Privacy Policy


Your continued use of the website explicitly means you consent to your use of this website being governed by this Website Privacy Policy and agree completely and without hesitation or limitation with this Privacy Policy for; if you do not consent or agree, you must terminate your use of this web site immediately.

NOTE: Unauthorized attempts to upload or change information on the Random Walk Ventures’ Website (“,” or Website”) are strictly prohibited and may be punishable under the Computer Fraud and Abuse Act of 1986 and the National Information Infrastructure Protection Act.

Random Walk Ventures, LLC, (“Random Walk Ventures,” “we,” “us,” “our”) is committed to maintaining the trust and confidence of its clients and visitors to its web site, and is dedicated to treating its clients’ and web users’ information in a manner that is consistently fair, ethical, and responsible. Random Walk Ventures is also committed to the security of the data it collects when you use the Website. Random Walk Ventures wants you to understand when it collects and uses information about you, the actions it takes to protect your privacy, and its commitment to data security. 

This online privacy policy applies only to information collected through our Website and not to information collected offline.

Random Walk Ventures created this Privacy Policy to demonstrate its firm commitment to privacy and security. This Privacy Policy describes how Random Walk Ventures collects information from all end users of the Website (the “Website”) – those who access some of Random Walk Ventures’ Services but do not have accounts (“Visitors,” “you,” “your”) as well as those who may pay a service fee or otherwise subscribe or register to use the website (“Users,” “you,” “your”) – what Random Walk Ventures does with the information collected, and the choices Visitors and Users have concerning the collection and use of such information. Random Walk Ventures requests that you read this Privacy Policy carefully.  Random Walk Ventures will not acquire any more information about Users or Visitors than is required by law or is otherwise necessary to provide a high level of service efficiently and securely.

Your privacy is important to Random Walk Ventures. This Privacy Policy explains how we intend to use any information you provide to it. Providing information on this site is voluntary.


Residents of the State of California, under certain provisions of the California Civil Code, have the right to request from companies conducting business in California a list of all third parties to which the company has disclosed personally identifiable information during the preceding year for direct marketing purposes. Alternatively, the law provides that if the company has a Privacy Policy that gives either an opt-out or opt-in choice for use of your personally identifiable information by third parties (such as advertisers) for marketing purposes, the company may instead provide you with information on how to exercise your disclosure choice options.

Random Walk Ventures has opted for the alternative option and therefore presents this comprehensive Privacy Policy which provides you with details on how you may opt-out or opt-in to the use of your personally identifiable information by third parties for direct marketing purposes. Therefore, while Random Walk Ventures is not required to maintain or disclose a list of third parties that received your personally identifiable information for marketing purposes, general information concerning third-party Website advertisers is provided herein for your understanding.


Random Walk Ventures is committed to safeguarding the privacy of its website visitors; this policy sets out how we will treat your personal information. Providing Random Walk Ventures with any personal information is not a requirement to access the Website. We do not collect any personal information about you when you visit the Website unless you choose to provide this information to us. Random Walk Ventures does, however, collect and store certain information automatically. Random Walk Ventures handles information about your visit to its website as detailed herein. collects information for Website management and statistical purposes. We use the collected information for statistical and demographic purposes, i.e.: to count the number of visitors to each unique Website or page, to establish the type of visitors, to list the most visited content, etc., all of these to improve and make the Website(s) more useful to visitors like you.

This Website receives and stores any information you enter on the Website or give or Random Walk Ventures in any other way, such as via telephone, electronic mail, online or otherwise. For example, this information may be collected when you send a request using the “Contact Us” page or form, when registering to comment on one or more of the Forum entries, or when you contact Random Walk Ventures for customer, not financial or retirement, support. We collect information in different ways from Visitors and Users who access the various parts of the Website and the network of websites accessible through the Website. uses this information primarily to provide a customized experience as you use the Website and, generally, does not share this information with third parties. However, we may disclose personal information collected if Random Walk Ventures received your permission beforehand or in very special circumstances, such as when we believe that such disclosure is required or permitted by law or other special cases described below.

This policy statement discloses’s privacy practices including the notification of:
a. Personally identifiable information collected through the Website;
b. Intended usage of this information;
c. Choices available regarding opt-in/opt-out, data collection, use and distribution of the information;
d. Security measures designed to protect the loss or misuse of information under the control of and/or Random Walk Ventures; and
e. How to maintain the accuracy of your information.


Certain features of the Website may allow you to contribute content. By their very nature, this information may reveal your identity or be linked to you personally. The Website may make blogs, message boards and other public forums available to its users. If you post personal information online, it will be publicly available and this information may reveal your identity or be linked to you personally. You may, therefore, receive unsolicited messages from other parties. Random Walk Ventures cannot ensure the security of any information you choose to make public, nor can we ensure that parties who have access to such publicly available information will respect your privacy. Please exercise caution when deciding to disclose personal information in these areas.

Any information you may disclose in any User Directory, case studies, testimonials, Forums, or other public areas of the Website(s), or anywhere on the Internet, becomes public information. You must exercise caution when deciding to disclose personal information in any public area.  Please know that if you submit comments, blog entries or other user-generated content to the Website, it may be published online or offline in any media or format, whether currently existing or hereafter developed. Others may have access to this content and may have the ability to share it with third parties across the Internet. Random Walk Ventures may also publish your name, email or other personal information with the content or a portion thereof. Random Walk Ventures may also use the content or a portion thereof for advertising, marketing, publicity and promotional activities.

Due to the extent of the variables identified within this Section 3, this Website Privacy Policy does not apply to any information you freely supply on any Message Board, including comments posted to Forum and/or Blog entries. Please be judicious in providing personal or sensitive information. While Message Board/Forum/Blog moderators (if any) may try to do their best to identify and exclude other participants who are collecting information for purposes other than merely commenting on Website Message Board(s)/Forum(s)/Blog posts, no moderator can be responsible for information gathered by other participants.


Visitors to the Website are not required to register in any manner.  Users are asked to provide certain personal information when they submit a request through a “Contact Us” form or attempt to post a comment to any of the Forum entries.  This information may include, but may not be limited to, name, address, telephone number, email address, and other information, perhaps such as the type of personal computer being used to access the Website. Users may be asked to complete an online form that collects information about demographics, product or website usage and preferences, along with other information that will help Random Walk Ventures improve its Website.  Random Walk Ventures through its Website may collect and store anonymous demographic information (such as your zip code, gender and age), and use this data to tailor your experience at our Website, provide content that Random Walk Ventures may determine you might be interested in, perform general improvements to the Website, and display the content according to your preferences.  The personal information collected from Users through any Website Registration or Account form is used to manage each User’s account (such as replying to inquiries) and provide Users additional information about services that may be of interest to them. Random Walk Ventures does not share this information with third parties, unless specifically stated otherwise or in special circumstances. However, in instances where Random Walk Ventures and a partner jointly promote the Services, we may provide the partner certain personal information, such as the name, address, and username of persons who subscribed to the Services as a result of the joint promotion for the sole purpose of allowing Random Walk Ventures and the partner to assess the results of the promotion. In this instance, personal information may not be used by the partner for any other purpose. Random Walk Ventures may also generate non-identifying and aggregate profiles from personal information Users provide during registration (such as the total number, but not the names, of Users). As explained in more detail below, Random Walk Ventures may in certain instances use this aggregated and non-identifying information to sell advertisements that may appear on the website. may, though does not at this current time, collect and may retain certain financial information from you during an account registration process, or in connection with other Random Walk Ventures’ products and services offered on the Website. Random Walk Ventures will never sell, share or rent any financial information collected from you except as disclosed in this policy or as necessary to fulfill your order


Some products and services are offered to Visitors and Users in conjunction with a partner (e.g., for joint promotions, as described in paragraph 3 above). To provide Visitors and Users with some of these products and services, the partner may need to collect and maintain personal information. In these instances, Random Walk Ventures will provide such data collected or transferred to our Partners and Sponsors. Additionally, there may be an opportunity for Users to have co-branded pages that are co-sponsored by non-affiliated partners [though this is not in use at the time this Policy was enacted]. If or when partners or sponsors exist, Random Walk Ventures will share non-identifying and aggregate information (except as described above), but not personally identifiable information of individual Users, with such partners in order to administer the co-branded products or services offered.


At some web pages that you access through links on the Website, you may be able to purchase products and services or register to receive materials, such as a catalog or new product updates. In many cases, you may be asked to provide contact information, such as your name, address, e-mail address, phone number, and credit/debit card information. If you complete an order for any product or service that is not provided by Random Walk Ventures, we have no control over the third parties’ use of any personal information you provide when placing such an order and therefore Random Walk Ventures has no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat your personal information. Except as provided herein, Random Walk Ventures will not provide any of your personal information to these third parties without your express written consent. Random Walk Ventures may provide links to these web sites as a convenience to the User. Please exercise care when visiting linked web sites. The linked web sites have separate and independent privacy statements, notices and terms of use which we recommend you read carefully. At the time Random Walk Ventures enacted this Policy, you are only able to order a “Sole-Practitioner Professional” or “Sole-Practitioner Custom-Branded” software license directly from SPS, though you can also make a donation for a Personal Edition Software License”).  If in the future the ability to order other products directly from Random Walk Ventures is enacted, then we will use the personal information you provide only to process that order. Random Walk Ventures will not and does not share this information with outside parties except to the extent necessary to complete that order.


Random Walk Ventures does not share personally identifiable information about its individual Visitors or Users with advertisers. Random Walk Ventures may display online advertisements and may share aggregated and non-identifying information about its Visitors and Users collected through the ‘Contact Us’ or Forum-comment registration process, as well as through online surveys and promotions with these advertisers. Additionally, in some instances, Random Walk Ventures uses this aggregated and non-identifying information to deliver tailored advertisements. For example, an advertiser informs Random Walk Ventures the audience the advertiser wants to reach (for example, females between 25 and 55 years of age) and provides us an advertisement tailored to that audience. Based upon the aggregated and non-identifying information Random Walk Ventures collected, the Website may then display the advertisement to the intended audience.


If you do nothing during your visit but browse through the website, read pages, or download information, the Website will gather and store certain information about your visit automatically. This information does not identify you personally. Random Walk Ventures automatically collects and stores only the following information about your visit:
• The Internet domain of your Internet Service Provider (ISP) or institution you use to connect and access the Website (,,, etc.);
• Your IP address, which is a number that is automatically assigned to your computer whenever you are connected to the Internet;
• The type of browser and operating system used to access our site;
• The date and time you access the Website;
• The pages you visit;
• If you linked to the Website from another website, the URL address of that website.

For other uses, the Website may collect, store and use the following kinds of personal data:
a. Information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type, referral source, length of visit and number of page views);
b. Information relating to any transactions carried out between you and on or in relation to these websites, including information relating to any purchases you make of Random Walk Ventures’ goods or services;
c. Information that you provide to for the purpose of registering with the Website, primarily including your user registration necessary for posting comments on the Website Forum or as entered in any “Contact Us” page or form;
d. Information that you provide to us for the purpose of subscribing to Website services, email notifications and/or newsletters, if applicable; and
e. Any other information that you choose to send to Random Walk Ventures.

The Website uses embedded scripts. Scripts and other programming code used within the Website may collect non-personally identifiable information regarding use of the Website, such as web pages visited, for how long they are visited and which links are clicked. Random Walk Ventures may use this information for a number of purposes including, for example, to enhance or customize content served to users of the Website.

Author Information: Some articles may be published on the Website from time to time and these may include personally identifying information about its author(s). This information is used solely to provide Website Users and Visitors with a means to contact the author and also provide link-backs to the author(s) preferred web page. Authors who seek to have their articles published here are required to provide contact information.


A cookie consists of information sent by a web server to a web browser, and stored by the browser. The information is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser. Cookies help create a speedy web experience by remembering your address and email information, so you don’t have to re-type it when making multiple purchases. They also enable you to recall previous purchases.

Cookies do not store credit card information. may use cookies, web beacons, or similar technologies in combination with your Website information to enhance and personalize your experience on the Website. Random Walk Ventures may use both “session” cookies and “persistent” cookies on these websites. Random Walk Ventures will use the session cookies to keep track of you while you navigate the website and to determine generic interest and popularity among various documents and/or posts. Random Walk Ventures will use the persistent cookies to enable the Website to recognize you when you visit. Session cookies will be deleted from your computer when you close your browser. Persistent cookies will remain stored on your computer until deleted, or until a specified expiration date. and its advertisers may also use ad network providers to help present advertisements on the Website. These ad network providers use cookies, web beacons, or similar technologies on your computer to help present, better target, and measure the effectiveness of their advertisements, using data gathered over time and across their networks of sites to determine or predict the characteristics and preferences of their audience. Random Walk Ventures may share certain non-personally identifiable information about you as a user (such as user IP address and its related zip code) with certain ad network providers to help them deliver more relevant advertisements through their ad networks. The use of cookies, web beacons, or similar technologies by ad network providers is subject to their own privacy policies, not those detailed herein.

You can control cookies through your browser’s settings. Most browsers allow you to reject all cookies, while some browsers allow you to reject just third party cookies. For example, in Internet Explorer you can refuse all cookies by clicking “Tools”, “Internet Options,” “Privacy,” and selecting “Block all cookies” using the sliding selector. Blocking all cookies will, however, have a negative impact upon the usability of many websites, including some portions of this Random Walk Ventures’ Website. If you reject all cookies, you may not be able to take advantage of certain offerings. advertisers and/or its payment services providers may also send you cookies. may also use clear GIFs, or pixel tags, provided by third-party ad-serving companies to help manage its online advertising. These clear GIFs allow those ad-serving companies used by Random Walk Ventures to recognize a browser’s cookie when a browser visits the Website. This allows Random Walk Ventures to learn which banner or other promotional ads bring users from the Website to a particular advertiser. The information Random Walk Ventures collects and shares through this technology is not personally identifiable (it does not include your name, address, telephone number or e-mail address).

9.1 Google Adsense and the DoubleClick DART Cookies

Google, as a third party advertisement vendor, uses cookies to serve ads on the Random Walk Ventures’ Website. The use of DART cookies by Google enables them to serve adverts to visitors that are based on their visits to this website as well as other sites on the internet.

To opt out of the DART cookies you may visit the Google ad and content network privacy policy at the following URL: Tracking of users through the DART cookie mechanisms are subject to Google’s own privacy policies

9.2 Analytics

This Website may use Google, Piwik, or other web analytics service to analyze the use of this Website. These Analytics tools generate statistical and other information about Website use by means of cookies or similar technologies, which are or may be stored on visitor’s or user’s computers. The information generated relating to the Website is used to create reports about the use of the Website. Google and/or Piwik will store this information.  Google and/or Piwik may record mouse clicks, mouse movements, scrolling activity as well as any text you type in this website. Google and/or Piwik do not collect personally identifiable information that you do not voluntarily enter in this SPS website. Google and/or Piwik may track your browsing habits across websites which do not use Google and/or Piwik services. uses the information collected by Google and/or Piwik service to increase the usability and accessibility of this Website.

For additional information, please review the Google privacy policy, available at: and the Piwik privacy policy, here: may publish Google Adsense interest-based advertisements on the Website. These are tailored by Google to reflect your interests. To determine your interests, Google will track your behavior across the web using cookies. You can view, delete or add interest categories associated with your browser using Google’s Ads Preference Manager, available at: You can opt-out of the Adsense partner network cookie at: However, this opt-out mechanism uses a cookie, and if you clear the cookies from your browser your opt-out will not be maintained. To ensure that an opt-out is maintained in respect of a particular browser, you could use the Google browser plug-in available at:

To try and bring you offers that are of interest, Random Walk Ventures has or may have relationships with other companies such as Google Adsense (, Amazon Affiliates ( and maybe others in the future, whose ads Random Walk Ventures may place on this Website. As a result of your visit to this Website, these ad server companies, by means of placing cookies on your computer, may collect information such as your domain type, your IP address and your click-stream information. For example, Google’s use of the DART cookie enables it to serve ads to users based on their visit to a site and other sites on the Internet. You can check for further information on Google’s privacy policy, at, and Amazon’s privacy policy at


If You Send Random Walk Ventures E-Mail: You may choose to provide Random Walk Ventures with personal information, as in e-Mail with a comment or question. Random Walk Ventures uses the information to improve its services to you or to respond to your request.

Responses to E-Mail Inquiries: When Visitors or Users send e-mail inquiries to Random Walk Ventures, the return e-mail address (and other personal information provided in the inquiry) is used to answer the e-mail inquiry received. Random Walk Ventures does not use the return e-mail address for any other purpose and does not share the return e-mail address with any third party.

Unless you consent, Random Walk Ventures will not use your personal information for any purpose other than that for which it is submitted. Random Walk Ventures uses personal information to reply to inquiries, handle complaints, provide operational notices and in program record-keeping.

Except for authorized law enforcement investigations, Random Walk Ventures will never share e-mail information with any other outside organizations.


Personal data submitted on the Website will be used for the purposes specified in this Privacy Policy or in relevant parts of the website. may use your personal information to:
a. Administer the website;
b. Improve your browsing experience by personalizing the website;
c. Enable your use of the services available on the website;
d. Send to you goods purchased via the website, and supply to you services purchased via the website;
e. Send statements and invoices to you, and collect payments from you;
f. Send you general (non-marketing) commercial communications;
g. Send you email notifications which you have specifically requested;
h. Send to you a Random Walk Ventures’ newsletter, if or when such publication is made available, and other marketing communications relating to our business or the businesses of carefully-selected third parties which Random Walk Ventures believes may be of interest to you by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications);
i. Provide third parties with statistical information about Website users – but this information will not be used to identify any individual user; and
j. Deal with inquiries and complaints made by or about you relating to the website.

Where you submit personal information for publication on the Website, Random Walk Ventures will publish and otherwise use that information in accordance with the license you grant to Random Walk Ventures.

Random Walk Ventures will not, without your express written consent, provide your personal information to any third parties for the purpose of direct marketing.

Currently, the Website only accepts payments for licensing Random Walk Ventures’ software and/or services and does not act as a conduit of payment information to any of the Website advertisers.  Currently, all Website financial transactions are handled either through Random Walk Ventures’ payment services provider, PayPal. You should only provide your personal information to PayPal after reviewing the PayPal Privacy Policy. You can be assured that if or when Random Walk Ventures accepts payments directly through the Website (rather than continue to use a payment processor such as PayPal), Random Walk Ventures will share information with the chosen payment processor only to the extent necessary for the purposes of processing payments you make via the Website.


Random Walk Ventures may disclose information about you to any of Random Walk Ventures’ employees, officers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes as set out in this Privacy Policy.

In addition, Random Walk Ventures may disclose information about you:
a. To the extent that Random Walk Ventures is required to do so to comply with any valid legal process such as a search warrant, subpoena, statute or court order;
b. In connection with any legal proceedings or prospective legal proceedings;
c. In order to establish, exercise or defend the legal rights of Random Walk Ventures (including providing information to others for the purposes of fraud prevention and reducing credit risk); and
d. To the purchaser (or prospective purchaser) of any business or asset which Random Walk Ventures is (or may be contemplating) selling.

Further, personally identifying and entity identifying information may be disclosed to third parties in an effort to protect the rights of authorship or other proprietary rights, including rights arising under the Copyright Act. This may include, but is not limited to, any of the following:
a. Filing a complaint and other pleadings in a U.S. District Court or other court of proper jurisdiction in a suit alleging copyright infringement and other claims;
b. Filing a petition with the Copyright Office for revocation of a registration of a copyright, in the case of a registration of a work that constitutes or contains a work of authorship; and/or
c. Filing a complaint with an ethics panel of a State Board, an Inspector General or professional conduct office of a federal agency, or a Dean or academic integrity panel of a school or university.
d. Information concerning persons known to infringe on the intellectual property rights of others or make false claims of authorship may be shared with other electronic publishers.

Random Walk Ventures does not currently do this, nor are their plans to do so in the future. This may, however, be done at some time in the future, for the purpose of limiting loses due to infringement and other misuse of electronic products.

Except as provided in this Privacy Policy, Random Walk Ventures will not provide your information to third parties.


Random Walk Ventures intends to treat its customers fairly and to comply fully with all Federal Trade Commissions (FTC) regulations related to advertising. This includes, but is not limited to, Federal Trade Commission 16 CFR Part 255: Guides Concerning the Use of Endorsements and Testimonials in Advertising, which requires, among other criteria, the disclosure of material connections between advertisers and endorsers. This includes directories, review/rating sites, blogs/forums and other websites, email or collateral that purport to provide an endorsement or assessment of an advertiser, which Random Walk Ventures must prominently disclose the fact that financial or in-kind compensation is provided from the advertiser.  In addition to any per-page disclosures, please note that Random Walk Ventures participants in the advertising and/or affiliate programs designed to provide a means for this Website to earn advertising or referral fees by advertising and linking to visitors and users.

14.  VOLUNTARY CUSTOMER SURVEYS may periodically conduct both business and individual customer surveys. Random Walk Ventures encourages all Users to participate in these surveys because the surveys provide us with important information that helps us improve the types of services offered and how we provides those services to you. Your personal information and responses remain strictly confidential, even if the survey is conducted by a third party. Participation in any Random Walk Ventures customer survey is voluntary. Random Walk Ventures takes the information received from individuals responding to any Random Walk Ventures Customer Surveys and combines (or aggregates) it with the responses of other Website Users to create broader, generic responses to the survey questions (such as gender, age, residence, hobbies, education, employment, industry sector, or other demographic information). Random Walk Ventures intends to use the aggregated information to improve the quality of its services to you, and to develop new services and products. This aggregated, non-personally identifying information may be shared with third parties. Unless otherwise noted in the survey invitation or the survey itself, Users have the option of completing surveys anonymously or providing Random Walk Ventures with contact information. If provided, Random Walk Ventures may use the contact information to follow up with Users based on the answers they provide. Random Walk Ventures may also contact you to highlight any changes made in response to feedback.


Random Walk Ventures, through the Website, may transfer (or otherwise make available) your personal information to Random Walk Ventures’ affiliates and other third parties who provide services on its behalf. For example, as discussed above, Random Walk Ventures may use service providers to authorize and process payments, administer surveys, and run various promotions. Your personal information may be maintained and processed by these affiliates and other third party service providers in the United States or other jurisdictions. Random Walk Ventures service providers receive information they need to perform their designated functions, and we do not authorize its affiliates or third parties to use or disclose personal information for their own marketing or other purposes.


Random Walk Ventures may transfer your personal information as an asset in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Random Walk Ventures as part of a corporate reorganization or stock sale or other change in corporate control.

In the event that ownership of was to change as a result of a merger, acquisition or transfer to another company or clinic, your Random Walk Ventures Information may be transferred. If such a transfer results in a material change in the use of your Random Walk Ventures information, we will provide notice about the choices you have to decline to permit such a transfer of information.


Random Walk Ventures values its visitors and users, and therefore requires your permission before it provides your information to others. The only exceptions include: (a) when Random Walk Ventures is required by law; (b) in the good-faith belief that such action is necessary in order to conform to the law; or (c) Random Walk Ventures must comply with a legal process served on its website. Random Walk Ventures may also need to give out your information if one of its partners requires it, but these situations are rare and we will always ask for your explicit permission first.


Random Walk Ventures does not use or share the personal information about Visitors or Users in ways unrelated to the ones described herein without your consent. However, Random Walk Ventures, or its service providers, may disclose personal information about Visitors or Users, or information regarding your use of this Website or other websites accessible through this Website, for any reason, in its sole discretion to comply with United States, Canadian or other laws, such as the Electronic Communications Privacy Act, regulations, or governmental or legal requests or demands for such information; in response to a search warrant or other legally valid inquiry or order; to an investigative body in the case of a breach of an agreement or contravention of law; to disclose information that is necessary to identify, contact, or bring legal action against someone who, for example, may be violating these Website Terms or other policies; to operate this Website properly; to protect the Website and its Users; or as otherwise permitted or required by law.


Information that collects may be stored and processed in and transferred between any of the countries in which Random Walk Ventures operates in order to enable the Website to use the information in accordance with this Privacy Policy. The Website is operated in the United States and intended for residents of the United States. If you are located outside of the United States, be aware that Information Random Walk Ventures collects will be transferred to the United States. By using the Website, accessing the Website or providing your information to the Website, you consent to this data transfer.

Information which you provide may be transferred to other countries which do not have data protection laws equivalent to those in force in New Hampshire, California, or the United States in general.

In addition, personal information that you submit for publication on the Website will be published on the Internet and may be available, via the Internet, around the world.

You expressly agree to such transfers of personal information.

20.  RANDOM WALK VENTURES WEBSITE STATISTICS uses information gathered from its site statistics to help diagnose problems with Random Walk Ventures’ servers, and to administer the Website.  Random Walk Ventures may use IP addresses to analyze trends, administer the site, track user’s movement, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information. Random Walk Ventures also gathers broad demographic information from this data to help it improve the Website and make your browsing and purchasing experience more enjoyable.

21.  SAFE HARBOR PRIVACY PRINCIPLES abides by the provisions of the Safe Harbor privacy principles under the Safe Harbor Program, administered by the U. S. Department of Commerce, which is located at:

SPS commits to refer unresolved privacy complaints under the Safe Harbor Principles to an independent dispute resolution mechanism, the European Data Protection Authorities, operated by the United States Council for International Business. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Random Walk Ventures, you may contact:

US Council for International Business
1212 Avenue of the Americas
New York, New York 10036



The Website contains links to other websites. Random Walk Ventures may regularly create links to the web sites of other parties; Random Walk Ventures makes every effort to link only to sites that carry the same standards of maintaining privacy of users. These pages may, however, link to other sites that do not meet our requirements. Random Walk Ventures cannot be held responsible for any material on sites other than that on the Website, whether the Website links to them or is linked from them, or any links they may provide. Random Walk Ventures is not responsible for the privacy policies or practices of third party websites.

The appearance of hyperlinks does not constitute endorsement by Random Walk Ventures of the hyperlinked website(s) or the information, products or services contained therein. Random Walk Ventures does not exercise any editorial control over the information you may find at those hyperlinked locations. Such links are provided consistent with the stated purpose of the Website.

When you link to another site, you may no longer be on the Website and are subject to the privacy policy of the new/linked site.

Random Walk Ventures has no control over and is not responsible for the privacy policies or information gathering practices of other websites, including those to which the Website may link and those which may link to the Website. Random Walk Ventures strongly recommends that you review the privacy policies of every online service you use before submitting any personal information and direct any concerns to the site administrator of that site.

If you believe any of these existing external links are inappropriate, please let Random Walk Ventures know.


The Website is a general audience website. You must be at least eighteen (18) years old to register online or purchase goods or services made available through the Website. Random Walk Ventures does not knowingly collect information from children under the age of 18.

Protecting children’s privacy is especially important to Random Walk Ventures. Random Walk Ventures complies with the Children’s Online Privacy Protection Act of 1998 and all other applicable laws. While Random Walk Ventures makes every effort to ensure that this Website is not used by those under age 18, Random Walk Ventures believes that there is no substitute for proper parental supervision.

24.  THE RANDOM WALK VENTURES COMMITMENT TO DATA SECURITY implements measures designed to protect personal information in its custody and control. Random Walk Ventures maintains reasonable administrative, technical and physical safeguards in an effort to protect against unauthorized access, use, modification and disclosure of personal information in its custody and control. Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure, as it is inherently insecure. Nonetheless, Random Walk Ventures will take reasonable technical and organizational precautions to prevent the loss, misuse or alteration of your personal information.  As a result, while Random Walk Ventures strives to protect your personally identifiable information, you acknowledge that: (a) there are security and privacy limitations of the Internet which are beyond the control of Random Walk Ventures; (b) the security, integrity and privacy of any and all information and data exchanged between you and Random Walk Ventures through this Website cannot be guaranteed; and (c) any such information and data may be viewed or tampered with in transit by a third party, despite the best efforts of Random Walk Ventures.

While Random Walk Ventures strives to protect your information and privacy, we cannot guarantee the security of any Information you disclose or transmit to it online. Therefore, Random Walk Ventures is not responsible for the theft, destruction, or inadvertent disclosure of your information. In the unfortunate event that your “personally identifiable Information” (as the term or similar terms are defined by any applicable law requiring notice upon a security breach) is compromised, Random Walk Ventures may notify you by e-mail (at its sole and absolute discretion) to the last e-mail address you have provided within the Website pages in the most expedient time reasonable under the circumstances. Delays in notification may occur while Random Walk Ventures determines the scope of the breach and restores reasonable integrity to the system, as well as for the legitimate needs of law enforcement if notification would impede a criminal investigation. Random Walk Ventures may evaluate new technologies for protecting information, and if deemed appropriate, will upgrade its information security systems.

You are responsible for keeping your passwords and user details confidential. Random Walk Ventures personnel will not ask you for your password, whether by email or during a phone support call.

Your online access to certain personal information may be protected with a password you select. Random Walk Ventures strongly recommends that you do not disclose your password to anyone. Random Walk Ventures will never ask you for your password in any unsolicited communication (such as letters, phone calls or email messages).

Data related to the services will be maintained in the United States. Random Walk Ventures has personal information retention processes designed to retain personal information of its customers for no longer than necessary for the purposes stated above or to otherwise meet legal requirements.


You have the right to access, update, and correct inaccuracies in your personal information in the custody and control of, subject to certain exceptions prescribed by law. You may request access, updating and corrections of inaccuracies in your personal information has in its custody or control by accessing your personal profile in your account or by contacting support via any available contact method, which may include email, phone or online chat.  Random Walk Ventures may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records.

To ensure you receive the information you need to manage your account and protect your privacy, please be sure to keep your contact and billing information up to date. You can contact Customer Support by email or through its online support form, if any.


This Privacy Policy prohibits the release of customer or account information without express permission from the customer, except when required by law, to conform to the edicts of the law, or to comply with legal process properly served on Random Walk Ventures, LLC.  If you seek the identity or account information of a Random Walk Ventures’ customer in connection with a civil legal matter, you must serve Random Walk Ventures, LLC, with a valid subpoena. Similarly, if you seek the identity or account information of a Website Visitor or User in connection with a criminal matter, and are a member of the law enforcement community, you must comply with this same process.

Random Walk Ventures will respond to subpoenas, court orders, or other legal process, and will utilize website visitor and/or user information as necessary to establish or exercise Random Walk Ventures’ legal rights or defend against legal claims. Random Walk Ventures will charge the person or entity for submitting a civil subpoena for costs associated with subpoena compliance. Payment must be made within thirty (30) days from the date of receipt of the Random Walk Ventures invoice. Checks should be made out to Random Walk Ventures, LLC.  Random Walk Ventures’ subpoena compliance costs are as follows:
• Research – $150.00/hour;
• Federal Express – Cost as Billed;
• Copies – $1.00/page;
• Compact Discs – $10.00/per CD.

Random Walk Ventures will not produce the content of e-mail, as the Electronic Communications Privacy Act, 18 U.S.C. §2701 et seq., prohibits an electronic communications service provider from producing the contents of electronic communications, even pursuant to subpoena or court order, except in limited circumstances. Random Walk Ventures, LLC, web servers do not retain deleted or sent e-mail.  Random Walk Ventures reserves the right to request a copy of the complaint and any supporting documentation that demonstrates how the e-mail address is related to the pending investigation and the underlying subpoena.

Random Walk Ventures will share information to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations or suspected violations of this Policy, the Website Terms, the Software License Agreement, or as otherwise required by law.

When Random Walk Ventures is threatened with suit by a third party, or any other legal action brought to its attention involving Random Walk Ventures based on the anonymity of the a website visitor or user, a transaction or other matter, we may seek assurance from you, the visitor or user, concerning your promise to indemnify Random Walk Ventures and written notice that you have contacted the plaintiff or representative for the complainant and made your contact information available to them.


By choosing to visit the Website, you agree that your visit and any dispute you may have regarding the protection of your privacy during such visit is subject to this Privacy Policy and all other and/or Random Walk Ventures’ Policies, if any, including, but not limited to, the provisions regarding limitations on damages and the application of the law of the state of New Hampshire. Please note that if you enter into other agreements with Random Walk Ventures, such other agreements may supersede this policy. If you have any concerns about your privacy on the Website, please contact Random Walk Ventures Website Customer Support.

You may instruct Random Walk Ventures to provide you with any personal information we hold about you. Provision of such information may be subject to the payment of a fee, currently fixed at $135.00 (USD).

You may instruct Random Walk Ventures not to process your personal data for marketing purposes by email at any time. In practice, you will usually either expressly agree in advance to our use of your personal data for marketing purposes, or Random Walk Ventures may provide you with an opportunity to opt-out of the use of your personal data for marketing purposes.

If you have any questions about this Privacy Policy or the practices described herein, you may contact: Random Walk Ventures, Newfields, NH 03856;

28.  CHOICE/OPT-OUT may, though does not currently, automatically subscribe you to receive notices about your account, e-mail newsletters and news of special promotions offered through Random Walk Ventures and/or in conjunction with partners, when you become a User.

To unsubscribe from Random Walk Ventures newsletters and promotional mailings, if or when we deploy such mechanisms, this Policy will be updated to reflect the procedures for updating your preferences or you may send an e-mail to Random Walk Ventures, Website Customer Support.

In the event Random Walk Ventures deploys such mechanisms, you will be provided with the opportunity to opt out of receiving marketing and promotional communications from and its partners during the registration process.  Random Walk Ventures, its affiliates or partners may use the information associated with your account to contact you with any special offers.

Random Walk Ventures reserves the right to send e-mail communications relating directly to Website to Users that have posted any content to the SPS Website.

29.  POLICY AMENDMENTS and Random Walk Ventures reserve the right to revise, amend, or modify this policy, and any or all other policies and agreements at any time and in any manner. Random Walk Ventures may update this Privacy Policy from time-to-time by posting a new version on the Website.  Random Walk Ventures will post notice of revisions, amendments, or modifications in accordance with this and other posted Policies, such as, though not necessarily inclusive nor limited to, Terms of Use.  You should check this page occasionally to ensure you are happy with any changes. Random Walk Ventures may, in its sole discretion, also notify you of changes to this Privacy Policy by email.

30.  Miscellaneous Provisions.

a. Entire Agreement/Waiver.  This Privacy Policy sets forth the entire understanding and Agreement of the parties as to the subject matter hereof, and supersedes any and all prior representations, warranties, negotiations, agreements, and arrangements, and may be changed only by a written agreement published to this Random Walk Ventures’ Website.

b. Headings.  Headings are inserted for the convenience of the parties only and shall not be interpreted to modify the contractual language within each section.

c. No Assignment; No Waiver.  You may not assign this Agreement, by operation of law or otherwise, without the prior written consent of Random Walk Ventures.  Subject to that restriction, this Agreement will be binding on, inure to the benefit of, and be enforceable against the parties and their respective successors and assigns. Any failure by Random Walk Ventures to enforce your strict performance of any provision of this Agreement will not constitute a waiver of Random Walk Ventures’ right to subsequently enforce such a provision or any other provision of this Policy, the Terms of Use, the Software License or any other Agreement.

d. Severability.  If any provision of this Privacy Policy shall be held invalid, illegal or unenforceable in any jurisdiction, such provision shall be ineffective to the extent of such invalidity, illegality or unenforceability, the validity, legality or enforceability of the other provisions hereof shall not be affected thereby, and there shall be deemed substituted for the provision at issue a valid and enforceable provision as similar as possible to the provision at issue, all without affecting the validity, legality or enforceability of such provision in any other jurisdictions.

e. Interpretation.  The parties hereto acknowledge and agree that this Privacy Policy represents the product of negotiations conducted in good faith and at arms-length and that this Policy should not be interpreted in favor of or against any party because of such party’s ability or inability to control the drafting of this Policy.

f. Survival.  The provisions of this Privacy Policy which are intended to survive termination or are necessary to interpret the rights and obligations of the parties in connection with such termination, as well as all unpaid payment obligations, shall survive the execution of this Policy and remain binding on the parties in accordance with the terms of this Policy.


This Random Walk Ventures, LLC, Privacy Policy, as posted on the Website, is the sole statement of the Privacy Policy with respect to the Website. No summary, modification, restatement or other version thereof, or other statement or policy, in any form, is valid unless Random Walk Ventures posts a new or revised policy to the Website.  By using the Website, you explicitly acknowledge that you have read this Privacy Policy and agree to be bound by these terms. Some documents on the Website may only be accessible by verifying your assent to be bound by the terms of this Privacy Policy; bypassing these screens by any means, including but not limited to use of links saved in your “Favorites” list or via cache, explicitly conveys your acknowledgement and assent to be bound by this or other applicable Random Walk Ventures’ use-governing document.

Effective Date: December 30, 2013.