Effective Date: August 1, 2017

Last Modified: October 15, 2017

This Privacy Policy applies to all of the products, services, and websites (collectively, our “Services”) offered by  (“eFlutter,” “we,” “our”). By using our Services and/or registering with eFlutter, you acknowledge and accept the provisions in this Privacy Policy and grant us permission to collect, store, and use the items of personal information described herein, so long as eFlutter adheres to the standards set forth more clearly below.  You also accept and understand that part of our services are to advertise, promote, and register you in other places and other websites that are outside of our direct control.  By registering yourself with us you grant us permission to register you and advertise you with third parties. You understand that you yourself are responsible for learning about the Terms and Conditions and Privacy Policies of third parties.  You may contact us at anytime to ask where we registered your information at [email protected].   If you would like your information removed from third party websites or businesses we will work with you and do so in accordance with their Privacy Policy.

We reserve the right to amend this Privacy Policy at any time and provide such amendments to you by posting a revised version on our website.  The revised version will be effective at the time we post it. In any event, we will not reduce your rights under this Privacy Policy without your explicit consent, and we expect most changes will be minor. Each version of this Privacy Policy will be identified at the top of the page by its Last Modified date, and we will also keep prior versions of this Privacy Policy in an archive for your review.

If you have any questions about this Privacy Policy, please feel free to contact us through our website, by email at [email protected].

Information Collected

In order to provide our full range of Services, we may collect the following types of information:

Information you provide. When you register for a username, we ask you for personal information (such as your email address, username, and an account password). In order to improve the quality of our Services and to provide you with a better user experience, we may combine the information you submit with information provided by third parties.

Financial Data. Some portions of the eFlutter website are provided as paid services. Accordingly, our payment processor may collect billing information from you to facilitate your purchase of Services from us. Such information may include a credit card number, the associated card’s expiration date, and a billing address. WE DO NOT HAVE ACCESS TO YOUR FINANCIAL DATA, WHICH IS COLLECTED BY OUR PAYMENT PROCESSOR. Financial data that is collected by our payment processor will only be used as necessary to initiate and complete any orders placed by your account. Credit card purchases for the pay services offered on the eFlutter site are processed via industry standard encryption through third-party processors, which processors only use your information the purpose of processing order placed by your account. Financial Data is considered private information and will not be shared with us, or with third parties, except with your authorization and as necessary to carry out orders placed by you with the understanding by you that such transaction(s) may be subject to the rules and policies of such third parties. Financial or other data provided by you to any companies or websites advertising on our website are not governed by this Privacy Policy. Any information provided by you to a third party, and any transaction with such a third party, is subject to that third party’s terms and conditions and privacy policy.

Demographic Information. Each time you access our Services, our servers may automatically record in their server logs information that your browser sends whenever you visit a website. These server logs may include information such as your Internet Protocol or “IP” address, the date and time of your request, browser type, browser language, and one or more cookies (see description below) that may uniquely identify your browser. Additionally, we may collect other available demographic information, such as zip code, search history, browsing history, and user history. Aggregate, non-individual membership demographic information may be shared with third parties with whom we have a direct or indirect relationship who may offer products or services we believe you may be interested in.

Links. We may present links that include codes that enable us to track whether these links have been followed. This information is used to improve the quality of our advertising and customized content, as well as the organization and layout of our website.

Cookies. Assuming your browser is configured to accept them, when you visit our websites, we will send one or more cookies to your computer or other device. A cookie is a small file containing a string of characters that uniquely identifies your browser. We may also set one or more cookies in your browser when you click on an ads or other links presented on our website. Cookies make it possible to store user preferences and record which portions of our website you and other users are using the most. We use cookies for the purposes of preventing fraud and improving the quality of our Service. eFlutter uses what are known as “evercookies” which may appear on your system despite certain settings and software to block standard cookies. Therefore, the evercookie works to ensure that you do not inadvertently clear your cookies and lose your preferences and ability to use eFlutter as you have selected and to ensure that we keep people who breach our rules off of eFlutter for the well-being of the eFlutter community.

User communications. We may retain communications that you send to eFlutter by email or otherwise, in order to process your inquiries, respond to your requests, and improve our Services.

Affiliated eFlutter Services on other sites. From time to time, we may offer some of our Services on or through other websites. In the event that we do offer such services, it is possible that personal information you provide to those sites may be sent to eFlutter to facilitate delivery of those services. We will process such information under this Privacy Policy as if the information had been submitted directly from you to eFlutter. Any affiliated site through which our Services are offered will likely have its own privacy policy, which may be very different from ours. It is very important for you to review the privacy policies for such affiliated sites before submitting personal information to them.

Other sites. This Privacy Policy only applies to Services offered by eFlutter. We are not able to exercise control over sites that are linked to from within our various Services. These other sites may collect data, set their own cookies in your browser, or ask you to provide personal information.

Use of Personal Information

eFlutter processes personal information only for the purposes described in this Privacy Policy. In addition to the reasons set forth above, such purposes also include:

Providing our Services (which includes displaying customized advertising and other content);

Auditing, research, and analysis (to maintain, protect, and improve our Services);

Technical diagnostics (to ensure our network is functioning as expected);

Protecting the rights or property of eFlutter or our users, or third parties;

To comply with applicable law, to cooperate with law enforcement and the court system;

Creating new Services; and

Marketing and sales of advertising.

We process personal information on our servers, which are located in the United States of America and in other countries. As a result, there exists the possibility that we may process your personal information on a server that is not located in your home country. In some cases, we may process personal information at the request of third parties and according to their instructions, such as our advertising partners. We will treat all personal information processed at the request of a third party exactly as if we had collected the processed personal information ourselves.

Important- If you cancel working with us, it is your responsibility, not our responsibility, to remove your personal information from any other third party databases and sites.  Part of our services is to register you with various third parties, which you have agreed to upon registration and when you accepted the Terms and Agreements and Privacy Policy.  By doing this we have fulfilled part of our services for you.  Our services do not include removing, guarding, protecting, updating, etc. your information for you.

Information Communicated via Video Chat

Part of eFlutter services is to register you on websites that allow for interactive video and written chat services, where it is possible for you to communicate identifying information about yourself to other users who are viewing a live video stream from your computer. You should be aware that any such communication is made directly to those users viewing the live video and written stream, and not to eFlutter. We are not responsible for the privacy of personal identifying information that you communicate via video or written chat to users who are viewing a live stream from your computer. Accordingly, you should refrain from sharing personal information.

Privacy Principle: Choice

Use of our Services requires registering for a username. When you sign up for our Services, we ask you to provide personal information, such as your email address.  In the event that we develop a new use for personal information that is not described in this Privacy Policy, you will be given the opportunity to opt out of such use. We will not collect or use sensitive information, such as racial or ethnic origins, politics, religion, or medical information, for any purpose not described herein.

Use of our Service may require you to configure your browser settings to allow cookies to be stored on your computer or other browsing device. You should be aware that the Services might not function properly without cookies enabled.

Privacy Principle: Onward Transfer

eFlutter may from time to time share personal information with individuals or other companies. In the event that we share information with companies or individuals not a part of eFlutter, we will only do so in the following circumstances:

• If we have asked for and received your consent. You should be aware that when you register for a username, during the sign up process, you provide us with permission to share your personal information with trusted third parties (e.g., streaming sites, social network sites, promotional partners and advertisers) so that they can promote their products and services and those of their affiliates and partners based on your preferences and interests. You may “opt out” of such disclosure(s) to the extent they include your personally identifiable information by sending an email at any time to [email protected] indicating your intent to do so. Doing so may affect your ability to work and perform.
• For the purpose of processing personal information on our behalf, we may provide personal information to trusted persons or businesses.
• We have a good-faith belief that access, use, preservation, or disclosure of your personal information is reasonably necessary: (a) to satisfy any applicable law, regulation, legal process or enforceable governmental request; (b) to enforce applicable Terms of Service, including investigation of potential violations thereof; (c) to detect, prevent, or otherwise address fraud, security or technical issues; or (d) as required or permitted by law, to protect against harm to the rights, property or safety of eFlutter, its users, or the public.

This Privacy Policy may be superseded by an acquiring party’s policies in the event that eFlutter becomes involved in a merger, acquisition, or any form of sale of some or all of its assets.

We may share with third parties certain pieces of aggregated, non-personal information, such as the number of users who viewed a certain page in our website, for example, or how many users clicked on a particular advertisement. Such information does not identify you individually.

Privacy Principle: Security

Appropriate security measures are taken to protect your personal information against unauthorized access to or unauthorized alteration, disclosure, or destruction. These measures include internal reviews of our data collection, storage, and processing practices. Physical security measures are also taken to prevent unauthorized access to systems where your personal information is stored.

Your personal information is revealed to our employees, contractors, and agents on a need-to-know basis in operating, developing, or improving our Services. As a condition of their employment or association with eFlutter, these individuals are bound by confidentiality obligations. If they fail to maintain the confidentiality of your personal information, they may be subject to discipline, including termination and criminal prosecution.

Privacy Principle: Access

We make good-faith efforts to provide you with access to your personal information that we have collected. In the event that such information is inaccurate, we will endeavor to provide facilities that allow you to either correct this data or to delete it, provided we are not otherwise required to retain such data by law or for legitimate business purposes. Before processing requests to access, delete, or alter such data, we ask individual users to identify themselves and the information requested to be accessed, deleted, or corrected. We may refuse to process requests: (i) that require disproportionate technical effort; (ii) that are unreasonably repetitive or systematic; (iii) that would be extremely impractical (for instance, requests concerning information residing on backup tapes); (iv) that jeopardize the privacy of others; or (v) for which access is not otherwise required. Unless providing access and correction service would involve a disproportionate effort, we will perform it free of charge.

Privacy Principle: Enforcement

We regularly review our compliance with this Privacy Policy. If you feel there has been a specific instance where we have failed to comply with this Privacy Policy, please bring this matter to our attention by sending a detailed description of such noncompliance to us at email [email protected].

It is our policy to contact the complaining user regarding his or her concerns when we receive formal written complaints at this address. In order to resolve any complaints regarding the transfer of personal data that cannot be resolved between eFlutter and an individual, we will cooperate with the appropriate regulatory authorities, such as local data protection authorities.

Email Communications

By providing your email address in connection with the creation of an account with eFlutter, you thereby demonstrate your consent to receive email communications from us. Email addresses, when provided, are only used for friend notifications, broadcast and payout reminders, and account verification. Your email address is never sold or shared. If you wish to “opt-out” of all future email communications relating to eFlutter, you may do so by taking the following steps:

Send and email to [email protected]

Include your full name and the email address that you registered with us and write the words “OPT OUT”

This will only remove you from our mailing list, however, as long as you are registered with us you will still receive important mail information.

Important – this does not remove your personal data or email from third party websites.