you came or the one to which you are directed. Also, advertisers receive the URL of the page that you are on when you click an ad on Two Cents. We also receive the internet protocol (“IP”) address of your computer or the proxy server that you use to access the web, your computer operating system details, your type of web browser, your mobile device (including your mobile device identifier provided by your mobile device operating system), your mobile operating system (if you are accessing Two Cents using a mobile device), and the name of your ISP or your mobile carrier. We may also receive location data passed to us from third-party services or GPS-enabled devices that you have set up, which we use to show you local information on our mobile or web applications. Most mobile devices allow you to prevent real time location data being sent to Two Cents, and of course Two Cents will honor your settings.

In the case of our Android apps, you will be provided notice of the types of data (e.g. location) that will be sent to us. If you choose to use our app after this notice, we process this data to enable registration or preview product features for you (e.g. business opportunities near you). If you choose not to become a Member, we will delete this information.

1.11. Other

We are constantly innovating to improve our Services, which means we may create new ways to collect information on the Services.

Two Cents is a dynamic, innovative environment, which means we are always seeking to improve the services we offer you. We often introduce new features, some of which may result in the collection of new information. Furthermore, new partnerships or corporate acquisitions may result in new features, and we may potentially collect new types of information.

2. How we use your personal information

At Two Cents, we strive to use your information to provide you world-class services in a professional and trustworthy manner.

2.1. Consent to Two Cents Processing Information About You

When you join Two Cents, you acknowledge that information you provide on your profile can be seen by others and used by us as described in this Privacy Policy and our User Agreement.

The personal information you provide to us may reveal or allow others to identify aspects of your life that are not expressly stated on your profile (for example, your picture or your name may reveal your gender). By providing personal information to us when you create or update your account and profile, you are expressly and voluntarily accepting the terms and conditions of Two Cents’ User Agreement and freely accepting and agreeing to our processing of your personal information in ways set out by this Privacy Policy. Supplying to us any information deemed “sensitive” by applicable law is entirely voluntary on your part. You have the right to withdraw or modify your consent to Two Cents’ collection and processing of the information you provide at any time, in accordance with the terms of this Privacy Policy and the User Agreement, by changing your account settings or your profile on Two Cents, or by closing your respective account.

2.2. Two Cents Communications

We communicate with you through email, notices posted on the Two Cents websites or apps, messages to your Two Cents inbox, and other means available through the Services, including mobile text messages and push notifications. Examples of these communications include: (1) welcome and engagement communications - informing you about how to best use Two Cents, new features, updates about other Members you are connected to and their actions, etc.; (2) service communications; these will cover service availability, security, and other issues about the functioning of Two Cents; (3) promotional communications; these include both email and in system messaging, and may contain promotional information directly or on behalf of our partners, including business opportunities and information from companies. These messages will be sent to you based on your profile information and messaging preferences. You may change your email and contact preferences at any time by signing into your account and changing your email settings. You can also opt out of promotional messages by sending a request to Two Cents’ support team. Please be aware that you cannot opt out of receiving service messages from Two Cents.

2.3. User Communications

At times communications that you initiate through Two Cents may list your name and primary email address in the header of the message. Messages you initiate may also provide the recipient with aggregate information about your network (for example, how many people are in your network). Other communications that you initiate through the Services, like a request for an introduction, will list your name as the initiator but will not include your personal email address contact information. Once you have connected with an individual, regardless of who sent the invitation, your contact information may be shared with that individual.

2.4. Customized Content

We use information that you provide to us to customize your experience and the experiences of others on Two Cents. For example, when you sign in to your account, we may display the names of new Members who have recently joined your network or recent updates from your connections and companies you follow. We also use aggregated information from your network and other users to show you content, such as news and presentations relevant to you, your industry, or your profession.

2.5. Sharing Information with Affiliates

We may share your personal information with our Two Cents affiliates (meaning entities controlled by, controlling or under common control with Two Cents) outside of the Two Cents entity that is your data controller as necessary to provide the Services. By agreeing to this Privacy Policy, you are consenting to this sharing.

For clarity, Two Cents and its affiliates combine information internally across different Services.

2.6. Sharing Information with Third Parties

We do not rent or sell personal information that you have not posted on Two Cents, except as described in this Privacy Policy. We will not disclose personal information that is not published to your profile or generated through engagement with other Two Cents services, such as Groups and Company Pages, without your consent or to carry out your instructions (for example, to process payment information) unless Two Cents has a good faith belief that disclosure is permitted by law or is reasonably necessary to: (1) comply with a legal requirement or process, including, but not limited to, civil and criminal subpoenas, court orders or other compulsory disclosures; (2) enforce this Privacy Policy or our User Agreement; (3) respond to claims of a violation of the rights of third parties; (4) respond to Member service inquiries; or (5) protect the rights, property, or safety of Two Cents, our Members, Visitors, or the public. See Section 2.14 for additional details about Two Cents’ compliance with legal requests for information.

Two Cents supports middleware providers that offer archiving solutions to firms subject to financial services regulation, which, with your permission, facilitate the archiving of your communications and other Two Cents activity by a third party for compliance purposes. Content distributed through Two Cents’ sharing features and third-party integrations may result in displaying some of your personal information outside of Two Cents. For example, when you post content to a Two Cents Group that is open for public discussion, your content, including your name as the contributor, may be displayed in search engine results.

2.7. Polls and Surveys

Polls and Surveys may be conducted by Two Cents, Members, or third parties. Some third parties may target advertisements to you on the results page based on your answers in the poll. We may use third parties to deliver incentives to you to participate in surveys or polls. If the delivery of incentives requires your contact information, you may be asked to provide personal information to the third party fulfilling the incentive offer, which will be used only for the purpose of delivering incentives and verifying your contact information. It is up to you whether you provide this information, or whether you desire to take advantage of an incentive. Your consent to use any personally identifiable information for the purposes set forth in the poll or survey will be explicitly requested by the party conducting it.

2.8. Search

You can search for Members, business opportunities, information about companies, and community content from Two Cents Groups on Two Cents. For example, you can find Members with particular expertise or experience, or Members that you may know from your industry or profession. You can also find opportunities and information about companies. You can also find content from Two Cents Groups. We use personal information from Two Cents, including Member profiles, Groups content, and Company Pages, to inform and refine our search service.

2.9. Groups

If you participate in Two Cents Groups, or share content, you should be aware that any information you choose to disclose using these services can be read, collected, and used by other Members in these forums, developers, and other third parties. Two Cents is not responsible for the information you choose to submit in these forums. Some content in Two Cents Groups may be public and searchable on the Internet if the group administrator decides to make it public. However, by default this information is private to the group and the group administrator is encouraged to inform the group members before making such information public.

2.10. Testimonials and Advertisements Placed through Two Cents Ads

If you provide any testimonials about our goods or services or place advertisements through the Two Cents Ads, we may post those testimonials and examples of advertisements you place in connection with our promotion of these services to third parties. Testimonials and advertisements may include your name and other personal information that you have provided.

2.11. Compliance with Legal Process and Other Disclosures

It is possible that we may need to disclose personal information, profile information, or information about your activities as a Member or Visitor when required by law, subpoena, or other legal process, or if Two Cents has a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce the User Agreement, investigate and defend ourselves against any third-party claims or allegations, or protect the security or integrity of our Service; or (3) exercise or protect the rights, property, or safety of Two Cents, our Members, personnel, or others. We attempt to notify Members about legal demands for their data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. In light of our principles, we may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but do not commit to challenge every demand.

2.12. Disclosures to Others as the Result of a Change in Control or Sale of Two Cents Corporation

We may also disclose your personal information to a third party as part of a sale of the assets of Two Cents Corporation, a subsidiary, or division, or as the result of a change in control of the company or one of its affiliates, or in preparation for any of these events. Any third party to which Two Cents transfers or sells Two Cents assets will have the right to continue to use the personal and other information that you provide to us in the manner set out in this Privacy Policy.

2.13. Service Providers

We may employ third party companies and individuals to facilitate our Services (e.g. maintenance, analysis, audit, marketing and development). These third parties have limited access to your information only to perform these tasks on our behalf and are obligated to Two Cents not to disclose or use it for other purposes.

3. Your Choices & Obligations

3.1. Rights to Access, Correct, or Delete Your Information, and Closing Your Account

You have a right to (1) access, modify, correct, or delete your personal information controlled by Two Cents regarding your profile, (2) change or remove your content, and (3) close your account. You can also contact us for any account information which is not on your profile or readily accessible to you. If you close your account(s), your information will generally be removed from the Service within 24 hours. We generally delete closed account information and will de-personalize any logs or other backup information within 30 days of account closure, except as noted below.

Please note: Information you have shared with others or that others have copied may also remain visible after you have closed your account or deleted the information from your own profile. Two Cents Groups content associated with closed accounts may represent an unknown user as the source. In addition, you may not be able to access, correct, or eliminate any information about you that other Members copied or exported out of Two Cents, because this information may not be in our control. Your public profile may be displayed in search engine results until the search engine refreshes its cache.

3.2. Data Retention

We retain the personal information you provide while your account is in existence or as needed to provide you services. Two Cents may retain your personal information even after you have closed your account if retention is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes between Members, prevent fraud and abuse, or enforce this Privacy Policy and our User Agreement. We may retain personal information, for a limited period of time, if requested by law enforcement. Two Cents Customer Service may retain information for as long as is necessary to provide support-related reporting and trend analysis only, but we generally delete or de-personalize closed account data consistent with Section 3.1., except in the case of our plugin impression data, which we will try to de-personalize at the time of collection, but in any event, we will de-personalize within 7 days.

We may store data of users from third party sources under the condition that it is permitted by the users and the holder of such information. For example, allowed by LinkedIn’s API, users are allowed to add profile information sourced from their LinkedIn accounts. By adding such information to their Two Cents’ account, users have granted permission for Two Cents to store such data. At any time users have the ability to remove such data from their accounts.

3.3. Your Obligations

As a Member, you have certain obligations to other Members. Some of these obligations are imposed by applicable law and regulations and others have become commonplace in communities of like-minded Members such as Two Cents:

• You must, at all times, abide by the terms and conditions of the current Privacy Policy, User Agreement, and other policies of Two Cents. This includes respecting all intellectual property rights that may belong to third parties, such as trademarks or copyrights.

• You must not upload or otherwise disseminate any information that may infringe on the rights of others or which may be deemed to be injurious, violent, offensive, racist, or xenophobic, or which may otherwise violate the purpose and spirit of Two Cents and its community of Members.

• You must keep your username and password confidential and not share it with others.

Any violation of these guidelines or those detailed in our User Agreement or elsewhere may lead to the restriction, suspension, or termination of your account at the sole discretion of Two Cents.

4. Important Information

4.1. Minimum Age

As described in Section 2.3 of the User Agreement, persons must be of Minimum Age to use Two Cents. The minimum age is thirteen.

4.2. Changes to this Privacy Policy

We may change this Privacy Policy from time to time. If we make significant changes in the way we treat your personal information, or to the Privacy Policy, we will provide notice to you on the Services or by some other means, such as email. Please review the changes carefully. If you agree to the changes, simply continue to use our Services. If you object to any of the changes to our terms and you no longer wish to use Two Cents, you may close your account(s). Unless stated otherwise, our current Privacy Policy applies to all information that Two Cents has about you and your account. Using Two Cents after a notice of changes has been communicated to you or published on our Services shall constitute consent to the changed terms or practices.

4.3. Security

We have implemented security safeguards designed to protect the personal information that you provide in accordance with industry standards. Access to your data on Two Cents 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 the Two Cents Services. We also offer secure https access to the Two Cents.com website. To protect any data you store on our servers, we also regularly monitor our system for possible vulnerabilities and attacks, and we use a tier-one secured-access data center. However, since the Internet is not a 100% secure environment, we cannot ensure or warrant the security of any information that you transmit to Two Cents. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information. Please note that emails, instant messaging, and similar means of communication with other Members are not encrypted, and we strongly advise you not to communicate any confidential information through these means. Please help keep your account safe by using a strong password.