Privacy

Privacy Policy

Date of Last Revision: May 3, 2010

This Privacy Policy ("Policy") applies to the website owned and operated by Alaye ("Company," "we," or "us") located at www.swapright.com (the "Site").

The Policy is designed to tell you how we collect and use personal information (as

defined below) so you can make an informed decision about using the Site. Please

read this Policy before using the Site or submitting any personal information to

us or to the Site. We reserve the right to change the provisions of this Policy at any time

by posting a revised Policy on the Site and indicating on the Policy the date it

was last updated. Your use of the Site following the posting of such changes or

revised statement shall constitute your acceptance of any such changes. We encourage

you to review our Policy whenever you visit the Site to determine if any changes

have been made and to make sure that you understand how any personal information

you provide will be used.

Personal Informtion

We do not sell, share, or rent any personal information to others in ways different

from what is disclosed in this Policy without first obtaining your consent, although

we may provide aggregate information or other nonpersonal information to third parties

without your authorization. We may share your contact information with third parties

if you have indicated to us that you wish to receive information from such parties.

In the event that we engage or partner with third party vendors, consultants or

other service providers in connection with the operation of the Site and our business

("Service Providers"), we may share personal information with such Service Providers

who need access to such information to carry out their work for us.

You should also note that information that you post to the Site, may become publicly

available. Your posting to the Site constitutes your consent to share

such information publicly.

We also may disclose personal information when we are required to or we believe

it is appropriate to comply with the law (e.g., a lawful subpoena, warrant or court

order); to enforce or apply this Policy or our other policies or agreements; to

initiate, render, bill, and collect for amounts owed to us; to protect our or our

users' or our rights, property or safety; to protect our customers our us from fraudulent,

abusive, or unlawful use of our Site; or if we believe that an emergency involving

the danger of death or serious physical injury to any person requires disclosure

of communications or justifies disclosure of personal information. In addition,

information about our customers, including personal information, may be disclosed

as part of any merger, acquisition, debt financing, sale of company assets, as well

as in the event of an insolvency, bankruptcy or receivership in which personally

identifiable information could be transferred to third parties as one of the business

assets of the Company.

Email

We will use e-mail to send you news and service updates, as well as notification of messages from other users

unless you "opt out" to receiving such e-mails by using the unsubscribe

links within the e-mails that we send. Please note, however, that as long as you

maintain an account, you may not "opt out" of receiving service or account-related

e-mails from the Company.

Cookies

A cookie is a small amount of data, which often includes an anonymous unique identifier,

which is sent to your browser from a web site's computers and stored on your computer's

hard drive.

Cookies are required to use the SwapRight service.

We use cookies to record current session information, but do not use permanent cookies.

You are required to log-in to your SwapRight account after a certain period of time

has elapsed to protect you against others inadvertently accessing your account.</li>

Data Storage

SwapRight uses third party vendors and hosting partners to provide the necessary

hardware, software, networking, storage, and related technology required to run

SwapRight. Although SwapRight owns the code, databases, and all rights to the SwapRight

application, you retain all rights to your data.

Security

The Company endeavors to secure your personal information from unauthorized access,

use or disclosure by putting into place physical, electronic and managerial procedures

to safeguard the information we collect through this Site. Additionally, your account information

is accessible online only through the use of a password. Please be aware, however,

that despite our efforts, no security measures are perfect or impenetrable. To 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 by emailing

us if you believe your password has been misused

or disclosed to anyone other than yourself. You should also note that e-mail is

not secure, and you should not send any confidential or sensitive information to

us via an unsecured e-mail.

We cannot protect, nor does this Privacy Policy apply to, any information that you

transmit to other users. You should never transmit personal or identifying information

to other users.

Children

The SwapRight service is not intended for children under 13, and we do not knowingly

collect information from children under the age of 13.

Children aged 13 or older should not submit any personal information without the

permission of their parents or guardians. By using the SwapRight service, you are

representing that you are at least 18, or that you are at least 13 years old and

have your parents' permission to use the service.

Changes

SwapRight may periodically update this policy. We will notify you about significant

changes in the way we treat personal information by sending a notice to the email

address specified in your SwapRight primary account holder account or by placing

a prominent notice on our site or blog.

Facebook Connect Users

If you joined SwapRight using Facebook Connect than any Facebook Privacy Policy terms which differ from the terms listed here shall prevail.

Questions

If you have any questions or comments about this Policy or the practices relating

to this Site, or you wish to verify, correct or delete any personal information

we have collected, please contact us, and we will

endeavor to respond to your inquiry or to correct, update or remove the personal

information you have provided us as you indicate to the extent possible. You can

correct certain information by logging into your account and changing the information,

and you may also delete certain information by closing your account. However, please

note that in certain circumstances, we may not, or may not be able to, remove or

change certain information, even in the event an account is closed.

In lieu of e-mail, you may also contact us by mail.