Locle (incorporated as Leprecian Limited) ("Locle") values the privacy of our customers, users, and others who use the mobile phone applications, locle.com, and other web sites, services, and content (e.g., widgets, feeds, and applications) owned or operated by Locle (the "Locle Services") (such customers or users, collectively or individually, "Users"). This Privacy Notice governs the Locle Services.

The great majority of our Users will use the Locle Services for harmless and fun social purposes. However, please note that by its very nature, your location information is subject to abuse, misuse, and over-monitoring by others including, perhaps, by your friends, family, or acquaintances. Please manage your own mobile and profile privacy preferences on the Locle Services, on an ongoing basis, accordingly.

Please be aware that any personally identifiable information or location information that you voluntarily disclose online such as when you use the journal feature, review events and venues, post event announcements, etc. becomes publicly available and can be read, collected, and used by others and could be used to send to you unsolicited messages. Locle is not responsible for the personally identifiable information or location information you choose to disclose publicly on the Locle Service.

GENERAL INFORMATION:

This Privacy Notice details important information regarding the use and disclosure of User information collected through the Locle Services. Locle provides this Privacy Notice to help you make an informed decision about whether to use or continue using the Locle Services.

This Privacy Notice is incorporated into and is subject to the Locle Terms of Use. Your use of the Locle Services and any personal information you provide on the Locle Services remains subject to the terms of this Privacy Notice and the Terms of Use.

IMPORTANT DISCLOSURES AND CONSENTS:

·         Data and messaging (including SMS text messages) plans are required to use the Locle Services. Standard data and messaging charges, fees, and taxes from your mobile network operator (wireless carrier) apply.

·         To provide Locle, we collect, maintain, use, and display your personal data and the geographic location of your mobile device (we call this location fix of your mobile device "location information" or "geo-location").

·         Locle shows your phone's current geo-location to your selected "Locle friends" - on many phones, this location tracking may occur even when the Locle app is not open and running, but is always controlled by your privacy settings.

In order to subscribe to the Locle Services, you must consent to: (a) the use, display, & disclosure of your phone's location to provide Locle to you and your Locle friends, geo-tag your messages & content, and otherwise as set forth in this Privacy Notice; (b) receive text messages; and (c) pay carrier data, messaging, and any other charges, fees, and taxes from your usage of the Locle Services.

Locle Services default privacy settings are set for the way that most Users use Locle, we save your password, your phone's geo-location is updated automatically, and that location information is displayed to your Locle friends even when Locle is not opened and running on your phone. Changing these settings is easy - just use the top-level 'settings' menu choice on the Locle mobile application.

Please note: location information is not guaranteed to be accurate or complete and should not be relied upon for any purpose.

THE INFORMATION LOCLE COLLECTS:

·         "REGISTRATION INFORMATION": You provide to Locle certain personally-identifiable information (such as mobile phone number, wireless carrier / mobile network operator, your name, email address, phone number, date of birth, password, etc.) when choosing to subscribe to the Locle Services.

·         "PROFILE INFORMATION": When using the Locle Services you provide certain other personal information and content - such as event times and locations, political views, interests and hobbies, age, gender, sexual orientation, relationship status, and favorite places for breakfast, drinks, dancing, outdoor activities, etc. - that will be publicly displayed to other Users and on third-party sites and services in accordance with your privacy and opt-in settings.

·         "LOCATION INFORMATION": To provide the Locle Services, we derive location information from your mobile network operator / wireless carrier, certain third-party service providers, or directly from the mobile device that you used to register with Locle. This location tracking of your mobile device may occur even when the Locle mobile application is not actively open and running, but your location is displayed and shared with others only in accordance with your privacy and opt-in settings.

·         "COOKIES, PERSISTENT FILE INFORMATION": When you use the Locle Services, we may send one or more cookies (small text files containing a string of alphanumeric characters) to your computer. Locle may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your web browser and may be used by us during your subsequent visits to the Locle Web site. Persistent cookies set by the Locle Web site can be removed. Please review your web browser "Help" file to learn the proper way to modify your cookie settings.

·         "LOG FILE INFORMATION": When you use the Locle Services, our servers automatically record certain information about your usage from your mobile device and web browser. These server logs may include information such as a mobile device identification number (including IMEI) and device identifier, web requests, Internet Protocol ("IP") address, browser type, browser language, referring / exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, features used in the Locle mobile application, the number of messages and friend requests related to your profile, the amount of time spent on particular web pages, the dates and times of your requests, and one or more cookies that may uniquely identify your browser.

·         "INVITE-A-FRIEND INFORMATION": If you choose to use our invite-a-friend feature, then Locle will ask you for your friend's mobile phone number or email address. If you provide a friend's mobile phone number, then Locle will automatically send to that friend a one-time text message inviting your friend to join the Locle Service and to add you as their friend. If your friend's phone number is on a mobile network operator / wireless provider and/or mobile device that is not supported by Locle, then your friend will not receive this text message until their wireless provider and/or mobile device supports the Locle Services. If you provide a friend's email address, then Locle will automatically send that friend a one-time email inviting your friend to register on the Locle website. Your friend may contact Locle to request that Locle remove this information from our systems.

THE WAY LOCLE USES INFORMATION:

·         Locle uses your personally identifiable, registration, profile, and location information to operate, maintain, and provide to you and other Users all of the features and functionality of the Locle Service.

·         To provide the basic functionality of the Locle Services - such as displaying your live location to your friends on the Friends Map or alerting your friends when you are nearby - Locle maintains for its use each User's location fix. If Users choose to "geo-tag" certain content or data with location information - such as journal (i.e., blog) entries, broadcasts, events, favourite places - then Locle maintains these user-created geo-tags for so long as the applicable content remains on Locle's systems.

·         Locle uses your personally identifiable information, location information, and certain non-personally-identifiable information (such as anonymous log file information) to track and analyze User preferences and trends in order to improve the quality and design of the Locle Services and to create new features, promotions, functionality, and services.

·         Locle uses cookies and log file information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the Locle Services; (b) provide custom and personalized content, advertisements, and information; (c) monitor the effectiveness of our marketing campaigns; and (d) monitor aggregate usage metrics.

·         Locle uses a third-party data source to verify that your mobile phone number is on a wireless provider supported by Locle. If you have a supported mobile phone number and device, then Locle sends a text message to your phone in order to verify your custody of that handset. If your operator / carrier or handset is not supported, then Locle stores your mobile phone number and will send out a one-time text message to you when the Locle Service does become available on your wireless provider and/or handset.

·         Locle uses your email address or mobile number from time-to-time for non-marketing or administrative purposes such as sending privacy or security related notices, notifying you of major Locle Services changes, or for other customer service purposes.

·         Locle uses your personally identifiable, registration, profile, and location information to personalize and serve in-service advertisements specifically to you and your interests. For example, if you put a favorite band in your profile, then we might serve you an advertisement highlighting the concert of a similar band playing in your city. However, we do not disclose who you are to the music company.

·         Locle does use your personally identifiable information or location information to send commercial or marketing SMS text messages or email messages to you.

WHEN LOCLE DISCLOSES INFORMATION:

·         Locle does not share your personally identifiable information or location information with other, third-party companies for their commercial or marketing use without your express consent or unless you have opted-in to be part of a specific program, external application or feature in accordance with the applicable Locle Services consent procedures.

·         Locle discloses personally identifiable, registration, profile, and location information to subsidiaries, affiliated companies, or other businesses or persons for the purpose of providing certain features of the Locle Services, and for processing such information on our behalf. For example, we may disclose information to mobile operator / wireless carrier partners for the purpose of revenue recognition, or we may disclose certain information in order to provide mapping, points-of-interest, local content, or navigation features. We require that these parties agree to process such information in compliance with our privacy policy, we use reasonable efforts to limit their use of such information, and we require these parties to use any other appropriate confidentiality and security measures.

·         Locle discloses anonymous log file, usage information to interested third-parties to assist those parties in understanding the usage patterns for certain content, services, advertisements, promotions, and/or functionality.

·         Locle may release personally identifiable, registration, profile, or location information if required to do so by law, or in the good-faith belief that such action is necessary to comply with state and federal laws or respond to a court order, subpoena, or search warrant.

·         Locle also reserves the right to disclose personally identifiable, registration, profile, or location information that Locle believes, in good faith, is appropriate or necessary to: enforce our Terms of Use; take precautions against liability; protect Users from fraudulent, abusive, or unlawful uses; investigate and defend ourselves against any third-party claims or allegations; assist government enforcement agencies; protect the security or integrity of the Locle Services; or protect the rights, property, or personal safety of Locle, Users, or others.

YOUR CHOICES:

You may update, correct, or delete your privacy settings and profile information at any time via the Locle mobile application or Web site. To protect your privacy and security, we take reasonable steps to verify your identity before granting you profile access or making corrections. You are responsible for maintaining the secrecy of your unique password and account information at all times.

OUR COMMITMENT TO DATA SECURITY:

Locle uses commercially reasonable physical, managerial, and technical safeguards. We cannot, however, ensure or warrant the security of any information that Locle receives on your behalf to operate the Locle Services or that you transmit to Locle and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

If Locle learns of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. Locle may post a notice on the Locle Services if a security breach occurs. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

OUR COMMITMENT TO CHILDREN'S PRIVACY:

Protecting the privacy of young children is especially important. For that reason, Locle does not knowingly collect or maintain personally identifiable information on the Locle Services from persons under 14 years-of-age, and no part of Locle Services is directed to persons under 14. IF YOU ARE UNDER 14 YEARS OF AGE, THEN PLEASE DO NOT USE OR ACCESS LOCLE SERVICES AT ANY TIME OR IN ANY MANNER. If Locle learns that personally-identifiable information of persons less than 14-years-of-age has been collected on the Locle Services without verifiable parental consent, then Locle will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under the age of 14 has obtained a Locle Services account, then you may alert Locle and request that Locle delete that child's personal information from our systems.

Parents, the following are some resources that may help you in understanding and guiding your children's access to the Internet. While Locle does not endorse these sites or products, we provide information about them as a public service to our Users.

·         OnGuard Online (maintained by US Federal Trade Commission) http://onguardonline.gov/socialnetworking.html

·         ConnectSafely.org: http://www.connectsafely.org/

·         SafeKids.com: http://safekids.com/

·         NetFamilyNews.org: http://www.netfamilynews.org/

·         WebWiseKids.org: http://www.webwisekids.org/

·         Center for Safe and Responsible Internet Use: http://www.csriu.org/

·         GetNetWise.org: http://getnetwise.org/

·         Net Nanny: http://www.netnanny.com/

INTERNATIONAL VISITORS:

The Locle Services are hosted in the Republic of Ireland. If you are using the Locle Services from the United States or other regions with laws governing data collection and use that may differ from European Union law, then please note that you are transferring your personal data to the Republic of Ireland and by providing your personal data you consent to that transfer.

THIRD-PARTY ADVERTISERS AND AD-SERVING COMPANIES:

Advertisements that appear on Locle are sometimes delivered (or "served") directly to Users by third-party advertisers or ad network companies. These companies may automatically receive your IP address or other information about your mobile device or personal computer when serving advertisements. These third parties may also download cookies to your computer, or use other technologies such as JavaScript and "web beacons" (also known as "1x1 gifs") to measure the effectiveness of the advertisements served and to personalize advertising content. Doing this allows the advertiser or ad network to recognize your computer or mobile device each time they send you an advertisement in order to measure the effectiveness of the ad and to personalize advertising content. These companies may compile information about the sites or services visited when seeing advertisements and determine which advertisements are clicked. Locle does not access or have control of the cookies that may be placed by third-party advertisers or ad networks. Likewise, third party advertisers and ad networks do not have access to your personal information stored with Locle unless you choose to share it with them. This Privacy Notice does not cover the use of tracking technologies or personal data by any such third-party advertisers or ad networks.

IN THE EVENT OF MERGER, SALE, OR BANKRUPTCY:

In the event that Locle is acquired by or merged with a third party entity, we reserve the right, in any of these circumstances, to transfer or assign the information we have collected from our Users as part of such merger, acquisition, sale, or other change of control so that the Locle Service can continue operations. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, we may not be able to control how your personal information is treated, transferred, or used. You will be notified via notice through the Locle Services of any such change in ownership or control of your personally identifiable information.

CHANGES AND UPDATES TO THIS PRIVACY NOTICE:

This Privacy Notice may be revised periodically without further notice to you and this will be reflected by the "last modified" notice below. Please revisit this page to stay aware of any changes. In general, we only use your personal information in the manner described in the Privacy Notice in effect when we received that personal information. Your continued use of the Locle Services constitutes your agreement to this Privacy Notice and any future revisions. If we decide to change our privacy policies, then we will post those changes to this Privacy Notice, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

For revisions to this Privacy Notice that may be materially less restrictive on our use or disclosure of personal information you have provided to us, we will make reasonable efforts to notify you and obtain your consent before implementing such revisions with respect to such information. If we make such material changes to this policy, then we will notify you here in this Privacy Notice, by email, or by means of a notice on the Locle Services home page.

EFFECTIVE DATE, DATE LAST MODIFIED:

Locle Privacy Notice effective as of February 18, 2008.

Locle Privacy Notice last modified on August 18, 2008.

CONTACT INFORMATION:

If you have questions or concerns regarding this statement, you should first contact our Privacy Manager.

PLEASE CONTACT OUR PRIVACY MANAGER BY POSTAL MAIL AT LOCLE, 1 ROCK ROAD, BLACKROCK, COUNTY DUBLIN, IRELAND WITH ANY QUESTIONS OR COMMENTS ABOUT THIS PRIVACY NOTICE. WE WILL RESPOND TO YOUR INQUIRY WITHIN 30 DAYS OF ITS RECEIPT.