Rich Media Worldwide, LLC and its affiliates (collectively "Rich Media") has prepared this privacy notice ("Notice") to describe what information about you is collected and how that information may be used, disclosed and protected when a subscriber, end-user or V-pak recipient accesses or uses any of our services, or interacts with V-paks, via the Internet. This Notice does not apply to information that may be collected offline. Rich Media may revise or update this Notice from time to time; therefore you should revisit this page often for the latest information.

"Personally identifiable" information is information that is directly associated with a specific person such as a subscriber, end-user or V-pak recipient’s name, address, or IP-address, e-mail address, or information about online activities (e.g., log files of Web searching activities).

Rich Media recognizes that parents may purchase our services for family use, including for use by minors. Any information collected from such usage will appear to be that of the subscriber or end-user (the parent) and treated as such under this Notice. Further, in accordance with the Children's Online Privacy Protection Act and this Notice, Rich Media does not design or intend for its services to collect personally identifiable information from children under the age of 13. Specifically, through our services agreement, subscribers to our services undertake not to direct any V-paks at children under the age of 13. If our policies change in that regard, we will obtain verifiable parental consent before any collection, use or disclosure of such information. Remember that if a child under 13 uses our services with or without your permission to access a Web Site on the Internet, that Web Site's privacy policy (including treatment of information your child provides to that Web Site) will govern. We encourage parents to be involved in the online activities of their children to ensure that no information is collected from a child under 13 without parental permission.

Whenever a business entity subscribes to our services and provides such services to its employees, this Notice generally will govern how we treat the employees' personally identifiable information. However, we view the business entity as the subscriber and our service agreement with the business entity may require that we provide access to or disclose personally identifiable information about an employee's use of our services, such as service usage. In that case, the company's own privacy policy will govern how it treats that information.

Our definition of personally identifiable information does not include "aggregate" information. Aggregate information is data we collect about a group or category of services, subscribers or V-pak recipients from which individual identities have been removed. In other words, how you use our services or interact with V-paks may be collected and combined with information about how others use the same services or V-paks, but no personally identifiable information will be included in the resulting data. Aggregate data helps us understand trends as well as subscriber and V-pak recipients’ needs so that we can better consider new services or tailor existing services to subscriber desires.

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We collect "personally identifiable" information in a variety of ways:

Information You Give Us: We collect information you give us when you sign up for, use, or request information about our services or otherwise communicate with us through the Internet. For example, you provide us with your billing address and credit information when you sign up for the Rich Media System service or purchase a product or online content from us or the sender of a V-pak, or otherwise interact with a V-pak and any content contained therein.

Automatically Collected Information: We automatically receive certain types of information whenever you interact with our Web Site or any V-pak. For example, we obtain certain types of information when your Web browser accesses the Rich Media Web Site or any V-pak, including your IP address, the type of browser you use and the pages, information or links you visit on our Web Site or within a V-pak.

Information from Other Sources: We may receive information about you from other sources. For example, we receive credit information from third party sources before initiating service. We may also buy marketing information from others to help us better inform you about new services that we think will interest you. This Notice will apply to any such information we add to or combine with personally identifiable information otherwise covered by this Notice.

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In general, we use "personally identifiable" information for billing purposes, to market and provide services, to anticipate and resolve problems with your service, or to create and inform you of services that may better meet your needs. For example, by understanding how you use our Web Site or interact with a V-pak, we are able to customize and personalize your experience or we may be able to provide information we think will interest you or enable you to conduct transactions more easily.

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Rich Media is NOT in the business of selling personally identifiable information to others and we disclose "personally identifiable" information only in the following ways:

1. With Your Consent
We may obtain your consent to disclose personally identifiable in a number ways, including in writing; verbally; online by clicking a button; or at the time of initiation or use of any service when your consent is part of the required terms and conditions to use the service. Sometimes your consent is implicit. For example, if you subscribe to the Rich Media System through our Web Site, you implicitly consent to our disclosure of your name, address and your charge card number to the bank to collect payment.

2. Transaction Processing
We disclose personally identifiable information to third parties as necessary to complete a transaction or perform a service in our behalf. When the third party acts solely in our behalf, such as a billing service vendor, Rich Media will restrict their use and disclosure of personally identifiable information. That means that such third party, acting solely on our behalf, will not be permitted to disclose "personally identifiable" information to another third party without your consent. Our services and, specifically, V-paks, may let you take advantage of services and products offered by other companies. In those cases, information about you received by those third parties will be governed by their privacy policies. For example, if you interact with a V-pak and transfer to a third party’s Web Site, information about your activities on that Web Site may be available to the company that controls or owns the Web Site you visit. Or, when you purchase a product from a merchant through a V-pak, you may provide "personally identifiable" information to that entity and some information may automatically be passed to such entity’s Web Site, including source IP address or other information you may provide. Whenever third parties have a role in any such transaction, you should review their privacy policies as well.

3. Certain Business Transfers
Rich Media may go through or initiate mergers and acquisitions. In such transactions as well as in the event of insolvency, bankruptcy or receivership, "personally identifiable" customer information may be transferred as one of the business assets in the transaction.

4. Protection of Rich Media and Others
We release personally identifiable and other account information when we believe release is appropriate to comply with the law (e.g., a lawful subpoena); to enforce or apply our customer service agreements; to initiate, render, bill, and collect for services; or to protect our rights or property, or to protect Rich Media, its affiliates, other End Users or recipient of V-paks, as well as owners of intellectual property rights in any content of V-paks fraudulent, abusive, or unlawful use of, or subscription to, the Rich Media System or any V-paks.

5. Rich Media's Use of Cookies and Web bugs
Cookies are small text files placed on your hard drive by a Web Site when you visit. These files identify your computer and record your preferences and other data about your visit to that site so that when you return to the site, the site knows who you are and can personalize your visit. For example, cookies are what enable our log-on page to function so that you only have to log-on once. We may use cookies in general to collect information to determine how to improve our Web Site or any Web Site managed by us on behalf of or for our customers, by seeing which areas, features and products are most popular; to personalize such Web Site(s) and make recommendations based on preferences you have communicated in the past as well as to improve your Web Site experience; and to complete transactions you have requested. Advertisers, if any, that may serve ads on such Web Site(s) may also use their own cookies. Our subscribers may use cookie technology to measure the effectiveness of their V-paks. Unless managed or controlled by us, the use of such cookies is subject to such subscriber’s privacy policy, not the policy of Rich Media. Rich Media may ask these subscribers to report back information to us and in such a case, that information, if linked to personally identifiable information, will be treated as such and governed by this Notice. This Notice will be updated to provide you with more information should these practices be modified or changed in any material way.

As technology advances and cookies provide more functionality, we expect to utilize them in different offerings in different ways. As we do so, this Notice will be updated to provide you with more information.

You also may have heard about Web bugs, a small, graphic image on a Web page or in an E-mail message that is designed to monitor who is reading the Web page or E-mail message. Web bugs are often invisible to the user because they are typically very small (only 1-by-1 pixel) and the same color as the background of the Web page or E-mail message. Web bugs are represented as HTML IMG tags in the Web page; users should click on "view source " of the Web page to see whether the page is using a Web bug. Rich Media does not permit third parties to use Web bugs on its sites.

Through our subscriber services agreement we prohibit the use of our services for the purpose of sending “spam” and any form of spam or unsolicited bulk or mass E-mail messages, but we cannot at this time completely block or prevent such activities as initiated by our subscribers, although, pursuant to the terms of our subscriber services agreement, sending spam or unsolicited bulk or mass advertising is cause for immediate termination by us of the associated subscriber account(s). We continue to look for options to continue to reduce these unsolicited bulk or mass messages.

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Rich Media maintains physical, electronic, and procedural safeguards for information collected through the use of its Web Site or interaction with V-paks that meet with industry standards and any applicable federal regulations. For example, we use Secure Socket Layer (SSL) software, which encrypts information you input, to enable you to securely view your account information on our Web Site. You should be aware that we have no control over the security of other Web Sites on the Internet you visit, interact with, or from which you buy products or services. We limit access to personal information about you to those employees who need to know that information to provide services to you. An important part of protecting the security of personal information is your efforts to protect against unauthorized access to your Rich Media subscriber user name and password, and to your computer. Also, be sure to sign off when finished using a shared computer and always log out of any site when viewing personal account information.

Rich Media makes no representations or warranties about the security of your interaction with V-paks or that your use of our services or V-paks will be error-free, uninterrupted, or free of infection by viruses or other malicious codes or acts of third parties beyond our control.

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You may change your username, password, and certain other information at any time by selecting "Account Information " in your back office. You may also call an account representative for assistance.

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Rich Media may update this Notice in the future for a variety of reasons including, but not limited to, changes in technology or the introduction of new services. You should revisit this page often for the latest information.

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If you have any questions, comments or concerns about this Notice, please contact support@rmworldwide.com. You may also contact us with any other questions about your service or account by e-mail or through your customer service representative.

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Rich Media Worldwide, LLC – Privacy Policy October 2004 (version 1.0)