Privacy Agreement

SPONTO™ PRIVACY POLICY
LAST REVISION: MAY 7, 2011

1. Introduction: Please read the following to learn more about our privacy policy. Sponto, Inc. ("SPONTO") takes great pride in building strong relationships with its users and takes users' privacy concerns seriously. That being said, SPONTO strives to reasonably protect the privacy of its users and treat any personal information with the utmost care and respect. Moreover, SPONTO works hard to provide its users with a significant level of control over his/her privacy and the use of any personal information. This Privacy Policy is designed to inform our users about our privacy procedures, the types of information we gather, and the methods of its use. By visiting or using the SPONTO website, SPONTO's services and applications, and any other linked pages, features, or content offered from time to time by SPONTO in connection therewith (collectively, the "Service"), you acknowledge that you accept the practices and policies outlined in this Privacy Policy. You may also email us with any privacy-related questions you have at privacy@sponto.com.

2. Privacy Policy Coverage:
This Privacy Policy covers SPONTO's treatment of personally identifiable information ("Personal Information") and other data that SPONTO gathers when you are accessing the Service. This policy does not apply to the practices of companies that SPONTO does not own or control, or to individuals that SPONTO does not employ or manage. In addition, the Service offered by SPONTO may contain links to outside sources, both ones SPONTO has included and others submitted by users. While SPONTO attempts to provide links only to those sites that share its particular respect for privacy, it cannot take responsibility for the content or privacy policies of third-party sites. Therefore, SPONTO encourages its users to carefully review the privacy policies of any sites visited and the third party applications used.

3. Personal Information Collected:
SPONTO collects user information in a variety of ways. SPONTO receives and stores information entered by users when using the Service or otherwise provided to SPONTO. SPONTO may collect a variety of user information, including the user's name, address, email address, phone number, birthday, use information and browser information. The information provided is used to ensure that users can interact with other users, to improve the content of the Service, to customize the user's advertising and content, and to communicate about specials and new features. SPONTO may also utilize information in order to adapt the Service for a specific user's needs and for research purposes.

Users should be aware that their user names will be publicly available to others on-line. Therefore, SPONTO strongly advises its users to fully consider all privacy concerns and whether they want to include any personally identifiable information as part of their user submissions. If a user provides personally identifiable information when using any of the Services, the user does so at his or her own risk.

Registration: At the time a user activates his/her account, SPONTO requires the user to provide certain information, including user name, password, mobile number, and gender. SPONTO strongly advises its users to not use any location information as part of their username or any personally identifiable information as part of their password.

Information Collected Automatically: As part of the Service, SPONTO continually and automatically receives and stores certain types of information. Once a user signs-up and commences using the Service, SPONTO automatically and continually receives and records certain information including, but not limited to a user's GPS location, velocity and acceleration information. Additionally, SPONTO may automatically collect non- personally identifiable usage data in aggregate form for statistical measuring purposes. This type of data enables SPONTO to determine, among other things, how often users access specific parts of the Service in order to allow SPONTO to revise, improve and develop said services. As part of this improvement function, SPONTO may provide aggregate information to its partners. However, SPONTO will not disclose aggregate information to a partner in a manner that would allow for a user to be personally identified.

Invitations: If a user invites someone to use the Service, SPONTO will disclose the user's real name as part of the invitation sent to the email address the user invited. This information is necessary to ensure the invited individual knows who has contacted them.

Promotions: From time to time SPONTO may present special offers, contests, sweepstakes or other promotions. In order to enter into said promotions, a user may need to provide additional personal information. To the extent that SPONTO intends to share such information with any third party involved in the promotion, such information and shared use will be specifically described as part of the terms of any offer, contest, sweepstakes or promotion.

Surveys and Feedback: SPONTO is committed to providing the best experience for its users. Therefore, SPONTO may request information or feedback from users as part of surveys or other feedback requests as part of its continuing work to make the Service the best it can be. SPONTO may employ users' non-personally identifiable information to improve the look, functionality and content of the Service or to personalize user experience, products, programs and service offers.

User Generated Content: SPONTO encourages users to submit their original content, ideas or other materials, in compliance with the Terms of Service (http://sponto.com/ legal) for the Website. That being said, SPONTO retains full control and determination of whether and how such submissions are used.

Emails from You: If a user contacts SPONTO by email, SPONTO will use the personally identifiable email address information only to respond to the specific inquiry. Additionally, as part of the Service, you will receive emails and other communications relating to your submissions to SPONTO. All users acknowledge and agree that by posting any user submissions, SPONTO may send you email and other communication that it determines in its sole discretion relate to said user.

Emails from Us: SPONTO may send its users special announcements and correspondence, including newsletters, virtual greetings, promotional offers and other messages. The messages may contain registration information, additional Service features or other SPONTO information. SPONTO may also send email updates on users' friends, contacts or potential contacts. As discussed herein, at any time the user may exercise its right to opt-out or cancel the consent to collect information for these purposes.

Cookies: SPONTO may use software technology called "cookies" which consist of small text files stored in a computer's internet browsers to assist it in providing users with the highest level of service. Users have the option of setting their internet browser to accept, reject, or provide notification of the use of a cookie. Cookies do not consist of personally identifiable information per se but could be used to connect a user with personal information, such as an email address. Unless the user sets its internet browser to reject the use of a cookie, SPONTO may use them for various uses including recording and saving password information and determining number and retention of users employing the Service.

IP Address: When users access the Service, SPONTO collects some non-personally identifiable information concerning the computer or mobile device used for access, such as an Internet Protocol ("IP") address and the type of computer operating system (e.g., Windows Vista, Windows XP or Mac OS) being used. An IP address is the set of numbers that every computer is assigned by the specific Internet Service Provider ("ISP"). These numbers allow a server to automatically identify a user's computer and SPONTO may use it to help diagnose server problems or otherwise to administer the Service. SPONTO may also use technology to track access and traffic patterns within the Service. SPONTO may also use this information to determine which areas of www.SPONTO.com are the most enjoyed or accessed by users.

4. Personal Information Shared:
An integral part of SPONTO's business model is based on the information of its users. SPONTO does not rent or sell its user information to any third-party. However, SPONTO may share user information as described below.

Use of the Service: SPONTO's Service is designed to promote the share of information between its users, including GPS location. This includes user information provided directly to SPONTO, as well as information that users broadcast to other third party services using the Service. Submitted user information will be available to other users of the Service in accordance with the default privacy settings. User names and public profiles will be generally searchable across the Service and may be available to third party search engines. Search results, however, will not provide access to all user information unless the searching party already has a relationship with the user and the user's privacy settings allow.

While the Service does continually and automatically note your location at school, restaurants, shops, bars (etc.) SPONTO does not make this information available to other users except in the following cases: on a map in an anonymous form, separated from personally identifiable information; in the case where you use the service to publish your own location information explicitly; and, lastly, if the service detects that you are in close proximity with at least two other members and one of the members uses the service to publish the groups location information. SPONTO does not specifically ask you to provide your home address or any other location information for your user profile. If a user mistakenly, or other third-party without authorization, adds a user's home or other location information to the Service database the user may request removal of the home or location information by sending an email to SPONTO at privacy@sponto.com.

The Service may allow its users to connect with other third-party social networking services. If a user chooses to connect its SPONTO account and use such third-party services, any information provided is no longer under the control of SPONTO and may be subject to the terms of use and privacy policies of such third parties.

Third Party Disclosure: Disclosure: It is the policy of SPONTO not to share any personally identifiable information with a third party for the purposes of marketing. All pertinent information collected will only be used to provide the Services. From time to time SPONTO may engage third parties for technical, processing or other services related to www.SPONTO.com or the Services. However, SPONTO will use all reasonable commercial efforts to ensure that such parties are obligated to keep the information secure and confidential. SPONTO may disclose personal information to the extent necessary to enforce our terms of use, or to otherwise protect the rights of users of the site. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction. Moreover, to the extent necessary to comply with court orders or with requests by law enforcement or governmental agencies, SPONTO may provide personally identifiable information to the required third parties.

Sale of Business or Assets: In some cases, SPONTO may choose to buy or sell assets. In these types of transactions, user information is typically one of the business assets that are transferred. In the event that all or substantially all of SPONTO' assets are sold, given, or otherwise transferred to another entity, all user information collected as part of access to and use of the SPONTO service would likely be transferred to that entity as well. By using the Service users acknowledge that such transfers may occur, and that any acquirer of SPONTO may continue to use its information as set forth in this policy.

Hyperlinks: The Service may contain hyperlinks, pointers or introductions to other sites on the internet or services that may be maintained by third parties. These other sites may use cookies, collect data or solicit personally identifiable information using methods not confirming to SPONTO' Privacy Policy. Such links do not constitute an endorsement by SPONTO of any third-party site or any materials contained therein. SPONTO does not control, and is not responsible for, the availability, accuracy, or currency of such third- party site or any information, content, products or services accessible from such third- party site. Therefore, SPONTO recommends that you fully review the privacy policy of any particular site maintained by a third party provider.

With Your Consent: Except as otherwise set forth herein, users will be notified when their personal information may be shared with third parties and users will have the opportunity to prevent the sharing of this information.

5. Security: SPONTO has attempted to incorporate reasonably appropriate physical, electronic, and managerial procedures into its business and online systems to protect and prevent unauthorized use of the information it collects on its users. Such methods include use of a firewall to prevent unauthorized access to our systems and information. While SPONTO exercises reasonable care and due diligence in providing a secure conduit of information between a user's computer or other device and our servers, SPONTO cannot and does not guarantee the security of materials or information transmitted to us over the Internet or wirelessly. Therefore, while SPONTO will attempt to protect the transmission of any information using methods which comply with the industry standards, we accept no liability for any unintentional disclosure of same.

6. Contact Us: If you need further assistance, please send an e-mail with your questions or comments to info@SPONTO.com or write to SPONTO at:

Questions
SPONTO, Inc.
5502 Nebraska Avenue NW
Washington DC 20015

You may also telephone us at (703) 472-7627.

7. Effective Date: The Privacy Policy detailed herein applies to any and all information that you may have obtained from SPONTO. SPONTO reserves the right, at its full and complete discretion and without prior notice, to change, modify, amend, add, subtract, or otherwise remove portions of its Privacy Policy at any time and for any or no reason. Please periodically continue to check the Privacy Policy on http://www.SPONTO.com/privacy.html for any changes. Your continued access to and use of the Service after the posting of any amendments, deletions or other changes to the Privacy Policy will constitute your acceptance, acknowledgment and agreement to the respective changes. This Privacy Policy was last updated on 5/07/2011.

News

Sponto will be presenting at the DC Tech Meet-Up during Social Media Week on Feb. 15th.