SocialGrow, Inc.

Privacy Disclaimer (last updated 2/18/10)X

Definitions

The following definitions are used in this Privacy Policy:

• “The competition” or “the MassChallenge competition” means the 2010 MassChallenge Startup Competition.

• “Entrant” means each member of every team competing in the competition.

• “Participant” means all parties playing an active role in the competition, including mentors, judges, entrants, affiliated third parties and speakers

• “Sponsors” means all corporations or entities that sponsor the competition.

Information that we collect

When you register with us, we collect some personal information from you, including your name, address, telephone number, and email address. We also collect additional information to be used in the competition. The type of information collected varies depending on your role in the competition, as described in the Official Competition Rules.

We also collect information about your interaction with our website. For example, we collect certain standard information that your browser sends to every website you visit, such as your IP address, browser type and language, access times and referring website addresses. We may also use website analytics tools on our site to retrieve information from your browser, including the site you came from, the search engines and keywords you used to find our site, the pages you view within our site, the links you click on, your browser add-ons, and your browser’s width and height.

Additionally, we may use technologies, such as cookies and web beacons, to collect information about the pages you view, the links you click and other actions you take on our sites and services. A cookie is a small text file that is placed on your hard disk by a Web page server. Cookies contain information that can later be read by a Web server in the domain that issued the cookie to you. Cookies cannot be used to run programs or deliver viruses to your computer. A web beacon is a single-pixel gif which assists in delivering cookies on our website and allows us to count users who have visited those pages. We may use web beacons from third parties in order to help us compile aggregated statistics regarding the effectiveness of our promotional campaigns or other operations of our website.

How we use your information

We may use information that we collect about you to:

• verify participant’s eligibility and operate the competition;

• match entrants with mentors and judges

• share information you have voluntarily provided about yourself with matched participants and MassChallenge staff in order to operate the competition;

• match entrant with the event, category or services best suited to your company’s needs;

• communicate with you by e-mail, postal mail, telephone and/or mobile devices about the competition;

• perform auditing, research and analysis about your use of our website so that we can make improvements to it;

• ensure the technical functioning of our network;

• develop new services;

• manage our business; and

• perform functions as otherwise described to you at the time of collection.

Choices for personal information

If we propose to use personal information for any purposes other than those described in this Privacy Policy, we will offer you an effective way to opt out of the use of personal information for those other purposes. We will not collect or use sensitive information for purposes other than those described in this Privacy Policy, unless we have obtained your prior consent.

Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some MassChallenge features and services may not function properly if your cookies are disabled.

Information sharing

Your personal information consists of the information you submitted regarding yourself, your company, and other information you submitted to us. We may share your personal information with entrants, judges, mentors, and MassChallenge staff insofar as it is necessary to run the competition. However, participants and sponsors will only have access to personal information which you disclose as part of your participation in the competition.

We only share personal information with other companies or individuals outside of the competition in the following limited circumstances:

• We have your consent. We require opt-in consent for the sharing of any sensitive personal information.

• We provide such information to trusted third-party businesses or persons for the purpose of performing services, such as website development, on our behalf. We require that these parties agree to perform these services based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures.

• We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) detect, prevent, or otherwise address fraud, security or technical issues, or (c) protect against harm to the rights, property or safety of MassChallenge, its users or the public as required or permitted by law.

We may share aggregated and non-personal information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis. For example, we may tell our advertisers the number of visitors to our website and the most popular features or services accessed. This information does not contain any personal information and may be used to develop website content and services that we hope you and other users will find of interest.

Information security

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. For example, the personal information you provide is stored on the secure databases of [name of third party whose database you’re using]. In addition, we use encryption in the transmission of your sensitive personal information between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your personal information. Payments made through our website are processed by PayPal, and thus are secured by PayPal.

Access to your personal data

We make good faith efforts to provide you with access to your personal information and either to correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes.

Children’s privacy

Our website is a general audience site, and we do not knowingly collect personal information from children under the age of 13.

Visiting our websites from outside the United States

This Privacy Policy is intended to cover collection of information on our website from residents of the United States. If you are visiting our website from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. Please be assured that we seek to take reasonable steps to ensure that your privacy is protected. By using our services, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Privacy Policy.

Complaints

Please feel free to direct any questions or concerns regarding this Privacy Policy or MassChallenge’s treatment of personal information by contacting us through this web site or by writing to us at

MassChallenge, Inc.

P.O. Box 426155

Cambridge, MA 02142

When we receive formal written complaints at this address, it is our policy to contact the complaining user regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between MassChallenge and an individual.

Changes to our Privacy Policy

We will occasionally update this Privacy Policy to reflect changes in our practices and services. When we post changes to this Privacy Policy, we will revise the “last updated” date at the top of this statement. If we make any material changes in the way we collect, use, and/or share your personal information, we will notify you by sending an e-mail to the e-mail address you most recently provided us. We recommend that you check our website from time to time to inform yourself of any changes in this Privacy Policy or any of our other policies.