ENTERPROID, INC. (d/b/a DIVIDE)

PRIVACY POLICY

ENTERPROID, INC. (d/b/a DIVIDE), and its affiliated companies (collectively, “we“) have created this statement (this “Privacy Policy“) to explain and summarize how we collect, use and protect, or in some cases do not protect, your personally-identifiable information (“PII“) through our websites, services, and related software (collectively, the “Services”).  We reserve the right to change this Privacy Policy at any time, by posting a new Privacy Policy at www.divide.com/legal/privacy.  You are responsible for periodically checking www.divide.com/legal/privacy for changes.   By accessing the Services, you indicate your understanding and acceptance of the terms of this Privacy Policy, and consent to the collection, retention and use of your PII consistent with this Privacy Policy, as amended from time to time.  Your use of the Services is governed at all times by the Terms of Use for the Services, which may be found at http://www.divide.com/legal/tos.  If you are accessing the Services from outside the United States, there may be other laws applicable to your PII.

CAUTION REGARDING PUBLIC DISCLOSURES

Anything, including your PII, that you disclose in public forums, such as news groups, comment sections on websites, and chat rooms becomes public information.  We cannot control the use of information disclosed in public forums.  You should exercise caution when disclosing information in public forums. IF YOU CHOOSE TO USE YOUR REAL NAME OR OTHERWISE DISCLOSE YOUR PII IN A PUBLIC FORUM, THAT INFORMATION WILL BE AVAILABLE TO AND VIEWABLE BY ANYONE ACCESSING SUCH FORUM, INCLUDING VIA A SEARCH ENGINE.

1. INFORMATION WE COLLECT

We collect PII that you provide to us or that we learn from your use of the Services.

We also collect information about, or related to, you that is not PII, such as which mobile device or browser you use to access the Services.  While we log this information, we generally do not match this information with your PII.  Provided that we have not matched this non-PII with your PII, we may use this non-PII internally or share it with third parties for any purpose.

We collect PII from you in several ways:

-       In order to access certain aspects of the Services, you may be required to create a user account and provide certain PII such as your name, email address, birth date, mobile telephone number, and mobile service provider.  REGARDLESS OF ANY OTHER PROVISION OF THIS PRIVACY POLICY, WE MAY PERMANENTLY STORE ANY PII PROVIDED BY YOU VIA SUCH REGISTRATION PROCESS.

-       We may collect PII from you in order to process an order from you, in connection with a support request from you, or otherwise in support of our operation, and your use, of the Services.

-       We may observe technical aspects of your activities, preferences, and transactions (such as your IP address) relating to your use of the Services. While we may collect or log this information, we generally do not identify you or match this information with your other PII.

-       You may provide us with PII in connection with a job application or inquiry.

-     We may collect, on behalf of the entity whose information technology (IT) infrastructure you are accessing via the Divide Services (your “IT department“), any and all information, including PII, that is stored, accessed, communicated via, or otherwise available on the “professional” side of your mobile device.  You should therefore assume that all activities, data, and usage on the “professional” side of your mobile device and the Services are available to your IT department.

-       We may collect, at your request, information regarding the physical location of your mobile device.  We do not track this information over time, but instead make it available to you, and if you enable it, your IT department on a point-in-time basis.  You may adjust these settings through the Services.  By default, both location tracking and sharing of location information are disabled.

-       We track detailed pin register information regarding data, SMS/MMS, and telephony usage on the “professional” side of your mobile device (for example, to whom SMS messages are sent and when, but not the content of the message), and make this information available to both you and your IT department.  We collect aggregate data, SMS/MMS, telephony usage (total bandwidth, messages, and minutes only) for your mobile device as a whole, which, when correlated with your “professional” usage, allows derivation of your aggregate personal data, SMS/MMS, telephony usage in the “personal” side of your device.  Accordingly, we only disclose your total usage to you, and not your IT department.

2. USES OF COLLECTED INFORMATION

We do not share your PII with third parties for their direct marketing purposes. 

Performance of the Services.  We may use your PII to diagnose technical problems, to facilitate your use of the Services, to track aggregate traffic patterns throughout the Service, or to otherwise improve the performance and utility of the Services.

IT Management.  As described above, your IT department has full access to your usage of the “professional” side of your mobile device, including the ability to add, change, and delete anything and everything on the “professional” side of your device.   If you enable, your IT department will also have access to your location at any given time, even if you are not actively using the “professional” side of your device.  You have access to the information we collect about you, as described above, and may choose to enable us to, at your request, wipe your entire device, including both the “professional” and “personal” sides, for example if your mobile device is stolen.

Notifications.  We may use your PII to notify you about changes to the Services, new products and services, and special offers that may be of interest to you.

Business Partners. We use business partners to provide certain services on our behalf, such as technical and customer support, shipping, credit card processing, and product fulfillment.  We require these business partners to safeguard your PII.  We endeavor to limit their access to and use of our PII to that required to enable them to perform their jobs.  

Human Resources.  If you provide your PII to us as part of an application for employment, we may use that PII for the purpose of employment consideration. We may keep your PII on file for future consideration.

Mergers, Acquisitions and Bankruptcy. We may transfer all PII in our possession to a successor organization in the event of a merger, acquisition, or bankruptcy or other sale of all or a portion of our assets. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred PII will be subject to this Privacy Policy, as it may be amended from time to time.

As Required by Law and Other Extraordinary Disclosures. We may disclose your PII to: (a) comply with legal process (such as a court order, subpoena, search warrant, etc.) or other legal requirements of any governmental authority; (b) potentially mitigate our liability in an actual or potential lawsuit; (c) protect our rights or property; or (d) protect the interest of other users of the Services.

Aggregation of Information.  In support of our operations and business activities, we may aggregate data that individually might be considered PII, but as a result of the aggregation, becomes anonymized.  For example, while your specific address would be PII, data on the overall number of subscribers with addresses in your zip code would not be able to be used to identify you, and is therefore not PII.  We will ensure that sample sets and categories across which we aggregate are broad enough to preclude identification of individuals.  Since this aggregated information is not PII, we may use it internally or disclose it to third parties for any purpose.

3. CHILDREN

We not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to register or use the Services.  If you are under 13, you are forbidden to register for the Services or provide any information to us.  If someone under 13 provides any information to us, and we learn the person submitting the information is under 13, we will attempt to delete this information as soon as possible. Because we do not knowingly collect any personal information from anyone under 13, we do not use such information or disclose it to third parties.

4. SECURITY

We use reasonable security measures to protect data transmissions.  However, no data transmissions over the Internet can be guaranteed to be 100% secure.  Consequently, we cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk.  We are not responsible for circumvention of any privacy settings or security measures in the Services.

You understand and acknowledge that, even after your subscription terminates, or you otherwise attempt to delete your PII from the Services, copies of your PII and other materials posted by you may remain viewable in, for example, cached or archived pages.

If we learn of a security breach that affects you, we will attempt to notify you electronically so that you can take appropriate protective steps.  By using the Services or otherwise providing PII to us, you agree that we can communicate with you electronically, including regarding security, privacy and administrative issues.  We may post a notice on the Services if a security breach occurs.  We may also send an email to you at the email address you provide to us during registration, as updated by you.

5. CONTACT PREFERENCES

Generally, when we contact you, we will try to provide you with an easy and convenient way to notify us if you would not like further similar communications. 

6. CONTACTING US

If you have any questions, comments, or concerns about this Privacy Policy, or would like to make changes to your PII or contact preferences, or delete PII you have provided to us, please email us at support@divide.com or contact us at the address below.  You may make changes to your PII or contact preferences through the Services.

Postal Mail Address:

ENTERPROID, INC. (d/b/a DIVIDE)

Attn: Privacy Support

56 West 22th Street, 10th Floor

New York

NY, 10010