Spes Nova Privacy Policy and Account Information

(Last Updated March 31, 2012)

This Privacy Policy describes how Spes Nova, Inc. (“Spes Nova”) collects and uses the personal information you provide on our website www.spesnova.org and all other websites owned and operated by Spes Nova that have this Policy posted (collectively, the “Website”) or that we generate through your involvement with Spes Nova through our Website. It also describes your choices about how your personal information is used and displayed and how you can access and update this information or change your selections.

No sale of personal information
Spes Nova will not sell or rent your personal information to third parties.

Information you provide through the account creation and update process
When you create an account on our Website, you provide us with basic information through the registration process (your name, e-mail address, a Spes Nova user name, and account password). You have the option to provide additional information (such as your address, a picture, or how you learned about Spes Nova). You can review, update or modify the account information you provide to Spes Nova through the Website by logging into your account on the Website.

Information displayed on your Transaction pages
When you create an account on our Website, the default setting is to have a public lender and/or purchasing profiles on the website. Basic lender and/or purchasing pages will automatically be created (“Transaction” pages). The basic Transaction page shows to the public your first name, your region (city, state/province, and country), and how long you have been registered on our Website. You may choose to provide and display additional information about yourself or why you have chosen to support Spes Nova and our borrowers or merchants. You can review, update or modify the Transaction page information you provide to Spes Nova through the Website by logging into your account on the Website. At your discretion, you have the option of closing down your public Transaction pages on the Website by changing your account setting to anonymous. If you choose to have your Transaction pages public, your Transaction pages will automatically show information about your activities and support on the Website.

Information collected and displayed about the Loans that you have made and/or the merchandise you have purchased (collectively, “Transactions”)
Spes Nova collects information on your Transactions, both individually and in the aggregate. If you created an account on the Website and conducted Transactions through your account, Spes Nova makes information on these Transactions available to you on your private portfolio pages on our Website. If you set your account settings to anonymous, Spes Nova will not publicly display information about your Transactions on our Website. If you do not set your account settings to anonymous, Spes Nova may display information about your Transactions on public Transaction pages on our Website. If you have created an account on the Website and conducted Transactions through your account, you can review information for these Transactions by logging into your account on the Website.

Information collected, displayed, and used for other Website and Program features
Use additional features on our Website or otherwise support Spes Nova. We may collect any additional information you choose to provide to facilitate the operation of these features on the Website or your support, including:

a. Lending Teams
If you join a Lending Team and have a public lender profile, information about your Lending Team will be displayed on your public lender page. In turn, you will be shown as a member of the Lending Team either in a personally identifiable or anonymous manner (depending on your lender profile setting). Information about the Loan Transactions that you have attributed to a Lending Team (individually and in the aggregate) also will be displayed as part of Loans made by that Lending Team. You can review your Lending Team information by logging into your account on the Website.

b. Invitees
The Transaction profile of persons who have accepted your invitations to create an account on our Website may be displayed on your Transaction page as accepted invitees. In turn, if you have accepted an invitation to create an account on the Website, your Transaction profile may be displayed as an accepted invitee on the Transaction page of the person who invited you. If you have created an account on the Website and invited persons using the Spes Nova invitation feature in your account, you can review your invite activity and your accepted invitee information by logging into your account on the Website.

c. Spes Nova Cards
If you purchase a Spes Nova Card gift product, we collect information about your purchase and information about your recipient that you provide. Spes Nova uses the information you provide to deliver the Spes Nova Card and contact the purchaser and/or the recipient with respect to the purchased items or lending projects. We may automatically disclose to the purchaser of an electronic Spes Nova Card the redeeming Transaction profile and date of redemption of the electronic Spes Nova Card. If you have created an account on the Website and purchased Spes Nova Cards through your account, you can review your Spes Nova Card information by logging into your account on the Website.

d. Comments and messages
If you use interactive features on the Website to write a comment, Spes Nova will collect your name and your comment, and Spes Nova may publicly display this information. Use interactive features on the Website to write a message through Spes Nova’s Transaction messaging feature. Spes Nova will collect your message and information about your recipient to deliver your message to the recipient and make your message available for access by the recipient. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request the removal of your personal information from our blog or community forum, please contact us. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

e. Donations
Spes Nova collects information on any donations you make to Spes Nova (whether through the Website or offline) to communicate with you via your e-mail address, physical address, or other means of contact that you have chosen to provide to Spes Nova.

f. Customer service
If you contact Spes Nova customer service, we will collect the information you provide in order to contact you and address your question or comment.

Information from cookies and web beacons
Similar to many websites, if you have enabled cookies in your browser, Spes Nova, independently and through enabled third party tools and programs, collects certain technical information using cookies, such as the path of users to the Website, pages visited, originating IP address, browser type, browser language and the date and time of the user's visit. This information helps Spes Nova track trends, improve the website's areas, and are standard analytics used by most websites. If you have disabled cookies, the Website may not work as intended because Spes Nova uses cookies when you sign in to keep track of your session. Web beacons are used to track the online movements of internet users and help Spes Nova better understand user interaction and engagement with the Website. The use of cookies by third parties on the Website is to make the Website easier to use and enable certain features of the Website and is not covered by this Privacy Policy. We do not have control over these cookies.

Electronic communications
From time to time, you will receive disclosures, notices, documents, and information based on your account information, status, or activity (collectively, "Communications") from Spes Nova. By creating an account with Spes Nova on the Website, you agree that all Communications from Spes Nova relating to your use of the Website may be provided or made available to you electronically by e-mail or at the Website. To access the Communications electronically, you will need to use a computer with Internet Explorer 8.0 or above, Chrome 4.0 or above, Safari 4.0 or above, Opera 10.0 or above, or Firefox internet browsers and with hardware capable of running these internet browsers. You may withdraw your consent to receive Communications electronically by contacting Spes Nova in the manner described below. However, if you withdraw your consent to receive Communications electronically from Spes Nova, we will not have the ability to permit you to fund any additional Transactions through your account on the Website. The withdrawal of your consent will not affect the legal validity and enforceability of electronic Communications provided by or on behalf of us in connection with any of your Transactions that have not been fulfilled or any electronic Communications provided by or on behalf of Spes Nova before the time you withdraw your consent. It is your responsibility to keep Spes Nova informed of any changes in your e-mail address so that you continue to receive all Communications without interruption. By registering on the Website, you acknowledge that you can access electronic Communications, and you consent to have all Communications provided or made available to you in electronic form. We may also provide you with Communications through physical mail.

Disclosure to affiliates, service providers, agents, and representatives
We will disclose your personal information with third parties only in the ways described in this privacy statement. Spes Nova's affiliates and service providers, agents, and representatives of Spes Nova and its affiliates may be provided access to your personally identifiable information as part of, or incident to, their provision of services to Spes Nova. All such access will be under appropriate confidentiality agreements and limited to use to provide services to Spes Nova to help Spes Nova further its mission.

Disclosure of non-personally identifiable data
Spes Nova reserves the right to disclose information that does not directly identify you for educational, informational, or promotional purposes to further Spes Nova’s mission.

Legal disclosures
Notwithstanding anything to the contrary in this Privacy Policy or the Terms of Use, you acknowledge, consent, and agree that Spes Nova may disclose information to (a) comply with applicable law, regulation, legal process, or governmental request; (b) protect the rights, property, and safety of Spes Nova, users and others, including intellectual property rights; and (c) enforce or apply our agreements and policies.

Terminating your participation
You may terminate your participation and registered account on the Website at any time and for any reason by sending a written notice of termination to Spes Nova along with instructions for the disposition of your then-available Spes Nova Credit and any additional credits that you may receive in the future (e.g., based on repayments of then-outstanding and active Loans or returned merchandise), such notice to be effective within five (5) business days of receipt by Spes Nova.

Links to other websites
If you follow any links which remove you from the Website, this Privacy Policy no longer applies.

Public Forums
Our Website offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request the removal of your personal information from our blog or community forum, contact us using the contact information below. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

Note regarding children under 13
The Website is intended to be used by adults, and it is not intended for children, and Spes Nova does not want to collect any personal information for persons under the age of 13. Spes Nova recommends that parents do not post or permit others to post any personally identifiable information with respect to persons under the age of 13. If you believe that we have any information from a child under age 13, please contact us using the contact information below.

Security
Spes Nova takes reasonable steps to maintain appropriate physical, technical, and administrative security to help prevent the loss, misuse, and unauthorized access, disclosure, and modification of personal information. While we take these reasonable efforts to safeguard your personal information, no system or transmission of data over the Internet or any other public network can be guaranteed to be 100% secure.

Location of data
Spes Nova is headquartered in the USA. Your personal information may be accessed by Spes Nova, our affiliates, service providers, agents, and representatives in the USA or elsewhere in the world. By providing us with personal information, you consent to this transfer. According to this Privacy Policy, Spes Nova will protect the privacy and security of personal data regardless of where the personal data is processed or stored.

Retention period
Spes Nova reserves the right to retain your personal information for seven (7) years or more to satisfy legal requirements such as recordkeeping and tax and credit reporting requirements and for purposes of fraud prevention, audit, and data integrity. In addition, Spes Nova reserves the right to retain, as well as to use and disclose as permitted pursuant to this Privacy Policy, your personal information for such period of time as reasonably needed by Spes Nova to facilitate Transactions for the operation of the Website, improve user experiences on the Website and further Spes Nova’s mission. Spes Nova reserves the right to retain information that does not directly identify you.

Modifications; Interpretation
Spes Nova may update or modify this Privacy Policy from time to time. If any changes are made, Spes Nova will reflect the date on which such changes are created and posted by updating the "last updated" date at the top of the page. If we make any material changes, we will notify you by e-mail (sent to the e-mail address specified in your account) or by means of a notice on this Website before the change becomes effective. Please be sure to check this page periodically for changes. Capitalized terms used but not defined in this Privacy Policy have the meanings outlined in the terms of use.

How to contact Spes Nova
We take privacy seriously, and we value yours. For additional information, or if you have any questions regarding this Privacy Policy or the privacy practices at Spes Nova, please submit your questions or comments to:

Spes Nova, Inc.
Attn: Privacy Policy

441 East Fordham Road
Dealy Hall, E513
Bronx, NY 10458