Privacy Statement

Release Date: May 2, 2015.

We want to earn your trust by being transparent about how GistPals works. You should read this policy in its entirety, but should pay particular attention to these four highlights:

• GistPals is designed to make sharing your information with anyone you want easy. You decide how much information you feel comfortable sharing and you control how it is distributed through your privacy settings. You should review the default privacy settings and change them if necessary to reflect your preferences. You should also consider your settings whenever you share information.

• Also, GistPals is a platform for sharing your information with third party applications and websites embedded. You control how information is shared with those third-party applications and websites since they are not directly linked to our services.

• Certain categories of information such as your name, profile photo, list of network pals, pages of other members who have added you as a pal, gender, geographic region, and groups you belong to are considered publicly available to everyone within the online community, and therefore do not have privacy settings. You can, however, limit the ability of others to find this information through your privacy settings.

• GistPals is a free service supported primarily by advertising. We will not share your information with advertisers without your consent. We allow advertisers through our platform to select characteristics of users they want to show their advertisements to.

This policy contains eight sections, and you view them in detail below:

1. Introduction

2. Information We Receive

3. Information You Share With Third Parties

4. How We Use Your Information

5. How We Share Information

6. How You Can View, Change, or Remove Information

7. How We Protect Information

8. Other Terms

1. Introduction

Questions. If you have any questions or concerns about our privacy policy, contact our privacy team through email: [email protected]

Scope. This privacy policy covers all of GistPals. It does not, however, apply to third party entities that GistPals does not own or control, such as third party widgets and websites. By using or accessing GistPals, you agree to our privacy practices outlined here.

No information from children under age 13. If you are under age 13, please do not attempt to register or provide any personal information about yourself to us. If we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from a child under age 13, please contact us immediately.

Parental participation. We strongly recommend that minors 13 years of age or older ask their parents for permission before sending any information about themselves to anyone over the Internet and we encourage parents to teach their children about safe internet use practices.

2. Information We Receive

Information you provide to us:

Personal information. When you sign up for GistPals you provide us with your name, email, gender, and occupation. During the registration process we give you the opportunity to provide additional profile information, such as your country, and to add a picture of yourself, to help your friends connect with you. In some cases we may ask for additional information for security reasons or to provide specific services to you. Once you register you can visit your profile at any time to add or remove personal information about yourself. You can add basic information about yourself, such as information about your hometown, current-city, relationships, and your occupation. You can also add other information about yourself including your interests and contact information.

Friend Information. We offer contact importer tools to help you upload your friends’ addresses so that you can find your friends on GistPals, and invite your contacts who do not have GistPals accounts to join. We do not store this information and if you give us your password to retrieve those contacts, we will not store your password after you have uploaded your contacts’ information.

Information we collect when you interact with GistPals:

Site activity information. We keep track of the actions you take on GistPals, such as adding a pal, becoming a pal on a Member’s Wall, adding a gist, indicating you “like” a post, or authorizing an application. In some cases you are also taking an action when you provide information or content to us. For example, if you share a photo, in addition to storing the actual content you uploaded, we might log the fact you shared it.

Access Device and Browser Information. When you access GistPals from a computer, mobile phone, or other device, we may collect information from that device about your browser type, location, and IP address, as well as the pages you visit.

Cookie Information. We use "cookies" (small pieces of data we store for an extended period of time on your computer, mobile phone, or other device) to make GistPals easier to use, to protect both you and other members. For instance, we use them to store your login ID (but never your password) to make it easier for you to login whenever you come back to GistPals. We also use them to confirm that you are logged into GistPals, and to know when you are interacting with third party applications and websites, our widgets and Share buttons, and our advertisements. You can remove or block cookies using the settings in your browser, but in some cases that may impact your ability to use GistPals.

Information we receive from third parties:

Social Widgets, third-party apps and Websites. We do not own or operate the applications that you use through GistPals Platform (such as games and utilities) or the websites that you interact with through GistPals. We refer to them as Third party applications and websites because they use our Platform to provide you with social features. Whenever you authorize a third party application or website, we will receive information from them, including information about actions you take. In some cases, in order to personalize the process of connecting, we may receive a limited amount of information even before you authorize the application or website.

Information from other websites. We may institute programs with advertising partners and other websites in which they share information with us:

- We may receive information about whether or not you’ve seen or interacted with certain ads on other sites in order to measure the effectiveness of those ads.

3. Information You Share With Third Parties

We take steps to ensure that third party websites and others use information that you share on GistPals in a manner consistent with your privacy settings, but we cannot guarantee that they will follow our rules. Read the following section to learn more about how you can protect yourself when you share information with third parties.

Sharing information on GistPals. We designed our privacy settings to enable you to control how you share your information on GistPals. You should review the default privacy settings to make sure they reflect your preferences. Here are some specific things to remember:

- You can control the visibility of most of the information you share on GistPals through the privacy settings you select.

- Certain categories of information such as your name, profile photo, gender and geographic region are considered publicly available, and therefore do not have privacy settings.

- Some of the content you share and the actions you take will show up on your pals’ activity feed and your activity feed.

- Even after you remove information from your profile or delete your account, copies of that information may remain viewable elsewhere to the extent it has been shared with others, it was otherwise distributed pursuant to your privacy settings, or it was copied or stored by other users.

- You understand that information might be re-shared by other users.

- Certain types of communications that you send to other users cannot be removed, such as messages.

- When you post information on another user’s page or comment on another user’s post, that information will be subject to the other user’s privacy settings.

- If you use an external source to publish information to GistPals (such as a mobile application or a Connect site), you should check the privacy setting for that post, as it is set by that external source.

“Everyone” Privacy Setting. Information set to “Everyone” is publicly available information, may be accessed by everyone on GistPals, and may be imported and exported by us and others without privacy limitations. The default privacy setting for certain types of information you post on GistPals is set to “Everyone”. You can review and change the default settings in your privacy settings. If you delete “Everyone” content that you posted on GistPals, we will remove it from your GistPals profile, but have no control over its use outside of GistPals.

GistPals Platform. As mentioned above, we do not own or operate third-party applications or websites. That means that when you visit third party applications and websites you are making your GistPals information available to someone other than the Network Administrator. To help those applications and sites operate, they receive publicly available information automatically when you visit them, and additional information when you formally authorize or connect your GistPals account with them. You can learn more details about which information the operators of those applications and websites can access through their privacy policy. We use technical measures to ensure that they only obtain authorized information. We also give you tools to control how your information is shared with them:

- You can use your privacy settings to limit which of your information is available to “Everyone” (by default, every member including those you have not connected with, can access “Everyone” and other publicly available content)

- We may make information about the location of your computer or access device available to third party applications and websites in order to help them implement appropriate security measures.

You should always review the policies of third party applications and websites to make sure you are comfortable with the ways in which they use information you share with them. We do not guarantee that they will follow our rules. If you find an application or website that violates our rules, you should report the violation to us on the help page and we will take action as necessary.

Exporting Information. You (and those you make your information available to) may use tools like RSS feeds, mobile phone address books, or copy and paste functions, to capture and export information from GistPals, including your information and information about you.

Links. When you click on links that navigates you out of GistPals, we are not responsible for the privacy practices of other sites, and we encourage you to read their privacy statements.

4. How We Use Your Information

We use the information we collect to try to provide a safe, efficient, and customized experience. Here are some of the details on how we do that:

To manage the service. We use the information we collect to provide our services and features to you, to measure and improve those services and features, and to provide you with customer support. We use the information to prevent potentially illegal activities, and to enforce our privacy and community regulation policies. We also use a variety of technological systems to detect and address anomalous activity and screen content to prevent abuse such as spam. These efforts may on occasion result in a temporary or permanent suspension or termination of some functions for some users.

To contact you. We may contact you with service-related announcements from time to time. You may opt out of all communications except essential updates through your newsletter settings page. We may include content you see on GistPals in the emails we send to you.

Downloadable Software. Certain downloadable software applications and applets that we offer, such as our video and photo uploaders, transmit data to us. We may not make a formal disclosure if we believe our collection of and use of the information is the obvious purpose of the application, such as the fact that we receive photos when you use our photo uploader. If we believe it is not obvious that we are collecting or using such information, we will make a disclosure to you the first time you provide the information to us so that you can decide whether you want to use that feature.

Memorializing Accounts. If we are notified that a user is deceased, we may memorialize the user’s account. In such cases we restrict profile access to confirmed contacts, and allow pals and family to write on the user’s page in remembrance. We may close an account if we receive a formal request from the user’s next of kin or other proper legal request to do so.

5. How We Share Information

GistPals is about sharing information with others — friends and people in your networks — while providing you with privacy settings that you can use to restrict other users from accessing your information. We share your information with third parties when we believe the sharing is permitted by you, reasonably necessary to offer our services, or when legally required to do so.

When you make a payment. When you enter into transactions with others or make payments on GistPals, we will only share transaction information with those third parties necessary to complete the transaction and will require those third parties to agree to respect the privacy of your information.

When you invite a friend to join. When you ask us to invite a friend to join GistPals, we will send your friend a message on your behalf using your name. We may also send up to two reminders to them in your name. If your friend does not want us to keep their information, we will remove it at their request.

When you choose to share your information with marketers. You may choose to share information with marketers or electronic commerce providers that are not associated with GistPals through on-site offers. This is entirely at your discretion and we will not provide your information to these marketers without your consent.

To help your friends find you. By default, we make certain information you have posted to your profile available in search results on GistPals to help your friends find you. However, you can control who has access to this information through your privacy settings.

To give search engines access to publicly available information. We generally limit search engines’ access to our site. We may allow them to access information set to the “Everyone” setting (but you can turn off the “Everyone” setting through your privacy settings).

To help improve or promote our service. Sometimes we share aggregated information with third parties to help improve or promote our service. But we only do so in such a way that no individual user can be identified or linked to any specific action or information.

To provide you with services. We may provide information to service providers that help us bring you the services we offer. For example, we may use third parties to help host our website, send out email updates about GistPals, remove repetitive information from our user lists, process payments, or provide search results or links (including sponsored links). These service providers may have access to your personal information for use for a limited time, but when this occurs we implement reasonable contractual and technical protections to limit their use of that information to helping us provide the service.

To advertise our services. We may ask advertisers outside of GistPals to display ads promoting our services. We may ask them to deliver those ads based on the presence of a cookie, but in doing so will not share any other information with the advertiser.

To offer joint services. We may provide services jointly with other companies. If you use these services, we may share your information to facilitate that service. However, we will identify the partner and present the joint service provider’s privacy policy to you before you use that service.

To respond to legal requests and prevent harm. We may disclose information pursuant to court orders, or other requests (including criminal and civil matters) if we have a good faith belief that the response is required by law. This may include respecting requests from jurisdictions outside of the Nigeria where we have a good faith belief that the response is required by law under the local laws in that jurisdiction, apply to users from that jurisdiction, and are consistent with generally accepted international standards. We may also share information when we have a good faith belief it is necessary to prevent fraud or other illegal activity, to prevent imminent bodily harm, or to protect ourselves and you from people violating our policies. This may include sharing information with other companies, lawyers, courts or other government entities.

Transfer in the Event of Sale or Change of Control. If the ownership of all or substantially all of our business changes, we may transfer your information to the new owner so that the service can continue to operate. In such a case, your information would remain subject to the promises made in any pre-existing Privacy Policy.

6. How You Can View, Change, or Remove Information

Viewing and editing your profile. You may change your profile information at any time by going to your account profile page and clicking the edit Profile link on the page. Your profile information will be updated immediately after you save changes on the edit profile page.

Suspending or deleting your account. If you want to stop using your account you may delete it or suspend it by contacting us. When we suspend an account, no user will be able to see it, but it will not be deleted. We save your profile information (pals, photos, interests, etc.) in case you later decide to reinstate your account. Many users suspend their accounts for temporary reasons and in doing so are asking us to maintain their information until they return to GistPals. You will still have the ability to reinstate your account and restore your profile in its entirety. When we delete an account, it is permanently deleted. You should only delete your account if you are certain you never want to use it. You may suspend or delete your account by contacting us through sending a message to Network Administrator or sending email to [email protected]

Limitations on removal. Even after you remove information from your profile or delete your account, copies of that information may remain viewable elsewhere to the extent it has been shared with others, it was otherwise distributed pursuant to your privacy settings, or it was copied or stored by other users. However, your name will no longer be associated with that information on GistPals. (For example, if you post something to another user’s profile, and then you delete your account, that post may remain, but be attributed to an “Anonymous GistPals User.”) Additionally, we may retain certain information to prevent identity theft and other misconduct even if deletion has been requested.

Non-user contact information. If a user provides your email address to us, and you are not a GistPals user but you want us to delete your address, you can do so on by contacting Network Administrator or emailing us. However, that request will only apply to addresses we have at the time of the request and not to any addresses that users provide to us later.

7. How We Protect Information

We do our best to keep your information secure, but we need your help.

Steps we take to keep your information secure. We keep your account information on a secured server behind a firewall. When you enter sensitive information (such as credit card numbers and passwords), we encrypt that information using secure socket layer technology (SSL). We also use automated and social measures to enhance security, such as analyzing account behavior for fraudulent or otherwise anomalous behavior, may limit use of site features in response to possible signs of abuse, may remove inappropriate content or links to illegal content, and may suspend or disable accounts for violations of our policies.

Risks inherent in sharing information. Although we allow you to set privacy options that limit access to your information, please be aware that no security measures are perfect or impenetrable. We cannot control the actions of other users with whom you share your information. We cannot guarantee that only authorized persons will view your information. We cannot ensure that information you share on GistPals will not become publicly available. We are not responsible for third party circumvention of any privacy settings or security measures on GistPals. You can reduce these risks by using common sense security practices such as choosing a strong password, using different passwords for different services, and using up to date antivirus software.

Report Violations. You should report any security violations to us on the help page or by email: [email protected]

8. Other Terms

Changes. We may change this Privacy Policy, unless stated otherwise, our current privacy policy applies to all information that we have about you and your account. If we make changes to this Privacy Policy we will notify you by publication here. You can make sure that you receive notice directly by enabling newsletter setting for your account.

Consent to Collection and Processing in Nigeria. By using GistPals, you consent to having your personal data transferred to and processed in Nigeria.

Defined Terms. "Us," "we," "our," "Platform" and "GistPals" mean the same and “content” are used more generally and interchangeably here unless otherwise limited by the context.

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