Privacy Statement

Effective as of January 1, 2010

Two Step Software, Inc. (“Two Step” or the “Company”) is committed to protecting the privacy of your information. This Privacy Statement describes Two Step’s information practices.

1. Web Sites Covered

This Privacy Statement covers the information practices of the Web sites: http://www.twostep.com and http://www.corporatefocus.net (collectively referred to as the “Company’s Web Sites”). The “System” refers to the use of the online application Corporate Focus from the Web site: http://www.corporatefocus.net.

The Company’s Web Sites may contain links to other Web sites. Two Step is not responsible for the information practices or the content of such other Web sites. The Company encourages you to review the privacy statements of other Web sites to understand their information practices.

2. Personal Information Collected

Two Step offers a variety of online applications that are collectively referred to as the “System.” Two Step collects information from individuals who visit the Company’s Web Sites (“Visitors”) and individuals who register to use the System (“Customers”).

When expressing an interest in obtaining additional information about the System or registering to use the System, Two Step requires you to provide the Company with contact information, such as name, company name, address, phone number, and email address (“Required Contact Information”). When purchasing the System, Two Step requires you to provide the Company with contact and billing information, such as billing name and address, and the number of employees within the organization that will be using the System (“Billing Information”). Two Step may also ask you to provide additional information, such as business interest, number of employees, or industry (“Optional Information”). Required Contact Information, Billing Information, and Optional Information are referred to collectively as “Data About Two Step Customers.”

As you navigate the Company’s Web sites, Two Step may also collect information through the use of commonly-used information-gathering tools, such as cookies and Web beacons (“Web Site Navigational Information”). Web Site Navigational Information includes standard information from your Web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on the Company’s Web sites (such as the Web pages viewed and the links clicked). For additional information about Two Step’s collection of Web Site Navigational Information, please click here.

3. Use of Information Collected

The Company uses Data About Two Step Customers to perform the services requested. For example, if you fill out a “Contact Me” Web form, the Company will use the information provided to contact you about your interest in the System.

The Company may also use Data About Two Step Customers for marketing purposes. For example, the Company may use information you provide to contact you to further discuss your interest in Two Step, the System, and to send you information regarding the Company and its partners, such as information about promotions or events.

In the event that Two Step collects any credit card information, it is used solely to check the financial qualifications of prospective Customers and to collect payment for the System.

Two Step uses Web Site Navigational Information to operate and improve the Company’s Web Sites. The Company may also use Web Site Navigational Information in combination with Data About Two Step Customers to provide personalized information about the Company.

For additional information about the Company’s use of Web Site Navigational Information, please click here.

4. Web Site Navigational Information

Two Step uses commonly-used information-gathering tools, such as cookies and Web beacons, to collect information as you navigate the Company’s Web sites (“Web Site Navigational Information”). This section describes the types of Web Site Navigational Information the Company may collect and how the Company may use this information.

Cookies

Two Step uses cookies to make interactions with the Company’s Web sites easy and meaningful. When you visit one of the Company’s Web Sites, Two Step’s servers send a cookie to your computer. Standing alone, cookies do not personally identify you. They merely recognize your Web browser. Unless you choose to identify yourself to Two Step, either by responding to a promotional offer, opening an account, or filling out a Web form (such as a “Contact Me” or a “Sign Me Up” Web form), you remain anonymous to the Company.

There are two types of cookies: session-based and persistent-based. Session cookies exist only during one session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you close your browser or turn off your computer.

If you have chosen to identify yourself to Two Step, the Company uses session cookies containing encrypted information to allow the Company to uniquely identify you. Each time you log into the System, a session cookie containing an encrypted, unique identifier that is tied to your account is placed in your browser. These session cookies allow the Company to uniquely identify you when you are logged into the System and to process your online transactions and requests. Session cookies are required to use the System.

Two Step uses persistent cookies that only the Company can read and use to identify browsers that have previously visited the Company’s Web sites. When you purchase the System or provide the Company with personal information, a unique identifier is assigned you. This unique identifier is associated with a persistent cookie that the Company places on your Web browser. The Company is especially careful about the security and confidentiality of the information stored in persistent cookies. For example, the Company does not store account numbers or passwords in persistent cookies. If you disable your Web browser’s ability to accept cookies, you will be able to navigate the Company’s Web sites, but you will not be able to successfully use the System.

Two Step may use information from session and persistent cookies in combination with Data About Two Step Customers to provide you with information about the Company and the System.

Web Beacons

Two Step uses Web beacons alone or in conjunction with cookies to compile information about Customers and Visitors’ usage of the Company’s Web Sites and interaction with emails from the Company. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular Web site tied to the Web beacon, and a description of a Web site tied to the Web beacon. For example, Two Step may place Web beacons in marketing emails that notify the Company when you click on a link in the email that directs you to one of the Company’s Web sites. Two Step uses Web beacons to operate and improve the Company’s Web sites and email communications. Two Step may use information from Web beacons in combination with Data About Two Step Customers to provide you with information about the Company and the System.

IP Addresses

When you visit Two Step’s Web sites, the Company collects your Internet Protocol (“IP”) addresses to track and aggregate non-personally identifiable information. For example, Two Step uses IP addresses to monitor the regions from which Customers and Visitors navigate the Company’s Web sites.

Two Step also collects IP addresses from Customers when they log into the System as part of the Company’s security monitoring features.

Third Party Cookies

From time-to-time, Two Step engages third parties to track and analyze non-personally identifiable usage and volume statistical information from individuals who visit the Company’s Web sites. Two Step may also use other third-party cookies to track the performance of Company advertisements. The information provided to third parties does not include personal information, but this information may be re-associated with personal information after the Company receives it. This Privacy Statement does not cover the use of third party cookies.

5. Public Forums, Refer a Friend, and Customer Testimonials

Two Step may provide bulletin boards, blogs, or chat rooms on the Company’s Web sites. Any personally identifiable information you choose to submit in such a forum may be read, collected, or used by others who visit these forums, and may be used to send you unsolicited messages. Two Step is not responsible for the personally identifiable information you choose to submit in these forums.

Customers and Visitors may elect to use the Company’s referral service to inform friends about the Company’s Web sites. When using the referral service, the Company requests the friend’s name and email address. Two Step will automatically send the friend a one-time email inviting him or her to visit the Company’s Web sites. Two Step does not store this information.

Two Step posts a list of Customers and testimonials on the Company’s Web sites that contain information such as Customer names and titles. Two Step obtains the consent of each Customer prior to posting any information on such a list or posting testimonials.

6. Sharing of Information Collected

Two Step may share Data About Two Step Customers with the Company’s agents so that these agents can contact Customers and Visitors who have provided contact information on our behalf.
Two Step may also share Data About Two Step Customers with the Company’s agents to ensure the quality of information provided. Two Step does not share, sell, rent, or trade personally identifiable information with third parties for their promotional purposes.

Two Step uses a third-party intermediary to manage credit card processing. This intermediary is not permitted to store, retain, or use Billing Information except for the sole purpose of credit card processing on the Company’s behalf.

Two Step reserves the right to disclose personally identifiable information of the Company’s Customers or Visitors if required by law or if the Company reasonably believes that disclosure is necessary to protect the Company’s rights and/or to comply with a judicial proceeding, court order, or legal process.

7. Communications Preferences

Two Step offers Customers and Visitors who provide contact information a means to choose how the Company uses the information provided. You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of the Company’s marketing emails. Additionally, you may send a request specifying your communications preferences to
support@twostep.com. Customers cannot opt out of receiving transactional emails related to their account with Two Step or use of the System.

8. Correcting and Updating Your Information

Customers may update or change their registration information by editing their user or organization record. To update a user profile, please login to the System with your Two Step username and password. To update an organization’s information or to update Billing Information or have your registration information deleted, please email: support@twostep.com or call (800) 223-8900. To discontinue your account and to have information you maintained in the System returned to you, please email support@twostep.com or call (800) 223-8900. Requests to access, change, or delete your information will be handled within 30 days.

9. Customer Data

Two Step Customers use the System to track their own data and information (“Customer Data”). Two Step will not review, share, distribute, or reference any such Customer Data except as provided in the Two Step Master Subscription Agreement or as may be required by law. Individual records of Customer Data may be viewed or accessed only for the purpose of resolving a problem, support issues, or a suspected violation of the Two Step Master Subscription Agreement or as may be required by law. Customers are responsible for maintaining the security and confidentiality of their user names and passwords.

10. Security

Two Step values the trust of its Customers and understands that handling confidential information with care is our most important responsibility. Two Step utilizes some of the most advanced technology for Internet security available today ensuring that your data is safe, secure, and available only to authorized users in your organization. Visitor and Customer information is stored in a secure server environment that uses firewalls and other advanced technologies to prevent interference or access from outside intruders. The Two Step Security Statement can be viewed here.

11. Changes to this Privacy Statement

This Privacy Statement is subject to change by Two Step at any time. If we are going to use your personally identifiable information in a manner materially different from that stated at the time of collection, we will notify you via email, on our Web site, or as we deem appropriate. In addition, if we make any material changes in our privacy practices that do not affect Visitor or Customer information already stored by Two Step in its systems, we will post a prominent notice in this Privacy Statement or on our Web site or otherwise as we deem appropriate notifying Visitors or Customers of the change.

12. Contacting Us

Questions regarding this Privacy Statement or the information practices of the Company’s Web sites should be directed to Two Step Privacy by clicking here or by mailing: Two Step Compliance Dept., Two Step Software, 144 Gould Street, Suite 202, Needham, MA 02494.

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