PRIVACY POLICY

SCOPE OF THIS POLICY This privacy policy ("Policy") explains how personal information is collected, used and disclosed by SmithOps LLC ("SmithOps", "we" or "us") with respect to your use of the website located at http://www.smithops.com (the "Site") and the services provided by SmithOps and accessed through the Site (the "Services").

CHANGES TO THIS POLICY We may revise and update this Policy at any time. We will provide notice that changes have been made by posting the revised Policy and updating the revision date at the top of the Policy. We encourage you to review the Policy whenever you visit the Site to make sure that you understand how your personal information is treated.

PERSONAL INFORMATION WE COLLECT We may collect various types of information about you including personal, demographic and aggregate data. "Personal information" means information that specifically identifies you such as your name, telephone number and email address. Personal information does not include aggregate information, which is data we collect about the use of the Site or the Services or categories of such users, unless it is linked with your other personal information. Aggregate data is used for a number of purposes such as to help us understand trends and user needs so that we can improve our products and services and is not subject to this Policy unless it is linked to your personal information. Personal information you voluntarily provide us may be collected in a number of ways through the Site and the Services, such as when you register for an account or send us an email. If you are a Sponsored Group owner (the corporate originator of a Group with the ability to invite users to join) we also will collect your credit card and/or billing information. Please see the section below Use of Cookies, IP Addresses and Web Beacons for a description of how some personal information also may be automatically collected through your use of the Site or the Services.

USES OF PERSONAL INFORMATION In general, we use personal information that we collect to process your requests or transactions, to facilitate your use and our administration and operation of the Site and the Services, to provide you with information or services you request, to inform you about other information, events, products or services we think will be of interest to you, and to learn more about and improve the Site and the Services. For example, we may use the information we collect to:

  1. provide you with the services you request and to complete any transactions or enable the use of any features;
  2. send you a welcoming, account related or customer service email;
  3. respond to your emails, submissions, comments, requests or complaints;
  4. process payments;
  5. request feedback and to enable us to develop, customize and improve the Site, the Services and new offerings; and

SHARING OF PERSONAL INFORMATION SmithOps does not sell or rent personal information to third parties or share personal information with third parties. We may share personal information with consultants, vendors and service providers ("Service Providers") who perform functions on our behalf. In addition, we may share your information with third parties if we have a good faith belief that the disclosure is necessary or appropriate to comply with law or legal process; to protect and defend the rights and property or personal safety of SmithOps, our customers or the public; to prevent and protect SmithOps and our users from fraudulent, abusive, unlawful or unauthorized use of the Site; or to otherwise enforce our rights and agreements. Your personal information also may be disclosed or transferred as part of, or during negotiations of, any merger, sale of company assets, financing or acquisition or in any other situation where personal information may be transferred as one of the business assets of SmithOps.

USE OF COOKIES The Site and some Services on our Site, may contain "cookies." A cookie is a piece of data that is stored on your hard drive and records your preferences and other data about your visit to the Site. If we combine cookies with or link them to any personally identifiable information, we will treat this information as personal information; otherwise it is treated as and used in the aggregate. Most internet browsers will allow you to erase cookies from your hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. If you block cookies, some portions of the Site and the Service may not function properly.

PROTECTING PERSONAL INFORMATION We strive to protect personal information while it is under our control. Your account information is accessible online only through the use of a password. To help protect the confidentiality of your personal information, you must keep your password confidential and not disclose it to any other person. You are responsible for all uses of the Site by any person using your password. Please advise us immediately if you believe your password has been compromised or misused.

PROMOTIONAL EMAILS SmithOps does not send out promotional emails about our products and/or services to current account holders of our Service. Please note, however, you may still receive transactional and relationship emails, including messages relating to transactions or services you have specifically requested, responding to any email from you to us, notifying you of updates or changes to our policies and procedures, or which otherwise provide you with information we believe is important to users.

SPECIAL NOTICE REGARDING CHILDREN The Site and the Services are not designed for nor do we knowingly collect personal information from children under the age of 13.

LINKS TO OTHER WEB SITES Any links from the Site to third party Web sites are provided for your convenience. Personal information you provide on the linked pages is provided directly to that third party and is not subject to this Policy. Please review the third party's privacy policy to better understand their privacy practices.

CONTACT INFORMATION TO CORRECT AND UPDATE PERSONAL INFORMATION OR OBTAIN ADDITIONAL INFORMATION If you have any questions, complaints or comments regarding our Policy or practices or you wish to verify, correct or delete any personal information we have collected, please contact us at privacy@www.smithops.com. We will endeavor to respond to your inquiry or information request to the extent possible.

Last modified: March 20, 2012