GRANDPARENTS.COM PRIVACY POLICY GRANDPARENTS.COM IS COMMITTED TO YOUR PRIVACY AND TO THE PRIVACY AND SAFETY OF CHILDREN. WE HAVE SPECIAL PROVISIONS DEALING WITH THE USE OF GRANDPARENTS.COM BY CHILDREN UNDER THE AGE OF 13. WE WILL NOT RENT, SELL OR SHARE YOUR PERSONAL INFORMATION WITH THIRD PARTIES WITHOUT YOUR PERMISSION. TO LEARN MORE ABOUT THE INFORMATION WE COLLECT AND USE, THE SECURITY OF YOUR INFORMATION AND HOW AND WHEN WE SHARE IT, PLEASE READ THE PRIVACY POLICY BELOW. PLEASE READ THE FOLLOWING PRIVACY POLICY RELATING TO YOUR USE OF THE GRANDPARENTS.COM WEBSITE CAREFULLY AS THEY GOVERN YOUR USE OF THE SITE AND ALL SERVICES OFFERED THROUGH THE SITE. To read information published by the Federal Trade Commission dealing with online safety, visit their site. This policy covers how Grandparents.com treats personal information that we collect and receive, including information related to your past use of our products and services. Personal information is information about you that is personally identifiable such as your name, address, email address, or phone number, and that is not otherwise publicly available. Information Collection and Use Grandparents.com collects personal information when you register with Grandparents.com, when you use the site and services offered on the site, when you visit pages on the site or the pages of certain partners, and when you enter promotions or sweepstakes. Grandparents.com may also combine information about you that we have with information we obtain from business partners or other companies. Grandparents.com uses such information for the following general purposes: to customize the advertising and content you see, fulfill your requests for products and services, improve our services, contact you, conduct research, and provide anonymous reporting for internal and external clients. When you register we ask for information such as your name, email address, birth date, gender, ZIP code and number of grandchildren. When you register with Grandparents.com and sign in to our services, you are not anonymous to us. Grandparents.com collects information about your transactions with us and with some of our business partners, including information about your use of the products and services that we offer. Grandparents.com automatically receives and records information on our server logs from your browser, including your IP address, Grandparents.com cookie information, and the pages you request. Special Provisions for Children Under 13 Children under 13 are not permitted to register for accounts with Grandparents.com. However, registered users over 13 may invite persons under 13 to participate on the Site on moderated blogs. When an invited user identifies himself or herself as under 13, Grandparents.com will monitor all of his or her postings for personally identifying information before they are posted publicly. Any posting containing personal information will be removed and deleted prior to it being posted publicly. Grandparents.com will not maintain any record of such personal information. As such, Grandparents.com neither collects nor posts personally identifying information about children under 13. Moreover, Grandparents.com will not contact them for marketing purposes. Visitors can post to user guest books. Grandparents.com does not knowingly collect PII in this form filled box from children under the age of 13. Information Sharing & Disclosure Grandparents.com does not rent, sell, or share personal information about you with other people or nonaffiliated companies except to provide products or services you request, when we have your permission, or under the following circumstances: We provide the information to trusted partners who work on behalf of Grandparents.com under confidentiality agreements to provide services in support of the site. These companies may use your personal information to help Grandparents.com communicate with you about offers from Grandparents.com. However, these companies do not have any independent right to use or share this information. We may sometimes share aggregate non-personal information with third parties about how our users utilize the site and services. This aggregate information is typically in the form of statistics, such as numbers of Grandparents.com users who live in a particular state or fall within a particular age group. Such aggregate information is gathered from individual Grandparents.com users’ information but is not traceable to any specific identifiable Grandparents.com user. Grandparents.com may share personal information with third parties to the extent required to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. Grandparents.com may also share personal information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of the Grandparents.com Terms of Service, or as otherwise required or permitted by law. If Grandparents.com is acquired by or merged with or into another company, we will provide notice before personal information is transferred and becomes subject to a different privacy policy. You will be notified when your personal information is collected by any third party that is not our agent/service provider, so you can make an informed choice as to whether or not to share your information with that party. Use of Personal Information with Tell-A-Friend Features If you choose to use our referral service to tell a friend about our site, we will ask you for your friend’s name and email address. We will automatically send your friend a one-time email inviting him or her to visit the site. Grandparents.com does not store this information . It is used for the sole purpose of sending this one-time email [and tracking the success of our referral program]. Your friend may contact us at admin@grandparents.com to request that we remove this information from our database. Use of Personal Information with Marketing Partners and Promotions In instances where Grandparents.com and a marketing partner are offering a special value (i.e. a free gift) to our users, we may share your personal information with such partners. By signing up to receive items through these promotions, you are expressly consenting to Grandparents.com sharing your personal information with such partners and you will become subject to their privacy policies, which may vary from those of Grandparents.com. In the event that you would like to opt-out of receiving offers from these partners, you must do so directly with them. If you have any problems contacting one of our partners, e-mail us at admin@grandparents.com and we will help you resolve the situation. Newsletters If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you. Out of respect for your privacy, we provide you a way to unsubscribe. To unsubscribe, please see the “Choice and Opt-out” section immediately below. Newsletter - Choice/Opt-out If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by following the instructions included in each newsletter or communication or by emailing us at admin@grandparents.com. We also offer an opportunity to opt-out of certain communications on our Account Settings. Use of Personal Information Posted on Blogs and Forums If you use the forum or blog on this Web site, you should be aware that any personally identifiable information you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit in these forums. Cookies Grandparents.com, like many web sites, uses cookies to prepare customized web pages for you. A cookie is a file containing a string of code that we transfer to your computer’s hard drive, to be kept there for later use. With cookies in place, whenever you use your web browser (such as Internet Explorer or Mozilla Firefox) to connect to Grandparents.com, our systems are able to recognize you. This enables Grandparents.com to present you with custom web pages. For example, instead of seeing a generic welcome page, you might see a welcome page with your name on it and information about products or services that reflect your interests. You can set up your browser to reject cookies or tell you when a cookie has been sent. However, cookies allow you to take full advantage of Grandparents.com interactive features, and we hope you will leave them turned on. In addition to our cookies, Grandparents.com may allow third parties that show advertisements on our site and set and access their own cookies on your computer. The cookies inserted by those third parties are not covered by Grandparents.com Privacy Policy, but rather, by the policies of those third parties. However, these third parties do not have access to Grandparents.com cookies. Grandparents.com also uses web beacons (also known as action tags or single pixel gifs) to allow us to count how many people have visited a certain page. This enables us to assess the popularity and effectiveness of the material posted on the Grandparents.com web site. Additionally, we sometimes use web beacons to access Grandparents.com cookies inside and outside our Web pages and in connection with Grandparents.com products and services. A web beacon is a transparent image placed on a web page that sends a signal when a person visits that page. This enables us to assess the popularity and effectiveness of the material posted on the Grandparents.com web site. We may also use web beacons in connection with e-mails sent to Grandparents.com users to let us know whether and when the e-mail was opened. We do link the information we store in cookies to any personally identifiable information you submit while on our site. Third Party Ad Serving We send to your web browser many of the advertisements you see when you use our network of Web sites. However, we also allow other companies, called third-party ad servers or ad networks, to serve advertisements within our web pages. Because your web browser must request these advertising banners from the ad network Web site, these companies can send their own cookies to your cookie file, just as if you had requested a web page from the site. Please note that if an advertiser asks us to show an advertisement to a certain audience (for example, women ages 50-69) or audience segment (for example, women ages 50-69 with 2 or more grandchildren) and you respond to that ad, the advertiser or ad-server may conclude that you fit the description of the audience they are trying to reach. As always remember, we only authorize our third-party ad servers to employ anonymous cookies for ad delivery and anonymous targeting. Our third-party ad servers do not collect, nor do we give them access, to any personally identifying information about you. We also use a third-party ad servers to serve ads on our behalf across the Internet. They may collect anonymous information about your visits to Grandparents.com, and your interaction with our products and services. They may also use information about your visits to this and other Web sites to target advertisements for goods and services. This anonymous information is collected through the use of a pixel tag, which is industry standard technology used by most major web sites. If you would like more information about this practice and to know your choices about not having this anonymous information used by our third party service provider, please click here. Opting Out of Third-Party Ad Servers If you want to prevent a third-party ad server from sending and reading cookies on your computer, you must visit each ad network's Web site individually and opt out. Currently, we have relationships with the following third-party ad networks (click to visit their Web site): 24/7 Real Media, Inc and aCerno. DART Spotlight Tags Grandparents.com uses pixels, or transparent GIF files, to help manage online advertising. These GIF files are provided by our ad management partner, DoubleClick. These files enable DoubleClick to recognize a unique cookie on your Web browser, which in turn enables us to learn which advertisements bring users to our website. The cookie was placed by us, or by another advertiser who works with DoubleClick. With both cookies and Spotlight technology, the information that we collect and share is anonymous and not personally identifiable. It does not contain your name, address, telephone number, or email address. For more information about DoubleClick, including information about how to opt out of these technologies, go to DoubleClick. Editing and/or Deleting Account Information & Preferences You can edit the information contained in your account at any time by clicking on MY ACCOUNT after logging on to Grandparents.com. You can delete your Grandparents.com account by visiting the ACCOUNT SETTINGS page within your account. Although you account will be deactivated immediately, information provided to us while you were a registered user may remain in back-up storage on our servers indefinitely. Nevertheless, once you delete your account, this information will be inaccessible to the public. Confidentiality and Security Grandparents.com limits access to personal information about you to employees who we believe reasonably need such information to provide products or services to you or in order to do their jobs. In addition, Grandparents.com maintains physical, electronic, and procedural safeguards that comply with federal regulations to protect personal information about you. Although Grandparents.com takes your privacy seriously and will take reasonable and customary measures to protect it, we cannot guarantee that there will be no unauthorized use of your personal information. If you register for the site and services and create a User Account, you will be provided a username and password for such User Account. You acknowledge that you are responsible for maintaining the confidentiality of the password as well as any and all activity that occur under your User Account and password. You agree that at the end of each session using the Site and Services, you will exit your User Account. In the event of any unauthorized use of your password and/or User Account, you agree that you will immediately notify Grandparents.com by sending an e-mail to security@grandparents.com. Grandparents.com cannot and will not be liable for any and all losses or damages arising from your failure to comply with this Section. Third Party Web Sites From time to time, Grandparents.com may make available to you certain services offered by third parties or may include links to sites operated and controlled by third parties. Those third party services and sites are not governed by this Privacy Policy. Users who choose to visit those third party sites are advised to review their privacy policies. Access to Personal Information If at any time you would like to review the personal information we collect about you, just ask. You should send an e-mail to privacy@grandparents.com from the e-mail account you used to create your account and we will provide you with a summary, as well as an opportunity to correct and update this information. TRUSTe Children’s Online Privacy Seal Program Grandparents.com is a licensee of the TRUSTe Children’s Online Privacy Seal Program. TRUSTe is an independent, non-profit organization whose mission is to build user’s trust and confidence in the Internet by promoting the use of fair information practices. This privacy statement covers the site Grandparents.com . Because this Web site wants to demonstrate its commitment to your privacy, it has agreed to disclose its information practices and have its privacy practices reviewed for compliance by TRUSTe. If you have questions or concerns regarding this statement, you should first contact Grandparents.com’s Director of Community at privacy@grandparents.com. If you do not receive acknowledgement of your inquiry or your inquiry has not been satisfactorily addressed, you should contact TRUSTe at this URL. TRUSTe will then serve as a liaison with us to resolve your concerns. Changes to this Privacy Policy This Privacy Policy may be changed from time to time. We will notify you about significant changes by sending a notice to the primary email address specified in your Grandparents.com account or by placing a prominent notice on our site. If we decide to change our privacy policy, we will post those changes to this privacy statement, the homepage, 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. We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to how we use Personal Information collected from children under age 13, we will notify parents by email in order to obtain verifiable parental consent for the new uses of the child’s Personal Information. Comments If you have questions or suggestions, please complete the form on our Suggestion page, send an e-mail to privacy@grandparents.com or write us at: Grandparents.com, LLC. Customer Care – Privacy Policy 24 Union Square East, 5TH Floor New York, NY 10003 Last updated April 24, 2008