Last Updated:  October 26, 2011

We at Kovio, Inc. (“us,” “our” “we,” or “Company”) consider the protection of your personal information to be a priority. The guidelines contained in this privacy statement apply to information collected, used and/or disclosed by us, and describe how we may collect, use and disclose information that we receive as a result of your use of the Kovio website – www.kovio.com (“the “Website”). 

We reserve the right to modify this Privacy Statement at any time without notice (for example, if we modify our practices regarding the collection or use of information). We will revise our Last Updated date to reflect any revisions to this Statement. 

What Information May We Collect?

• We may receive your name, email address, physical address, and other such information as we may request or that you may provide to us from time to time. 
• We may also collect information that is aggregated in a non-personally identifiable way for our quality assurance purposes and for making improvements to our Website.
• We may capture certain information automatically through the Website, including your Internet protocol address, mobile device identification number, browser type, page access history, linking information, click stream data, page visits, page views, and/or web site log files.
• We may use cookies, log files, clear gifs, and/or similar devices to identify you, to keep track of your interactions with our Website (including those of our partners and affiliates), and to and enhance certain activities available on any such website.  These devices are small text or other electronic files that are used for user-identification purposes, record-keeping purposes, and to increase the ease of use of the Website.  We may use persistent or not-persistent cookies.  You can remove or reject persistent cookies by following the directions provided in your Internet browser’s “help” file.  If you remove a persistent cookie or reject persistent cookies, the functionality of our Website, or any part thereof, may be impaired or unavailable.

How Might We Use Your Information?
We might use the information we collect in the following ways:

• To contact you with professional relevant information about products and services.
• To provide you with personalized offers, promotions, news, events, and other information relevant to your practice.
• To establish and maintain customer accounts.
• To quickly process your requests for information.
• To allow us to respond efficiently to your questions.
• To monitor Website statistics.
• To monitor our customer service employees.
• To allow us to disclose your information to the extent permitted by law, in the situations described more fully below.

How Do We Protect Your Personal Information?
Although we cannot guarantee the impenetrability of our servers, we have established and implemented reasonable physical, electronic, and administrative procedures to safeguard and secure the personal information we collect online.

Do We Disclose the Information We Collect to Outside Parties?

We may share your information, including (in some cases) your personal information and login information, in the following situations:

• When we hire vendors to perform services on our behalf, such as helping us operate our Website, fulfilling a contest or sweepstakes, administering surveys, processing online transactions, executing and optimizing marketing/advertising campaigns, and managing and enhancing consumer data. These companies are only allowed to obtain personal and login information they need to perform the specific task they’ve been hired to do and are prohibited from using the information for any other purpose.  They have also agreed to keep your information confidential and secure.  In the case of any network advertiser hired by us (see below), we require the network advertiser to refrain from sharing or using any data collected at our request for the benefit of anyone other than us unless we have your explicit consent for that type of use. 

• When we share your information with our related companies, including our subsidiaries, parent company, equity investors, and affiliated companies.  This allows us to get a better understanding of who our consumers are worldwide, improve our products based on global needs and interests, and market our products using local resources and based on local interests.

• When we hire independent network advertisers to show you banner ads when you visit other, third party websites.  To do this more efficiently, the network advertiser may use and place on your computer certain web technologies, such as cookies and/or web beacons, to collect from you non-personal information (in most cases, certain technical and/or browsing data) while you visit our Website or other websites participating in the same network.  This information is then used to display advertisements about goods and services (whether offered by us or other companies) more likely to be of interest to you when you visit those other websites.  If you would like to learn more about this practice or how you can opt out from allowing network advertisers to gather this information from you or use it to provide you tailored ads on other sites, please visit the Network Advertising Initiative (NAI)’s website at: http://networkadvertising.org/consumer/opt_out.asp.  Please note that even if you use the mechanism above to opt-out from this type of information gathering, if, at any time, you disable or delete all cookies stored on your computer, you will have also disabled the same technology (namely, cookies) used by the NAI to help prevent you from receiving this type of advertising.  If you do not want this to happen, please make sure not to disable/delete the NAI cookie, or add NAI to the approved list of sites from which you allow or accept cookies.

• If we wish to generally assess (with the help of a third party company) how our online offerings and services are performing in the Internet marketplace, their popularity or use amongst certain consumer demographics or profiles, and other similar performance metrics.   The information disclosed for these purposes will be in aggregate form and limited to demographic or other anonymous data; no personal or login information will be shared except as provided for above.

• When we partner with independent, carefully-selected third party companies as part of a jointly-sponsored promotion or to offer you the ability to receive special offers and discounts directly from third party companies. For example, we may team up with a third party company to offer a contest, giveaway, or other promotion that promotes both our products and theirs, and as part of such promotion, we may share the collected consumer data (including personal and login information).  Similarly, when you sign-up to receive our marketing communications, we may allow you to simultaneously sign-up to receive email offers directly from third party companies who offer other products or services that might interest you.  A limited amount of personal and login information may be shared as part of such third party email program.

• If we are bought or acquired by another company (either fully or partially), merged with another company, or experience a reorganization, bankruptcy, or other similar event. If any of these events occur, your information may be shared with our successor or assign (i.e., the new company or the company that takes over), subject to the notification procedures set forth in this policy.

• When disclosures are required by law or are meant to help protect the security and safety of our Website, we may disclose any information we have collected, regardless of time.  We will make this type of disclosure only as permitted or required by law, or when we believe in good faith that it is necessary: (i) to protect your safety or security, including the safety and security of your property; (ii) to protect the security of our Website or third parties’ websites; and/or (iii) to enforce our Terms of Use, contest, sweepstakes, promotion, or other rules as may be applicable from time to time.

Subject to the exclusions identified above, we will not actively share personal and login information with third party advertisers for their direct marketing purposes unless you give us your consent.  Advertisers, however, may obtain public information about you from your profile or other public sources.  As to the other kinds of information (e.g., demographic information, business information, information collected passively, and information received from third party social networking sites), we may use and share this information with third parties consistent with the terms of this policy. 

How Do I Ask Questions and Provide Feedback Regarding Privacy?
We welcome your questions, comments and concerns about privacy.  Please contact us at info@kovio.com with any questions or comments you may have regarding the privacy of your information.

Notice to California Residents – Your California Privacy Rights
A business subject to California Civil Code section 1798.83 is required to disclose to its California customers, upon request, the identity of any third parties to whom the business has disclosed personal information within the previous calendar year, along with the type of personal information disclosed, for the third parties' direct marketing purposes.

If you are a California resident and would like to make such a request, please submit your request in writing to:

233 S. Hillview Dr.
Milpitas, CA 95035
USA

Please note that under California law, businesses are only required to respond to a customer request once during any calendar year.

Effective Date/Changes
This privacy policy is effective as of the date identified above, and applies to all information previously obtained by us.  We reserve the right to change the privacy policy at our sole discretion.  Our Website users will be informed of any such change by posting a new privacy policy on the Website and the effective date of any change of privacy policy will be clearly marked.

Links to External Websites
The Site contains links to other websites belonging to third parties.  These websites are not covered by this Privacy Policy and we are not responsible for the privacy practices within any of these other websites. You should be aware of this when you leave the Site and we encourage you to read the privacy statements of the other websites.