Privacy Policy

January 1, 2017

The SHARP Method ("SM") is a diverse multimedia company and, together with its Affiliates, operates in various media areas and platforms, including but not limited to digital programs, entertainment, and information websites. In this Privacy Policy, “Affiliates” refers to our subsidiaries and entities that Filibuster or its subsidiaries, licensees, assignees and/or distributors currently operate or have an ownership interest in, as well as future ones where such a relationship may be created.

This Privacy Policy applies only to the information we collect through the websites, mobile applications, electronic devices, kiosks, and all other interactive services whereby data is transmitted (hereinafter “the Services”) operated by SM and its subsidiaries (collectively “we” or “us”) regardless of how you access the Services, unless such website, mobile application, electronic device, kiosk, or other interactive service has a separate Privacy Policy specific to such website, application, device, kiosk, or interactive service. The Policy describes:

· The information we collect and how we collect it;

· What we do with the information we collect;

· Information sharing and disclosure;

· How you can access and update your information;

· How we protect information;

· Linked sites and advertisements;

· Users from outside the United States;

· Children;

· How to contact us;

· Your California privacy rights;

· No rights of third parties; and

· Changes to this policy.

The information we collect and how we collect it.

How we collect and store information depends on the websites you visit, the activities in which you participate and the Services you use. You can use some of the Services without providing any information other than that automatically collected as described below.

We may collect information about you during your use of the Services, including your name, username, password, email address, postal address, phone number, mobile phone number, payment information, gender, birth year, and information you provide or post on our Services or allow us to access when you do certain things, such as:

· Enter registration information for one or more of our Services;

· Enter a sweepstakes or contest or register for a promotion;

· Participate in voting or polling activities;

· Make a purchase;

· Request certain features (e.g., newsletters, updates, and other products);

· Sign up to receive SMS (text message) notifications;

· Download or use one of our mobile applications;

· Connect with the Services or otherwise allow us to access certain information about you via a social networking site (“SNS”); or

· Post user-generated content to or on any of our Services.

We may collect and store your user ID associated with a SNS account that you use to sign in to your SM account or connect or use with the Services. When you sign in to your SM account or mobile application with your SNS account information or otherwise connect to your SNS account with the Services, you authorize SM to collect, store, and use in accordance with this Privacy Policy any and all information available to SM through the SNS interface, including without limitation any information that you have made public in connection with your SNS account, information that the SNS shares with us, or information that is disclosed as being shared during the sign-in process.

We may also combine information that we collect from you with information we obtain about you from third parties and Affiliates and information derived from any other subscription, product, or service we provide.

Please be careful and responsible whenever you are online. Should you choose to voluntarily disclose information through the Services, such as via SNSs, on message boards, chat areas or in advertising or notices you post, that information can be viewed publicly and can be collected and used by third parties without our knowledge and may result in unsolicited messages from other individuals or third parties.

Cookies and other electronic technologies.

When you use the Services, we use persistent and session cookies and other tracking technologies to: (a) store your username and password; (b) analyze the usage of our sites and Services; (c) customize the Services to your preferences; and (d) control the advertising displayed by the Services. We may also use other Internet technologies, such as Flash technologies, Web beacons or pixel tags, and other similar technologies, to deliver or communicate with cookies and track your use of the Services (including to serve you ads when you are on other websites or the Internet when we can access those cookies). We also may include Web beacons in e-mail messages or newsletters to determine whether the message has been opened. As we adopt additional technology, we may also gather additional information through other methods.

We use these automated technologies to collect and analyze certain types of information we consider to be non-personal information, including: (a) information related to the devices you use to access or interact with our services, such as: IP addresses, geolocation information (as described further below), unique device identifiers and other information about your mobile phone or other mobile device(s), browser types, browser language; and (b) information related to the ways in which you interact with the Services, such as: referring and exit pages and URLs, platform type, the number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services, and other similar information. We may also capture other data, such as search criteria and results. In some cases, we will associate this information with a unique SM identifier (that cannot be used by itself to identify you) for our internal use, in which case your SM identifier will be considered SM information and nothing in this Privacy Policy restricts how SM may use this information.

Most browsers automatically accept cookies, but you can modify your browser setting to decline cookies by visiting the Help portion of your browser’s toolbar. If you choose to decline cookies, please note that you may not be able to sign in, customize, or use some of the interactive features of the Services. Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser will not remove flash cookies. To learn more about how to manage flash cookies, you can visit the Adobe website and make changes at the Global Privacy Settings Panel.

Third party advertising and your choices.

Third parties whose products or services are accessible or advertised via the Services may also place cookies or other tracking technologies on your computer, mobile phone, or other device to collect non-personal information about your use of the Services. We also allow other third parties (e.g., ad networks and ad servers) to serve tailored ads to you on the Services, and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Services. We neither have access to, nor does this Policy govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device you use to access the Services by non-affiliated, third-party ad technology, ad servers, ad networks or any other non-affiliated third parties. Those parties that use these technologies may offer you a way to opt out of ad targeting as described below. You may receive tailored advertising on your computer through a web browser. If you are interested in more information about tailored browser advertising and how you control cookies from being put on your computer to deliver tailored advertising, you may visit theNetwork Advertising Initiative’s website and/or the Digital Advertising Alliance’s website. You also can control advertising cookies from Google, by using its Ads Preference Manager. Please note that to the extent advertising technology is integrated into the Services, you may still receive advertisements even if you opt-out of tailored advertising.

When using a mobile application, you may receive tailored in-application advertisements. Each operating system, iOS for Apple phones, Android for Android devices and Windows for Microsoft devices provides its own instructions on how to prevent the delivery of tailored in-application advertisements. You may review the support materials and/or the privacy settings for the respective operating systems in order to opt-out of tailored in-application advertisements. For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact the applicable platform operator.

Device location information.

We may collect different types of information about your location, including general information (e.g., IP address, zip code) and more specific information (e.g., GPS-based functionality on mobile devices used to access the Services), and may use that information to customize the Services with location-based information, advertising, and features. For example, if you provide a zip code that indicates that you live in Chicago, the Services may be customized with Chicago-specific information and advertisements. In order to do this, your location information may be passed along to our ABTiliates, agents, vendors or advertisers. If you access the Services through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer’s instructions for further details.

What we do with the information we collect.

We use the information that we collect for the following purposes:

· For the purposes for which you provided it;

· To send you information about your relationship or transactions with us;

· To send you alerts or other communications via SMS messages or other media or networks;

· To notify you about new features of the Services, special events, or products, services, and special offers;

· To administer sweepstakes and contests;

· To process and respond to your inquiries;

· To contact you with information that we believe will be of interest to you;

· To attribute content that you make available through the Services;

· To generate and review reports and data about our user base and Service usage patterns;

· To analyze the accuracy, effectiveness, usability, or popularity of the Services;

· To improve the content and features of the Services or develop new Services;

· To allow us to personalize the content and advertising that you see on the Services;

· To enforce the legal terms that govern your use of the Services; and

· To administer and troubleshoot the Services.

The Services are supported by advertising revenue. We will send you commercial email on behalf of ourselves, our Affiliates, and advertisers. Each such email we send you will have an opt-out that you can use to stop receiving such communications.

We may aggregate and/or anonymize information collected by the Services or via other means so that the information does not identify you. Our use and disclosure of aggregated, anonymized, and other non-personal information is not subject to any restrictions under this Privacy Policy, and we may disclose it to others without limitation for any purpose.

Information sharing and disclosure.

We will make your information available to other companies, websites, applications or people in the circumstances described below:

· We may rent, sell, or share your information with non-affiliated third parties: (a) in order to provide services or products that you have requested; (b) when we have your permission; or (c) as described in this Privacy Policy.

· We may share your information with any Affiliate or agent of SM in order to provide the Services or advertising or to communicate with you on our behalf.

· When you sign up to participate in a contest or sweepstakes, your information may also be provided to our sweepstakes or contest advertisers, operators, or sponsors and the use of that information will be also governed by those advertisers’, operators’, or sponsors’ privacy policies or practices.

· We may disclose your information in response to any subpoenas, court orders, or other legal process we receive, or to establish or exercise our legal rights or to defend against legal claims.

· We may share your information with third-party advertisers and advertising networks or others with which we have a contractual relationship.

· We may disclose your information when we believe it appropriate in order to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of the Terms of Service for the Services you accessed, and/or to protect our rights and property.

As we continue to develop our business, we may sell, buy, merge or partner with other companies or businesses. In such transactions, user information may be among the transferred assets.

How you can access and update your information.

To ensure that you have some control over the information we have about you, you may review and update certain user profile information by logging in to the relevant portions of the Services where such information may be updated (may be available on some Services and not others) or by contacting us at getsharp@sharpmethod.com

How we protect information.

We have implemented reasonable administrative, technical, and physical security measures to protect against the unauthorized access, destruction or alteration of your information. Despite our best efforts, however, no security measures are completely impenetrable.

Linked sites and advertisements.

The Services may contain links to third-party websites. We are not responsible for the privacy practices or the content of those third-party websites.

We have relationships with third-party providers to provide content, products, services, and functionality through the Services. When you visit sites or use any Services provided in conjunction with one or more of these third-party providers and the brands of those providers appear on the site or Services in connection with such content, products, services, or functionality, we may share any information you provide or that is collected during your use of those Services with those providers. In some cases, the provider may collect information from you directly, in which case the provider’s privacy policy (which may differ from this Privacy Policy) would apply. If you have any questions regarding the privacy policy of any of our providers, you should contact the provider directly for more information.

Users from outside the United States.

The Services are hosted in the United States and are governed by United States law. If you are using the Services from outside the United States, please be aware that your information may be transferred to, stored and processed in the United States where our servers are located and our databases are operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By using the Services, you consent to your information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in our Privacy Policy.

Children.

The Services are not intended for persons under the age of 13. We require that only persons 13 years of age or older use the Services. By using the Services, you hereby represent that you are at least 13 years old. Some third parties, such as platform providers like the iTunes Store or Google Play may provide age-based ratings on some of the Services. These ratings shall have no bearing on this limitation. Third parties may also provide content categories on some of the Services. These categories shall have no bearing on this limitation.

How to contact us.

If you have any questions, comments, or concerns regarding our Privacy Policy or practices, please send an email to g etsharp@sharpmethod.com

Your California privacy rights.

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. If you are a California resident and would like to request this information, please submit your request in an email to getsharp@sharpmethod.com

No rights of third parties.

This Privacy Policy does not create rights enforceable by third parties.

Changes to this policy.

SM reserves the right to change this policy at any time. Please check this page periodically for changes. Your continued use of the Services following the posting of changes to this policy will mean you accept those changes. If we make any material changes to this Privacy Policy, we will post the updated Privacy Policy here and periodically notify you by email or by means of a notice on our website. However, it remains your primary responsibility to monitor and adhere to changes and updates on the Web site, irrespective of whether or not any such notices have been sent or received by you.

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