Start Early ("Company" or "We") respect your privacy and are committed to protecting it through our compliance with this policy.  

This Privacy Policy (the “Policy”) describes the types of information we may collect from you or that you may provide when you visit the website community.startearly.org (the "Website") and our practices for the collection and use of personally identifiable information (PII) of our website users and registered members (each a “User,” “you,” “your,”). By using our services and where applicable,  by providing consents for specific purposes, you consent to the use of your data as described in this  Policy.  

Modifications 

We may modify this Policy in whole or in part, in our sole discretion, by posting amended terms to the Website. Every time you wish to use our Website, please check this Privacy Policy to ensure you understand the terms that apply at that time.  

Collection of your Personal Information  

We collect personally identifiable information, such as your e-mail address, first and last name,  position, home or work address or telephone number, and other information. We also collect anonymous demographic information, which is not unique to you, such as your ZIP code, gender,  preferences, interests, and favorites.  

There is also information about your computer hardware and software that is automatically collected by us (see “Information We Collect Through Automated Data Collection Technologies”). This information is used by us for the operation of our services, to maintain quality of the services, and to provide general statistics regarding use of our websites.  

If you use our services, such as interactive services, we may collect information about you or other individuals included in your posts, materials, messages or other contributions (as defined in our Terms of Use) which you may share with other Users or the public. We ask that you respect the data privacy rights of any individuals who are referred to, or whose personally identifiable information is included in, your contributions. 

Some of the above mentioned information will constitute "Personally Identifiable Information" or "Personal Data" depending on the extent to which such information is protected by privacy or data protection laws in the relevant country.  

Please keep in mind that if you directly disclose Personally Identifiable Information through our public discussion or message boards, this information may be collected and used by others.  

Use of your Personally Identifiable Information 

We will only process your Personally Identifiable Information, in accordance with applicable law, for  the following purposes:  

∙ To operate our websites and deliver the services you have requested, including, without limitation, our interactive services which you use.  

∙ In response to your queries.  

∙ To include your name, title, employer, phone number, and mailing address in our Members’  Directory for access by other members.  

∙ Enabling our service providers to carry out certain functions on our behalf, including statistical analysis, verification, technical, logistical or other functions.  

∙ Ensuring the security of our business, preventing or detecting fraud or abuses of our website.  

∙ Developing and improving our services, for example, by reviewing visits to our website and its various subpages to ascertain demand for specific content.  

∙ To comply with applicable law, for example, in response to a request from a court or regulatory body, where such request is made in accordance with the law.  

∙ We may also rely on legal ground where processing is necessary to fulfill a contract we may have in place with your, for our legitimate business interests and for compliance with our legal obligations.  

Information We Collect Through Automatic Data Collection Technologies 

As you navigate through and interact with our Website, we may use automatic data collection  technologies to collect certain information about your equipment, browsing actions, and patterns,  including: 

∙ Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.  ∙ Information about your computer and internet connection, including your IP address,  operating system, and browser type.  

The information we collect automatically is only statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more  personalized service, including by enabling us to:  

∙ Estimate our audience size and usage patterns.  

∙ Store information about your preferences, allowing us to customize our Website according to your individual interests.  

∙ Speed up your searches.  

∙ Recognize you when you return to our Website.  

 The technologies we use for this automatic data collection may include:  

∙ Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies,  our system will issue cookies when you direct your browser to our Website.  

∙ Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for  Flash cookies, see Choices About How We Use and Disclose Your Information.  

∙ Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).  

∙ Google Analytics.  We use Google Analytics, which is a web analytics service provided by  Google, Inc. (“Google”). Google Analytics uses cookies to help the website analyze how 

individuals use the Website. The non-personal information generated by the cookie about your use of the Website will be transmitted to and stored by Google. Google will use this information for the purposes of evaluating your use of the Website, compiling reports on  Website activity for our purpose, evaluation, and providing other services relating to the  Website activity and Internet usage. Google will not associate your IP address with any other data held by Google. You may disable cookies within your browser as described above,  however please note that if you do this you may not be able to use the full functionality of the  Website. By using this Website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. For certain browsers, you can also prevent Google from collecting information (including your IP address) via cookies and processing this information by downloading this browser plugin and installing it: http://tools.google.com/dlpage/gaoptout.  

We do not collect personal information automatically through these technologies, but we may tie this information to personal information about you that we collect from other sources or you provide to us.  

Disclosure of your Personal Data 

There are circumstances where we wish to disclose or are compelled to disclose your Personally  Identifiable Information to third parties. This will only take place in accordance with the applicable law and for the purposes listed above. These scenarios include disclosure:  

∙ To our members accessing our Members’ Directory (access restricted to members only)  ∙ To other Users or the public as you may request using our interactive services, or as is necessary in order to resolve any disputes in relation to your contributions to our websites and services.  

∙ To our outsourced service providers to facilitate the provision of our services, for example,  the disclosure to our database hosting provider for the safe keeping of your Personally  Identifiable Information, web hosting provider through which your Personally Identifiable  Information may be collected.  

∙ To contractors, services providers or other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.  

∙ To a successor in the event of a merger, dissolution or other sale or transfer of some or all of Start Early assets, whether as a going concern or as part of bankruptcy, liquidations, or 

similar proceeding, in which personal information held by Start Early about our Website users is among the assets transferred.  

∙ For any other purpose disclosed by us when you provide the information.  

 We may also disclose your personal information to comply with any court order, law, or legal process, including to respond to any government or regulatory request or if we believe disclosure is necessary or appropriate to protect the rights, property or safety of Start Early or its website users or contributors.  

Choices About How We Use and Disclose Your Information 

We strive to provide you with choices regarding the personal information you provide to us. We have  created mechanisms to provide you with the following control over your information:  

∙ Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.  

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.  

Retention of Personal Data 

Your Personally Identifiable Information will be retained for as long as is reasonably necessary for the purposes listed above or as required by applicable local law. We may keep an anonymized form of your Personally Identifiable Information, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.  

Data Security  

We have implemented appropriate technical and organizational measures in accordance with industry standards to safeguard your Personally Identifiable Information. When personal information 

(such as a credit card number) is transmitted to other websites, it is protected by encryption, such as the Transport Layer Security (TLS) protocol. However, no security measure is completely secure  (e.g. from malicious intrusion) and we are unable to guarantee complete security of your Personally  Identifiable Information. In order to improve the security of your Personally Identifiable Information and your User account, we would advise that you must choose a strong password to protect your  account information and to change it regularly at reasonable intervals. Furthermore, you must exit from your User account at the end of each session, not allow your browser to save your login details  and secure and limit access to your personal devices.  

Monitoring

We monitor in order to ensure compliance with our legal obligations and good practice, your compliance with our Terms and policies, to gather information as part of investigations by regulatory bodies or in connection with legal proceedings or requests, to ensure confidentiality of commercially sensitive information, to operate firewalls, prevent viruses, malicious code and the downloading or use of executable software code, to prevent the downloading, copying, distribution or other use of obscene, offensive or illegal material (such as pornographic, racist or other discriminatory content),  to restrict access to third-party websites, blogs and bulletin boards in accordance with applicable systems use policies, and to prevent unauthorized access and modifications to our systems.  

Upon receipt of valid notice, we will review your complaint and reply within 30 days. In our reply we may ask you for further information or inform you of what steps we have taken to resolve the matter.  

Interactive Services Complaints Procedure 

If you believe that a User contribution posted on any of our interactive services is inaccurate or otherwise infringes upon your data privacy rights, please notify us by email to info@startearly.org.  A  notice will be valid if it includes:  

∙ Documentation sufficiently confirming your identity  

∙ Your contact details  

∙ A screenshot of the infringing material with a time and date stamp  

∙ A signed statement explaining how the material infringes upon your data privacy rights; and  ∙ Your suggestions as to how the infringing User should remedy his/her infringement.  

Links to other websites 

You should be aware that when you are on our website, you could be directed to other websites that are beyond our control. There are links to other sites from our website that may take you outside our service. We cannot guarantee that the privacy statements of these websites meet our standards. As always, we recommend reading the privacy statements of any new website you go to online.  

Contact Information 

If you notice any unlawful use of Personally Identifiable Information or have questions regarding this  Privacy Policy, you may contact us by email at info@startearly.org.