A Word About Your Privacy

We respect your privacy. Not only do we respect it, but we also protect it. When you subscribe to Two Oars™ we will ask you for personal information about yourself. This information is only provided to those to whom you have authorised us to release information, or as required by legislation. All of the above must meet our rigorous privacy standards. This policy does have a legal tone that reflects both the importance of the issue and it is consistent with recent Data Protection legislation. If you want more information regarding our privacy principles, please read on. If you have privacy questions or concerns, please contact our Data Protection Officer at privacy@twooars.com.

TRUSTe License: Two Oars Limited is a licensee of the TRUSTe Privacy Program. TRUSTe is an independent, non-profit organization whose mission is to build user's trust and confidence in the Internet by promoting the use of fair information practices. This privacy statement covers the site www.twooars.com. Because this Web site wants to demonstrate its commitment to your privacy, it has agreed to disclose its information practices and have its privacy practices reviewed for compliance by TRUSTe.

The Data Protection Act 1998

The Data Protection Act puts obligations on users of personal information and lays down principles for its use. One principle states that information has to be processed fairly and lawfully. This means that you're entitled to know how we intend to use any information you provide. You can then decide whether you want to give us that information. To provide the highest level of customer service we need accurate subscriber information. You can help by updating your user profile whenever your circumstances change. You also have the right to request a copy of information that we hold about you in our records. Any request to obtain a copy of this information must be made in writing to the Data Protection Officer, Two Oars Limited, Marble Arch House, 66-68 Seymour Street, London W1H 5AF, United Kingdom.

Its your information and you decide who will have access to it.

The following discloses the information gathering and dissemination practices for the services offered by Two Oars Limited (the "Services"). Two Oars Limited ("Two Oars") reserves the right to amend this Privacy Statement at any time with or without notice. Only the current Privacy Statement is deemed effective, so please review this Privacy Statement periodically.

Two Oars has created this Privacy Statement in order to demonstrate our firm commitment to safeguarding the privacy of our Subscribing Entities and our website visitors. Our Privacy Rules summarise this commitment.

Two Oars General Privacy Rules:

1. We do not reveal any personally identifiable information that we collect about you, your use of the Services or any data you enter to anyone else.

During the registration process, Two Oars collects personally identifiable information (e.g. names, email addresses and postal address) from the Subscribing Entities. Two Oars may also collect personally identifiable information at other times. Two Oars uses such information only for its own internal purposes. For example: providing our Services; administering our website; providing technical support, contacting or sending information to the Subscribing Entity, and verifying its users' identities. We will not sell, rent or release a Subscribing Entity's personally identifiable information to any other party except with its explicit permission. In addition, we will not access or release the Subscriber's Data except at the request of the Subscribing Entity or under certain rare special circumstances (see below).

Rare Special Circumstances.

Two Oars Limited may disclose or access personally identifiable information or Subscribing Entities' data in special cases if (a) it is required to do so by law or to comply with legal process served on Two Oars Limited, or (b) we have a good faith reason to believe that disclosing or accessing such information is necessary or appropriate in order to (i) identify, contact or bring legal action against someone who may be violating or threatening to violate Two Oars Limited's or its Third Party Providers' Terms & Conditions, Privacy Policy or policies or causing or threatening to cause injury to or interference with the Services or Two Oars Limited's, its Third Party Providers' or its Subscribing Entities' or any third party's rights or property, (ii) protect and defend the Services, or Two Oars Limited's, its Subscribing Entities' or Third Party Providers' rights or property, (iii) act under exigent circumstances to protect the safety of the Services, or of Two Oars Limited's Subscribing Entities, Third Party Providers or the public, or (iv) identify, confirm or assess a violation or threatened violation of Two Oars Limited's or its Third Party Providers' Terms & Conditions, Privacy Policy or policies, or injury to or interference or threatened injury to or interference with the Services or Two Oars Limited or its Subscribing Entities' or any third party's rights or property.

In the event of any planned disclosure by Two Oars Limited to a third party of Subscriber's Data as described in point (b), above, which results from a circumstance that Two Oars Limited believes in good faith is not caused by such Subscribing Entity any such disclosure shall occur only after prior notice to the Subscribing Entity and upon terms and conditions that will safeguard the Subscribing Entity's confidential information to the extent reasonably feasible.

Personal Information of Others.

Your information may include contacts and other personal information in your Contacts module for individuals who have not subscribed to Two Oars or who are otherwise not Two Oars users. Two Oars is committed to protecting the privacy rights of these individuals. We will neither access your Contact data nor sell, exchange or give information in your Contacts module regarding such individuals to any third-parties.

2. Unless you choose otherwise, Two Oars shares information about you only on a basis that does not personally identify you.

• Use of personally identifiable information by Two Oars
• Personally identifiable information and Third Party Providers
• Creation of anonymous profiles
• Use of cookies

Personally identifiable information and Third Party Providers:
Two Oars partners with Third Party Providers (e.g. affiliates, sponsors, partners, advertisers, and content and service providers) to provide special services, products, discounts or other information that will benefit our Subscribing Entities. The free features of our Services are funded by our Third Party Providers or by Two Oars Limited.

If a Subscribing Entity is asked for personally identifiable or other information, that Subscribing Entity is providing this information only to Two Oars, unless the Subscribing Entity is registering for, purchasing or using services or products provided by a Third Party Provider (e.g. in order for Two Oars Limited to provide a service or the Subscribing Entity to purchase or use a product, it may be necessary for Subscribing Entities to provide certain personally identifiable and other information directly to the Third Party Provider. Use of these services is always optional for all Two Oars Limited Subscribers), or using a service offered by a Third Party Provider as part of the Two Oars Services. For example, when the Subscribing Entity is registering and using the Barclaycard Merchant Services website to pay for this service.

Personally identifiable and other information may also be collected by our Third Party Providers when Subscribing Entities view or access pages, or view or respond to an advertisement or promotion offered by one of our Third Party Providers on this website or Third Party Provider websites. Collection and use by a Third Party Provider of any information that is transmitted to a Third Party Provider will be subject to such Provider's privacy policy, and Two Oars has no responsibility or liability for such independent policies or the Providers' use of such information. Although we choose all partners carefully, we advise that all Subscribers review a Third Party Provider's privacy statement prior to registering for or using their service.

Creation of anonymous profiles:
Two Oars uses information that it collects about Subscribing Entities to create Subscriber preference profiles that help us attract Third Party Providers. Two Oars and its Third Party Providers may also use these Subscriber preference profiles on an anonymous basis to help them customise Subscribing Entities experiences using the Service. Anonymous Subscriber preference profiles are shared with Third Party Providers, but unless a Subscriber otherwise expressly elects, the profiles do not reveal any personally identifiable information and the Third Party Provider cannot use them to determine an individual Subscriber's identity. Any other information that we share with our Third Party Providers or that they share with us is shared ONLY in aggregate form.

Use of cookies and log files:
In order to offer our Services and to better respond to any problems Subscribing Entities may experience with the Services and our public website, Two Oars uses cookies.

Our Service uses cookies in two ways. First, we use them to identify Subscribers in order for them to use the Services. These cookies expire at the end of each Subscriber's session apart from one that only stores your first name so that we can say "Hello" the next time you login! We also use cookies to store and sometimes track information and record Subscriber preferences. This information cannot be linked to a Subscriber's personally identifiable information except for internal purposes when necessary (to contact a Subscriber, for example). These cookies are an integral part of providing the Services.

Our public website (these are the public web pages of www.twooars.com that provide visitors with information about our company (Two Oars Limited) and our Service) uses two anonymous cookies in order to administer our website and best serve our visitors. The first is used to track how visitors have come to our site, and expires after 24 hours. The second cookie is used to determine how frequently a visitor or Subscriber visits our public website, and expires after 1 year. We may also review our log files which show how often our site is visited. These files and both of the anonymous cookies do not include any personally identifiable information about a site visitor or Subscribing Entity.

If you want to stop cookies being stored on your computer in future, please refer to your browser manufacturers' instructions by clicking help in your browser menu. Further information on deleting or controlling cookies is available at www.aboutcookies.org. Please note that by deleting cookies or disabling future cookies you may not be able to access certain areas or features of our site.

Our Third Party Providers may also use their own cookies. Our Privacy Statement does not apply to their cookies, which are subject to the terms of their own privacy policies.

We post customer testimonials on our website which may contain personally identifiable information such as the customer's name. We do obtain the customer's consent, to post their name along with their testimonial, prior to posting the testimonial.

3. We use industry-standard technology and other means to keep your information as secure as possible.

At Two Oars, we know the security of your data is a crucial issue for you. Two Oars exercises great care to secure your data and personally identifiable information, and has implemented security measures in accordance with industry-standard practice. Two Oars uses multi-layered security to protect your data, and we are continuously engaged in examining and updating security as we update our Service. More information about our security practices, and the protection of your data, is available on our FAQ page.

Internally, we forbid access to subscribers' data and restrict access to all personally identifiable information to employees who need access to the information in order to do their jobs. These employees are limited in number, and are committed to our privacy and security policies. All such employees execute comprehensive nondisclosure agreements, which provide explicit confidentiality protections. Any employee who violates our privacy and/or security policies is subject to possible termination and civil and/or criminal prosecution.

Unfortunately, no data transmission over the Internet can be guaranteed to be totally secure, and there is a slight risk that data could be intercepted or interrupted during Internet transmission. Although we strive to provide for secure transmission of Subscribing Entities' data and personally identifiable information from the Subscriber's computer to the Two Oars's servers and for secure storage of all data, Two Oars cannot warrant the security of any information Subscribing Entities transmit to us or from our online services, and Subscribing Entities do so at their own risk.

4. Two Oars does not send spam and we give you choices concerning the collection and use of information about you.

We will send the Subscribing Entity's contact person (known as the "Prime User") a confirmation email when the Subscribing Entity first joins our service. This is to confirm the card payment has been accepted and will include the Subscribing Entity's new account details. After that we will email the Prime User a payment receipt for each monthly fee processed. These are the only emails we will send to the Subscribing Entity except in response to any emails the Subscribing Entity may send to us regarding our service.

Except for a few specific instances, Subscribing Entities may always elect:

Subscribing Entities can exercise some of these options by telling us during the registration process or when they choose to receive or use a specific advertisement, service or product. Subscribing Entities can notify us of a change in their registration options by:

If information is being collected by any entity other than a Third Party Provider or if it will be disclosed by Two Oars in any manner not described in this Privacy Statement, Subscribing Entities will be given prior notice, and can always elect not to use that particular service or provide the Information.

If a Subscribing Entity discontinues its subscription, all the personally identifiable information of the Subscribing Entity will be removed from our databases (other than in aggregate form), and the data will be removed and/or deleted from our servers.

A Subscribing Entity may update or modify any of its personally identifiable information by using the 'settings' link once logged in. For further assistance with this, Subscribers may send an email to helpdesk@twooars.com, or write to Help Desk, Two Oars Limited, Marble Arch House, 66-68 Seymour Street, London W1H 5AF, United Kingdom.

To ask any questions about this Privacy Statement, our Services, our public website or make any suggestions or tell us about any other ideas concerning our public website or our Services, please contact:

Two Oars Limited
Marble Arch House
66-68 Seymour Street
London W1H 5AF
United Kingdom

privacy@twooars.com

Last Updated on 22nd December 2005, © Two Oars Limited All rights reserved