Emma

Your Pocket Marketplace
Last Revised on April 16, 2011

Emma™ Privacy Policy

We at Strategy Network Incorporated ("we" or the "Company") respect your privacy and value the relationship we have with you. This Privacy Policy is designed to show you what information about you we collect through the EMMA Application on the social network operated by Facebook (the “Facebook Application”) and the related mobile device software applications (the “Mobile Software” and together with the Facebook Application and the Mobile Software, the "Service"), and how we use and share that information. Your use of Facebook in general and your relationship with Facebook are subject to Facebook’s own Privacy Policy and Facebook’s other terms and policies, which we strongly recommend that you review before you start using the Service. We do not control and are not responsible for Facebook’s processing of your information.

Information We Collect About You

The Service enables you to make and respond to a wide variety of opportunities to engage with other Facebook users. These engagements may include invitations to exclusive social events, offers to participate in sports leagues, or opportunities to meet with other people interested in similar subject matters. In order to allow you and those users you engage with to verify each others’ identities and validate your interest in making and responding to offers, the Application enables you to make certain of your personal information and content from your Facebook profile ("Facebook Information") available to other users. In order to facilitate this process, when you use the Application, we may collect any Facebook Information you have made visible to "Everyone" on Facebook as well as the information Facebook designates as your publicly available information. This includes your:

  • name
  • profile picture
  • gender
  • current city
  • networks
  • friend list
  • pages

When first using the Service, you will also be asked to grant us access to additional Facebook Information that you are allowed to share under Facebook’s policies. Currently, we ask that you share the following information:

  • your contact information, including your email address, phone number and mailing address
  • your profile information
  • photos and videos you have uploaded to Facebook
  • your custom friend lists
  • your family members and relationship details and status
  • information about your friends

If you have agreed to grant another user of the Application access to your Facebook Information, we may access it and make it available to such user at times when you are not actively using the Application. Even if you have not explicitly allowed us access to any of your Facebook Information, we may collect information about you when your friends on Facebook allow access to and use the Service, subject to your Facebook settings. We may also send you emails and post on your Facebook Wall in connection with your use of the Service. In addition to the Facebook Information, we may collect information we receive from you in connection with your requests for customer support, your user feedback or other communications you direct to us. Any such information will be treated in the same manner as Facebook Information.

Information We Collect When You Access the Service on a Mobile Device

When you use the Mobile Software on your mobile telephone or other mobile device, we collect your unique device identifier, IP address and location (“Mobile Information” and together with Facebook Information “User Information”).

To log into the Mobile Software, you must input your email address and Facebook password. This Facebook login information is collected directly by Facebook as part of the login process and does not pass through our servers.

How We Use Your Facebook Information

We may use your Facebook Information for the following purposes:

  • to enable you to use the Application, including on a mobile device through one of our mobile applications, to make your Facebook Information available to other users of the Application
  • to post on your Wall or to send you emails regarding your use of the Service
  • to provide technical support and to respond to your inquiries
  • to communicate about new features or promotions of the Service
  • to prevent fraud or potentially illegal activities and to enforce our Terms of Use
  • to resolve disputes and troubleshoot problems
  • to solicit your feedback to improve the Service and your experience using it
  • to administer and improve the Service

We will not sell your personally identifiable Facebook Information to advertisers or spammers.

How We Use Your Mobile Information

We may use your Mobile Information to keep track of your activity levels and location in order to improve the level of service you receive from the Service.

How We Share Your User Information

We may share your User Information in the following cases:

  • With other Users of the Application:

    We may share your Facebook Information with other users of the Application with your consent. We will only make available to a user of the Application that Facebook Information that you have specifically authorized such user to access. Once you have granted another user access to your Facebook Information, such user will continue to have access to such information until you request that we remove such access or you uninstall the Application. If you request that we stop another user’s access to your Facebook Information, we will do so as soon as reasonably possible.

  • With Affiliates and Third-Party Service Providers:

    We may disclose your Facebook Information to our affiliates and third-party service providers to the extent permitted by Facebook. We may also disclose your Mobile Information to such third parties. Third parties are not authorized by us to use or disclose your User Information except as necessary to perform services on our behalf or comply with legal requirements.

  • With Your Consent:

    We may share your User Information with other third parties with your consent.

  • As Required by Law:

    We may disclose any User Information we deem necessary, in our sole discretion, to comply with any applicable law, regulation, legal process or governmental request.

  • To Prevent Harm or Loss:

    We may disclose User Information when we believe, in our sole discretion, disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with suspected or actual illegal activity.

  • In Connection With a Sale of Our Business:

    We also reserve the right to transfer User Information in the event we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use the User Information in a manner that is consistent with this Privacy Policy. Following such a sale or transfer, you may contact the entity to which we transferred the User Information with any inquiries concerning the processing of that information.

We will not provide personally identifiable User Information to third parties for their use in marketing their products or services to you without your consent, but we do not control and are not responsible for Facebook’s own use of content and information it collects in relation to this Service. We may use and share with third parties aggregated and anonymized information to show general demographic and preference information among users of the Service and to deliver within the Service targeted advertising about other products and services.

How We Protect Your User Information

We maintain administrative, technical and physical safeguards designed to protect the User Information that we collect about you against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. While we cannot guarantee that no accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use of your information will occur, we try to prevent such occurrences.

Transfers of User Information to Other Countries

The Company uses databases located in different jurisdictions. We may transfer User Information we collect about you to our databases outside your country of residence. Even if the laws in the country to which the information is transferred do not require us to provide adequate protection for your data, we will nevertheless seek to ensure that information transferred to such country is adequately protected.

Your Privacy Rights and Choices

You may stop the Service from using your User Information at any time by (i) uninstalling the Facebook Application and setting your Facebook privacy settings to prevent the Service from accessing your Facebook Information through your friends or (ii) by deleting your Facebook account. Subject to applicable law, we provide you with access to the User Information we have retained about you and the ability to review, correct, update, block or delete the information where it is inaccurate. Subject to applicable law, we may limit or deny access to your User Information where providing such access is unreasonably burdensome or expensive under the circumstances. Please submit your request to the address specified in the "How to Contact Us" section below.

Updates to This Privacy Policy

This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our information processing practices or for any other purpose. We will post a notice in the Info section of the Service’s profile to notify you of any significant changes to the Privacy Policy and indicate there and at the top of the Privacy Policy when it was most recently updated.

How to Contact Us

If you have any questions or comments about this Privacy Policy, please contact us by email at support@emma.com or telephone at 703-744-6529. You also may write to us at Strategy Network, 1850 Towers Crescent Plaza, Vienna, Virginia 22182, Attn: Office of the General Counsel. Questions or comments submitted through other means, such as Wall posts, may not be received or addressed.