FIRST STEPS ATLANTA PRIVACY POLICY

Last Updated: November 1, 2014

Protecting your privacy is important to us. We hope the following statement will help you understand how First Steps Atlanta, LLC, a Georgia limited liability company (“First Steps”) and atlanta.firststepsnetwork.com (which, together with any First Steps-branded websites, web pages, mobile applications and mobile websites operated by us, shall be referred to herein as the “Site”), collects, uses and safeguards the personal information you provide to us on our Site. First Steps provides this Privacy Policy to inform you of our policies and procedures regarding the collection, use and disclosure of personal information we receive from users of the Site and/or the services we provide at the Site (the “Services”). Throughout this Privacy Policy, “you,” “your,” “user(s),” “Parent(s),” “Sitter(s)” or Member(s)” shall refer to any person or entity using the Site or the Services and, unless otherwise stated, “we,” “our” or “us” will refer collectively to First Steps and its subsidiaries, affiliates, directors, officers, members, employees, agents and contractors. At First Steps, we are committed to protecting your privacy online. Because your information may be shared with others in order to accomplish the purposes of the Services, our pledge is to safeguard any information that we collect on the Site, which is associated with you and your name, in accordance with this Privacy Policy. We may revise and update this Privacy Policy at any time without notice by posting such revised or updated Privacy Policy on the Site. Any changes to this Privacy Policy will become effective upon posting such revisions or updates. You are required to periodically check our Privacy Policy for any changes, if you continuously use the Services. Your continued usage of the Services will mean that you accept those changes.

By accessing the Site and/or using any of the Services, you agree to the terms contained in this Privacy Policy and any documents incorporated by reference. You further agree that this Privacy Policy forms a legally binding contract between you and First Steps. Please read this Privacy Policy carefully as it affects your rights and liabilities under law. If you disagree with the way we collect and process Personal Information (as defined below) collected on the Site, please do not use the Site or the Services. This Privacy Policy applies to the Site and the Services. The Site and the Services may contain links to other websites over which we have no control. First Steps is not responsible for the privacy policies or practices of other websites which you access from this Site or through the Services. We encourage you to read the privacy policies or statements of the other websites you visit.

Information We Collect and How it is Used

First Steps is committed to helping connect Members to other Members. When you use the Site or Services or in connection with setting up your user name and/or account, we may ask you for information about you that can be used to contact or identify you (“Personal Information”). Personal Information includes, but is not limited to, your name, phone numbers, email address, home postal address, business address, employer/affiliated organization, reasons for accessing the Site and intended usage of requested information. We may also obtain Personal Information from forms you enter or upload on the Site or that you provide to us in writing, over the telephone, automatically when you visit out Site, or from third parties, including verification services, payment processing services and other online or offline sources, including but not limited to, background checks. The information collected about third-party references will not be used for other purposes. A third-party reference may request to have their information removed from a Sitter application/profile at anytime. DO NOT UPLOAD OR INSERT ANY INFORMATION TO OR INTO THE SITE OR SERVICES THAT YOU DO NOT WANT TO BE SHARED OR USED IN THE MANNER DESCRIBED HEREIN. WE WILL USE PERSONAL INFORMATION COLLECTED AS DESCRIBED ABOVE, INCLUDING PERSONAL INFORMATION COLLECTED THROUGH VERIFICATIONS, REFERENCES OR BACKGROUND CHECKS, IN THE PROVISION OF SERVICES TO OUR MEMBERS.

The Personal Information we collect from you is used in the operation of the Site (including the sharing of certain Parent information with prospective Sitters and vice/versa) and allows us to provide you with the Services and to enable users to navigate and enjoy using the Site. We may share the information we gather about you with agents and service providers to perform functions on our behalf, such as to send email, process background checks, or process credit card payments. We may use your Personal Information to develop, improve and advertise the Site and Services. We may also use your Personal Information for internal purposes such as auditing, data analysis and research to improve our Services and user communications. We may also use your email address or phone number (if provided by you) to contact you regarding changes to the Services, system maintenance and outage issues, account issues or otherwise to troubleshoot problems. We also use the information we obtain to develop and deliver our Services and to fulfill legal requirements. Additionally, if you use our Site’s Community Board, please be aware that any Personal Information you submit there can be read, collected, or used by other users of these forums. We are not responsible for the information you choose to submit in this forum.

We limit the collection and use of Personal Information to the minimum we require to deliver our Services to our users and to administer our business. Providing your information is voluntary and you can always choose not to provide Personal Information by choosing not to use our Site, Services or features. If your Personal Information changes, you may update it by contacting First Steps or updating your user information on our Site. If you no longer wish to be a Member of First Steps you may contact First Steps at anytime and request that your account be closed.

Disclosure of Personal Information

If we are requested to disclose your Personal Information to a government agency or official, we will do so if we believe in good faith, after considering your privacy interests and other relevant factors, that such disclosure is necessary to: (a) comply with legal requirements or a legal or judicial process with which we are involved, (b) protect our rights or property or the rights or property of our affiliated companies, (c) prevent a crime or protect national security or (d) protect the personal safety of Site users or the public. Because First Steps is a United States company and information collected on our Site is stored in whole or in part in the United States, your information may be subject to U.S. law.

We also reserve the right to disclose Personal Information and/or other information about users that we believe, in good faith, is appropriate or necessary to enforce our agreements, take precautions against liability, investigate and defend ourselves against any third party claims or allegations, assist government enforcement agencies, protect the security or integrity of our Site or Services, and protect the rights of First Steps, our users and others.

Finally, we may disclose and transfer such information to a third party who acquires any or all of First Steps’ business divisions, whether such acquisition is by way of merger, consolidation or purchase of all or a substantial portion of our assets or equity interests. In addition, in the event that we become the subject of an insolvency proceeding, whether voluntary or involuntary, we or our liquidator, administrator, receiver or administrative receiver may sell, license or otherwise dispose of such information in a transaction approved by the bankruptcy court. You will be notified of the sale of all or a substantial portion of our business to a third party by email or through a prominent notice posted on the Site. Potential purchasers and their advisors may have access to data as part of the sale process. However, use of your Personal Information will remain subject to this Privacy Policy, as it may be revised from time to time.

Information Collected by Cookies

We use cookies on the Site. A cookie is a small data file that the Site sends to your computer’s hard drive to allow the Site to store information which uniquely identifies our users and which allows us to improve the quality of our service. The Site’s cookies do not collect or store Personal Information. Rather, the cookie stores a token which uniquely identifies a particular user at a particular time. That token is then linked to the user information in our secured databases.

Cookies allow us to (a) manage, present and keep track of temporary information, such as data you upload onto the Site for use with the Services, (b) register you as a user on the Site or in other various programs associated with the Site, (c) remember you when you log in to the places on the Site that require you to be a Registered User of the Site, (d) help us understand the size of our audience and traffic patterns, (e) collect and record information about what you viewed on the Site, and (f) deliver specific information to you based on your interests.

Information Collected by Web Beacons and Log Files

When you access the Site, the Site automatically collects certain other information through the use of electronic images known as web beacons (sometimes called single-pixel gifs) and log files. Such information may include your IP address, browser type, the date, time and duration of your access and usage of the Site and whether you opened emails you received from us.

This information is collected for all visits to the Site and then analyzed in the aggregate. This information is useful for, among other things, tracking the performance of our online advertising, such as online banner ads, and determining where to place future advertising on other websites.

Disabling Cookies and Web Beacons

If you are uncomfortable with the collection of such information through the use of cookies and web beacons, we recommend disabling these features through your browser preferences. You can configure your browser to refuse all cookies or to display a message when a cookie is being sent. Your browser documentation should provide specific procedures for disabling cookie and web beacon support. Please be aware that if you configure your browser in this way, it will limit the performance of the Site and some of the Site’s features and functionality may not be available to you.

Protecting Your Information

Steps We Take to Keep Your Information Secure

We keep your information on a secure server behind a firewall. We also use automated and other measures to enhance security and may suspend or disable accounts for violations of our Terms of Use (located at www.revily.com) and this Privacy Policy.

Risks Inherent in Sharing Information

Please be aware that no security measures are perfect or impenetrable, and no method of transmission over the Internet, or method of electronic storage, is 100% secure. We are not responsible for third party circumvention of any privacy or security measures of First Steps. You can reduce these risks by using common sense security practices such as choosing a strong password, using different passwords for different services and using up to date antivirus software.

Report Violations

You should report any security violations to us at this email address: info@firststepsnetwork.com.

Children

The Site and the Services are not directed to individuals under 18 years old, and we do not knowingly collect Personal Information from persons under 18 years old. If we learn that we have collected Personal Information from a person who is under 18 years old, we will take reasonable steps to delete such information from our files as soon as possible. If you believe that we might have any Personal Information from a child under age 18, please contact us by email at info@firststepsnetwork.com.

Phishing or False Emails

If you receive an unsolicited email that appears to be from us or one of our clients or users that requests Personal Information (including, for example, your user name or password), or that asks you to verify or confirm your account or other Personal Information by clicking on a link, that email was likely to have been sent by someone trying to unlawfully obtain your information, sometimes referred to as a “phisher” or “spoofer.” We do not ask for this type of information via email. Do not provide the information or click on the link. Please contact us at info@firststepsnetwork.com if you receive an email like this.

Contact Us

If you have concerns about your privacy in connection with your use of the Site or any general questions related thereto, please tell us by emailing us at info@firststepsnetwork.com, or at P.O. Box 18613, Atlanta, GA 31126. We will attempt to address your concerns.

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