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Privacy Policy

This privacy policy ("Policy") applies to the mulu.me web site (the "Site"), as well as services, including software, applications, web tools, widgets (including the widgets referred to as the “muluBox” and “muluMini”), plug-ins, components, functionalities, technologies, or programs that were created for purposes of using the Site or the services (collectively, the “Services”) operated or owned by Mulu, Inc. (hereinafter "we," "us," or "our"), and tells you how we collect, store, use, disclose and protect personal information from and of users of the Site and the Services.

This Policy constitutes a binding agreement between you, as a user of the Site and the Services, and us, as the owner of the Site and provider of the Services. BY USING THE SITE OR THE SERVICES, OR ACCESSING OR REGISTERING ON THE SITE, YOU ARE CONSENTING TO THE TERMS OF THIS POLICY. IF YOU DO NOT AGREE TO THE TERMS OF THIS POLICY, PLEASE DO NOT USE THE SITE OR THE SERVICES, OR ACCESS OR REGISTER ON THE SITE.

I. Changes to this Policy

We may change this Policy from time to time. If we make any changes to this Policy, we will change the "last updated" date below. If there are material changes to this Policy, we will notify you by either posting a notice on the Site or by email message to the last email address that we have on file for you. We encourage you to check this Policy whenever you use the Site or the Services in order to understand how your personal information is used.

II. Information Collected

We collect four types of information when you visit the Site: (1) personal information, (2) non-personal information, (3) aggregate data and (4) demographic information.

A. Personal Information

As used in this Policy, the term "personal information" means both (i) information that specifically identifies an individual (such as first and last name or email address), and (ii) demographic, aggregate or other information when it is directly linked to information that can identify an individual. For instance, if we collect your IP address (which is typically non-personal data) and tie it to your full name, the combination of this data would constitute "personal information."

B. Non-Personal Information

We also may collect "non-personal information," such as your IP address, or data that is collected via cookies, web beacons or other technical mechanisms (such as the muluBox). This information does not identify you personally, but it may provide us with information about your interests, your location, and the web sites, products or services that you view and the time you spend viewing them.

We may also tie this non-personal information with personal information, in order to provide you with better recommendations, help authenticate you or other data or information you may provide, prevent fraud, and ensure that the Site and the Services meet your needs. As mentioned above, when we tie non-personal information with personal information, it is considered “personal information” for the purposes of this Policy. This means that we will be using and sharing this combined data in the ways described below, in Sections IV and V of this Policy.

C. Aggregate Data

"Aggregate data" is non-personal information that we collect about a group or category of services or users. Aggregate data helps us understand trends in our users' needs so that we can better consider new features, analyze usage, facilitate payment, or improve or tailor our services. For example, we may collect data about the searching habits of residents of a particular state or country, without tying this data to any specific personal information about those residents.

D. Demographic Information

"Demographic Information" may be your gender, age, zip code and interests, which we may obtain from you, or from other third parties. We use this information to provide you with personalized services or announcements that are customized to meet your demographic, and to analyze trends to ensure the information provided by the Site meets your needs. For example, we may serve you with an advertisement based on the content you view while on our Site or through our Services.

NOTE: This Policy in no way restricts or limits our collection and use of non-personal information, aggregate data or demographic information, and we may link this data to your personal information and/or share it with third parties for a variety of purposes, including to help us better understand our customer needs, and to improve our Site and Services for advertising and marketing purposes.

III. Collection Mechanisms

A. Collection of Personal Information

We collect personal information from you in the following instances:

  1. Information You Give Us. We collect personal information from you via the Site when you use our Site and Services. Examples include the following: (a) Registration and Profile Information. When you register to use the Site or update your profile, we may collect various kinds of information about you including, your first and last name, address and email address, and information that you upload such as photos, files, and documents. (b) Contact Information. We collect the email addresses and contact information that you provide to the Site when you create contacts. When you choose to collaborate or share files with other users of the Site or access and/or communicate with users on third party web sites that are accessible from the Site, we also collect email addresses you provide in order to email invitations to those other users on your behalf.

  2. Payment Information. f you choose to create a subscription account or otherwise supply Mulu with payment information as a result of some offering on the Site or in connection with the Services, we may collect your first and last name, credit card and billing information in order to complete your request. We also may use a payment processing vendor to process your payment, in which case the vendor may also collect and store your data. In such an instance, the information will be used in accordance with our payment processing vendor's privacy policy, which will be provided to you at the time of payment.

  3. Submissions and Customer Service. From time to time we may use surveys, contests or sweepstakes requesting personal or demographic information and customer feedback.

  4. Automatically Collected Information. We automatically receive certain types of information when you visit the Site or interact with our web pages, Services and communications. For example, it is standard for your web browser to automatically send information to every web site you visit, including ours. That information includes your computer's IP address, access times, your browser type and language, and referring web site addresses. We may also collect information about the type of operating system you use, your account activity, and files and pages accessed or used by you. Similarly, as another example, we may collect behavioral advertising information (defined in Section IIIB(3), below), such as information about the pages you visit, the products you view, or the time spent on a page. This information is collected on our Site and through our Services as well as on web sites that you visit after leaving our Site or connect to through our Services and it may be collected whether you are signed in to our Site or not. While much of this data may not be personally identifiable, we may tie this data to your personal information. In the event that we do tie this data to your personal information, we will treat it as personal information and protect and use it in accordance with the terms of this Policy.

B. Collection of Non-Personal Information

We also collect non-personal information, aggregate data and demographic data from you in the following instances:

  1. Internet Protocol (IP) address. Your IP address is a number that lets computers attached to the Internet know where to send you data -- such as the web pages you view. We use this information to deliver our web pages to you upon request, to tailor the Site and the Services to the interests of our users and to measure traffic within the Site and with the Services.

  2. Cookies and Web Beacons. We may use certain kinds of technology such as cookies and web beacons to collect information. Among other things, the use of cookies and web beacons enables us to improve our Site and Services by seeing which areas and features are most popular, to count the number of computers accessing our Site and using our Services, to personalize and improve your experience, to record your preferences, and to allow you to visit our Site and use our Services without re-entering your member ID and/or password.

A cookie is a small amount of data which is sent to your browser from a web site's computer and stored on your computer's hard drive. Most browsers automatically accept cookies as the default setting. You can modify your browser setting to reject our cookies or to prompt you before accepting a cookie by editing your browser options. However, if a browser is set not to accept cookies or if a user rejects a cookie, some portions of the Site and Services may not function properly. For example, you may not be able to sign in and access certain web page features or Services. Some of the cookies we use may be flash cookies/Adobe cookies, which are more persistent in nature. These cookies may not be deleted when your cookies are deleted. Please check your browser to determine where these types of cookies are stored and how they may be deleted.

A web beacon is an electronic image, also called a "gif," that may be in the form of a "png" image, as well as iframe, script, input link, embed, object, and other tags to track usage. These web beacons may be used on our web pages to deliver cookies, attribute sales to our affiliate partners and advertisers, count visits and compile statistics on usage and campaign effectiveness or in our emails to tell if an email has been opened and acted upon.

  1. Behavioral Advertising Information. We use tracking devices and cookies to collect non-personal information about the users of our Site and our Services. For example, we collect information regarding the websites that you visit, the time you spend looking at certain web pages, and the products that you select through our Site and Services. The information collected may help us provide recommendations to you, serve you with advertisements or direct you to a product or service that we believe may be of interest to you. This information is collected from users while they are on our Site and when they use our Services, even if these users have not yet registered on the Site. This information may also be collected from users after they leave our Site and after they are transferred through our Services. Services such as the muluBox appear on third party websites and permit the purchase of products published on third party pages across the Internet. When an individual clicks on a product, they will be directed to the merchant’s website and certain information is transmitted as well. For example, we collect information to help us monitor click-through rates and we receive non-personal information from merchants to facilitate payment so that we can designate funds to our users, including affiliates, and/or to their designated charities.

Further, this information may be collected whether you are signed in to our Site or not. The purpose of this data collection is to optimize your experience on our Site and with our Services, to ensure we are partnering with third parties that offer products and services that are of interest to you, to facilitate a transaction or fulfill the terms of an agreement, or to ensure that the advertisements offered to you are relevant. We take steps to ensure that the information we collect and share for these purposes remains anonymous.

For more information about this type of advertising and to opt-out of receiving targeted advertisements from certain advertisers, please visit http://www.networkadvertising.org/managing/opt_out.asp.

  1. Geolocation Data. We may also collect your location if you choose to allow us to track your location through our Site or Services or if your personal or non-personal information indicates a certain geographic location. This information may help us provide recommendations to you based on your location, serve you with advertisements or direct you to a product or service that we believe may be of interest to you and that is marketed to people near your location.

IV. Use of Personal Information

In general, we use your personal information to process your requests or transactions, to provide you with information or services you request, to inform you about other information, events, promotions, products or services we think will be of interest to you, to facilitate your use of, and our administration and operation of, the Site and the Services and to otherwise serve you and our users. For example, we may use your personal information:

  • to request feedback and to enable us to develop, customize and improve the Site, the Services, and our publications and products;
  • to conduct marketing analysis and to send you surveys or newsletters; to contact or alert you about the Site, the Services, products, activities, special events or offers from us or our partners; and/or to contact or alert you for other marketing, informational, product development or promotional purposes;
  • to keep track of any purchase made by you in order to ensure the Site and the Services meet your needs, and/or notify you of any product or service we believe may be of interest to you;
  • if necessary, to facilitate or assist with any transaction between you and any of our affiliates or with any other web site that is available through our Site or Services;
  • to contact you about your use of the Site or Services, or to otherwise respond to your emails, submissions, comments, requests or complaints, including customer support inquiries or questions about our products or services;
  • to tie it to your non-personal information or demographic information in order to provide you with recommendations for products or services that are based on your interests, your age or your location;
  • in the event you purchase a product or service directly from Mulu, we may use your personal information to process your order, complete a transaction or perform after-sales services;
  • to administer our Site and Services, anticipate and resolve problems with the Site and the Services; to store contacts you enter or upload into your contacts list for your private use and viewing;
  • to send emails to other users of the Site or the Services that you invite (or to contacts you invite to become users of the Site or the Services) to collaborate and access your files;
  • to enable you to communicate, collaborate, and share files with users you designate;
  • to connect your Mulu account to external, third party applications, such as when you create an account using an external application such as Facebook or Twitter;
  • to share your Mulu picks, questions and answers in a way so that they may be publicly attributed to you, which is one of the key social features of the Site and the Services;
  • to share your Mulu picks, questions and answers with third party, external applications that you may enable and/or authorize;
  • to make available to developers via an Application Programming Interface ("API") certain aggregated or anonymized data, which may be tied to your personal information, where data accessed from the API may be used in external, third party applications subject to review and approval by Mulu;
  • to collect and display statistics about your usage of the Site and the Services (such as the number of users you have followed or the contributions you have made) and to associate this data with your username;
  • to contact you regarding any promotion, sweepstakes or contest that you participate in through the Site or the Services; and
  • for other purposes about which we notify you.

V. Sharing of Information

A. Personal Information

We will share your personal information with third parties as outlined in this Policy or with your consent. Below are examples of how we may share your personal information:

  1. We may disclose information to a third party to (a) comply with laws or respond to lawful requests and legal process, (b) to protect Mulu.me, Mulu, Inc., and our agents, customers, and others from legal claims or actions, including claims of fraud or to enforce our agreements, policies and terms of use or (c) in the good faith belief that disclosure is needed to respond to an emergency, or protect the personal safety of any person.
  2. The Site includes collaboration features that by their nature support sharing with users you choose. Those users can see your name, email address, information you add to your profile, and any files you choose to share; and they can post comments and email you.
  3. We may also share your personal information (either alone or in combination with non-personal information and/or demographic information) with affiliates, strategic partners, agents, third party marketers or other unaffiliated parties who are offering products or services that we believe may be of interest to you or who require your personal information for research, administrative and/or internal business purposes. These parties may use this information to contact you with an offer or advertisement related to a product or service, or they may use such information for their own research, administration or business purposes. If you do not want us to share your personal information in this manner, please do not provide us with this information.
  4. The Site and the Services may provide you with opportunities to connect with third parties that may be offering or advertising products and services. For example, the Site and the Services may allow users to access web sites maintained and controlled by manufacturers or retailers of merchandise. You may purchase products or services from these third party retailers, or affiliates, while you are on the Site and when you are using the Services. While these transactions will be between you and the third party, please note that from time to time, we may choose, or it may be necessary for us, to share your personal information with these retailers in order to assist with the fulfillment of the transaction, as part of an agreement with that third party, or otherwise for the purposes described in this Section V(A) of the Policy. The Site may also include access to social networking web sites established, owned and controlled by third parties such as Facebook.com, and information may be exchanged between the Site and these social networking web sites. If you choose to use any third party services or access, purchase or view products or services on a third party web site, we may facilitate sharing of your personal and non-personal information with those third parties. Please note, however, that your use of any services offered or your purchase of any product offered by a third party on a third party web site shall not be solely governed by our Terms of Use or this Policy and we do not control the services of those third parties or how they use your information. Be sure to review the terms and the privacy policies of those third parties before using their services.
  5. We may be required to share your personal information in order to fulfill a service to you. For example, if you register on the Site or use our Services, we may have to share your personal and/or non-personal information with third parties in order to provide content to you that we believe may be of interest to you. Also, if you obtain a subscription to use the Site, we may have to share your billing information with third party credit processing companies in order to fulfill that service to you. We also may have to share your personal information if you choose to enter a sweepstakes or contest in order to fulfill the terms of that promotion. This means that we may share the information for prize fulfillment purposes or mail carriers. We also may share your information with the co-sponsor of that promotion. We may have to share your information with unaffiliated third-party service providers, agents or independent contractors who help us maintain the Site, provide our Services, and provide other administrative services to us (including, but not limited to providing customer service, maintaining and analyzing data, sending customer communications on our behalf, and entry collection, winner selection and prize fulfillment for contests, sweepstakes and other promotions). We seek to ensure that these unaffiliated third parties will not use the personal information for any other purpose than to provide the administrative services for which they are responsible. Because the unaffiliated third-party service providers that help us administer the Site and the Services will have access to users' personal information, if you do not wish for these unaffiliated third-party service providers to have access to your information, please do not register or submit any personal information to us.
  6. We may share personal information in connection with an acquisition, merger, or sale of all or a substantial portion of our business, with or to another company. In any such event, you will receive notice if your data is transferred and becomes subject to a substantially different privacy policy.
  7. We may share personal information and/or non-personal information in order to track and analyze usage and volume statistical information from our visitors and customers and provide such information to third parties.

B. Non-Personal Information, Aggregate Data and Demographic Information

  1. Generally. We reserve the right to share non-personal information, aggregate data and demographic information and behavioral advertising information about our customers, sales, and traffic to our partners and advertisers. We may also collect information regarding click-through rates and de-identified purchase information to facilitate the payment and collection of affiliate fees and to contribute to specified causes. Please also note that we may share your non- personal information, demographic information, aggregate data or behavioral advertising information when it is tied to your personal information, as described in Section V(A)(3) of this Policy.
  2. Behavioral Advertising Information. As mentioned in Section IIIB(3), we also collect behavioral advertising information via the Site and the Services. Some of the information that we collect is used to serve you with targeted advertisements; therefore, we may share this information with advertisers to better direct their advertisements to you while you are on our Site. This includes non-personal information, aggregate data and demographic information, but may also include your location if you choose to allow our Site or our Services to track your location or if your aggregate data indicates a certain geographic location. In some instances, we may collect behavioral advertising information using our Services. For example, when you use the muluBox, we collect information such as the time you spend looking at certain web pages, the page on which you found the muluBox, and the products that you select. Please note that this information may be shared between our affiliate providers, merchants, and us.

VI. User to User Transactions

From time to time, users of the Site and the Services may transact or conduct business with one another directly through the Site or the Services. You may be required to share personal information, non- personal information or data with another user of the Site or the Services during these transactions and that user may maintain your information and data in accordance with his or her own policies and terms. Therefore, please ensure that you are transacting with users that you know and trust, and please ask to see that user's policies with respect to data retention, storage and use before disclosing any information or data to them. We are not responsible for the personal information, non-personal information, or other data that you share DIRECTLY WITH ANY USER OF THE SITE OR SERVICES AND WE MAKE NO WARRANTY, REPRESENTATION OR GUARANTEE WITH RESPECT TO THE STORAGE, USE OR MAINTENANCE OF ANY INFORMATION OR DATA BY ANY USER OF THE SITE OR SERVICES.

VII. International Transfer of Information

If you choose to provide us with personal information, we may transfer that information to affiliates and subsidiaries or to other third parties, across borders, and from your country or jurisdiction to other countries or jurisdictions around the world. If you are visiting from the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring your personal information to the United States which does not have the same data protection laws as the EU and by providing your personal information you consent to:

  • the use of your personal information for the uses identified above in accordance with this Policy; and
  • the transfer of your personal information to the United States as indicated above.

VI. Network and Information Security

No data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to us is done at your own risk.

We take reasonable steps to protect information we collect from you to prevent loss, misuse and unauthorized access, disclosure, alteration, and destruction. If we learn of a security systems breach we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Site or the Services or providing personal information to us you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of the Site and the Services. We may post a notice on our Site if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

VII. Third Party Web Sites

This Policy applies solely to information collected on the Site and in connection with the Services. The Site or the Services may provide links to other web sites. We are not responsible for the privacy practices or the content of these other web sites.

VIII. Forums, Chat Rooms and Other Public Posting Areas

Please note that any information you include in a message you post to any chat room, forum or other public posting area is available to anyone with Internet access. If you don't want people to know your email address, for example, don't include it in any message you post publicly. PLEASE BE EXTREMELY CAREFUL WHEN DISCLOSING ANY INFORMATION IN CHAT ROOMS, FORUMS AND OTHER PUBLIC POSTING AREAS. WE ARE NOT RESPONSIBLE FOR THE USE BY OTHERS OF THE INFORMATION THAT YOU DISCLOSE IN CHAT ROOMS, FORUMS AND OTHER PUBLIC POSTING AREAS.

IX. Children

The Site and the Services do not knowingly target children under the age of 13 and we do not collect personal information from any child under the age of 13. In the event we learn that such information has been provided to the Site or through the Services, we will delete or destroy it.

X. Password

Your account information and access to our Site and Services are sometimes accessible only through the use of an individual user ID and password. To protect the confidentiality of personal information, you must keep your password confidential and not disclose it to any other person. Please advise us immediately if you believe your password has been misused. In addition, always logout and close your browser when you finish your session. Please note that we will never ask you to disclose your password in an unsolicited phone call or email.

XI. Updating and Accessing Personal Information

If your personal information changes in any way, we invite you to correct or update your information as soon as possible. You can make updates to your profile information by logging into your account on the Site at any time. You can also request changes or access to your information by emailing [email protected]

XII. Choice/Opt-Out

We may send you communications or data regarding the Site and the Services, including but not limited to (i) notices about your use of the Site and the Services, including any notices concerning violations of use, (ii) updates, and (iii) information or materials regarding transactions, products and/or services purchased or selected by you. By using and/or registering with the Site and/or the Services, you agree to receive this type of communication from us. These notices will be sent to the email address we have on file for you.

Note however, that some email messages may be more commercial in nature, as they may advertise a feature of our Site or Services, a product or service we believe that you may be interested in, or otherwise discuss a marketing campaign or promotion offered by Mulu or one of our partners. We give you the opportunity to opt-out of receiving these commercial emails from us by following the opt-out instructions provided in the message.

XIII. Assignment

In the event that all or part of our assets are sold or acquired by another party, or in the event of a merger, you grant us the right to assign the personal and non-personal information collected via the Site and the Services.

XIV. Enforcement

If you have any questions about this Policy, you should first contact us at [email protected]

Contacting Us

Any questions about this Policy should be addressed to [email protected]


Beginning on January 1, 2005, California Civil Code Section 1798.83 permits our visitors who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us at [email protected].

Effective Date: 5 Dec 2011

Last Updated: 30 October 2012

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