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Privacy Policy for Kargo Services and Web Sites

Thank you for using our service (the "Service") or visiting our web site ("Web Site"). The following policies, terms and conditions apply to all services and websites (including mobile websites) owned and/or operated by Kargo Global, Inc. and its affiliates (collectively "Kargo")

PLEASE READ THIS PRIVACY POLICY AND THESE TERMS OF SERVICE CAREFULLY BEFORE USING THIS SERVICE OR WEB SITE. BY USING THIS SERVICE, VISITING THIS WEB SITE, OR DOWNLOADING THIS APPLICATION YOU AGREE TO THESE TERMS AND CONDITIONS. IF YOU DO NOT AGREE, PLEASE DO NOT USE THIS SERVICE, WEB SITE OR APPLICATION.

Privacy Policy

Your privacy is important to us and we provide this notice to explain our information practices and the choices you can make about the collection and use of the personal information you submit to us. In providing our products and services, we endeavor to comply with the industry standards established by the Mobile Marketing Association and set forth at www.mmaglobal.com

If you are using our service or visiting our site from outside the United States, please be advised that because we operate internationally, and certain of our computer systems are currently based in the United States, your personal data will be processed by us in the U.S. where data protection and privacy regulations may not offer the same level of protection as in other parts of the world, such as the European Union. By using the Web Site, you (I) consent to Kargo's Privacy Policy and Terms of Service, and (ii) consent to any such transfer of information outside of your country, and you also consent to Kargo using your personal information to contact you electronically, in writing, or otherwise to provide notices relating to your use of Kargo services and web sites and to give you information about the products and services offered by Kargo, its business partners and their respective affiliates.

1. Visitors

We may collect certain non-personally identifiable information when you complete a transaction, use our services, download our applications or visit many of our web pages or those of certain partners. Like most web sites, we use server log files. These files contain information such as Internet Protocol (IP) addresses, browser types, Internet Service Provider (ISP), referring/exit pages, platform types, date/time stamps, the number of clicks to analyze trends, administer the site, track the user's movement in the aggregate, and gather broad demographic information for aggregate use, such as Individual IP addresses, device type, carrier, subscriber I.D. and the international mobile equipment identity number ("IMEI"). Such information is not linked to any personally identifiable information.

2. Web Site Customers

• In order to purchase products or services from Kargo, use certain parts of the Service or download an application we require that you provide us with certain personally identifiable information ("PII"). The types of PII that may be collected at this site include without limitation: name, address, e-mail address, mobile phone number and MSISDN (mobile station integrated services digital network number), geographic location information, credit card and billing information, download history, gender, age and demographic information, and customer generated content and/or information about your interests in and use of various products, programs, and services. We may combine PII and other information about you that we have with information we obtain from our business partners or third party data providers.

We may collect PII under the following circumstances:

• When you choose to register with Kargo and our network of products and services.
• When you sign up to receive one of our SMS alert messages or with our partners and we ask you to register with us.
• When you use Kargo products and services, even if you do not register or IP address.
• When you send messages sent to Publisher/Network short codes.
• If you enter one of our partner's sweepstakes and we ask for PII so that we may contact you in the event that you win the sweepstakes.
• When you choose to send us PII about yourself in an email or by completing an online form. We use this information only to contact you to respond to your inquiry or to fulfill your request.
• When you provide such information on a public forum. From time to time Kargo may make chat rooms, forums, message boards, news groups and other interactive services available to its users. Please remember that any information that is disclosed in these areas becomes public information and you should exercise caution when deciding to disclose your personal information.
• When you download an application.
• When you process a transaction to use a Service or contact customer service.
• When you 'check-in' to a Kargo site or are asked to provide this information for polls, questionnaires or other game like functions that are part of the Service and where you are prompted to enter such information.

Once collected, we will store your PII for a reasonable time for record keeping purposes. The information that we store is usually deleted as space requires or in the normal course of business. If you wish to request that we remove your information from our systems and no longer provide you services you may contact us at info@kargo.com. As permitted by applicable law, we may merge PII with public information or other information received from reputable vendors to update contact information or to enhance demographic profiles.

3. What does Kargo do with Collected Information?

Kargo's primary goal in collecting personal information is to provide each user with a customized experience. This includes personalization services, interactive communications, and many other services. In order to provide some services free of charge, we display advertisements. By knowing a little about users, Kargo is able to deliver more relevant advertisements and content, and hence better service, to our users.

Therefore, we may use such personally identifiable information to provide the information or content you have requested (e.g., fulfill your orders for downloadable content, games, data and news or access the social capabilities of the site), to contact you about programs, products, features or services in which we believe you may be interested (such as future promotional materials), to customize the advertising and content that you see, or for other purposes disclosed from time to time. We also may use your PII to contact you regarding your use of our services or Web Site or changes to our Privacy Policy, Terms of Service, or other policies or terms that affect you and your use of our Service or Web Site, or to conduct research by sending you a survey. In addition, we may use information collected about our users to improve the content and navigation of our Service or Web Site, help target certain advertisements or content by location, gender or other demographic information, or for other internal purposes.

Kargo may disclose users' PII to third parties (i) when we have their consent (through an "opt in"), in which case their use of a user's information is subject to such third party's own privacy policy; (ii) when users use co-branded services on Kargo Web Sites and provide any personally identifiable information to any of our third party co-branded business partners; (iii) when we have retained or contracted with service providers or other companies to work with or on behalf of Kargo to provide products, goods or services, including without limitation fulfilling orders, providing customer service or marketing assistance, performing business and sales analysis, member screenings, site data computation and support for website functionality, better content offers and enhanced features available through Kargo Web Sites; (iv) if required to do so by law or in the good faith belief that such action is necessary to comply with a legal process served on Kargo or its affiliates, subsidiaries or affiliate by a governmental agency, court or other entity (e.g., to respond to subpoenas, court orders or other legal process); (v) if we believe a user's actions violate any law, regulation, our "Terms of Service" or any of our guidelines for promotions, product offerings or any other features of Kargo, or if a user threatens the rights, property or safety of Kargo, its advertisers, other users, themselves or any other party; (vi) as and when we, in our sole discretion, and in the good-faith belief believe that such disclosure is necessary or appropriate to investigate or resolve possible problems or inquiries, to protect our business and assets, to defend our interests, rights or property and/or to comply with our legal and regulatory obligations; or (vii) in the event of a bankruptcy, or a merger, acquisition, joint venture or other business combination involving Kargo.

Kargo may from time to time display targeted advertisements based on personal information on its web site(s), apps or via your mobile device. Advertisers (including ad serving companies) may assume that people who interact with, view, or click targeted ads meet the targeting criteria-for example, men aged 18-24 from a specific geographic area. Kargo does not provide any personal information to the advertiser when you interact with or view a targeted ad. By your voluntary use of our site you are consenting to the possibility that the advertiser will assume that you meet the targeting criteria used to display the ad. These third party advertising companies may collect information about your visits to our Website, such as number of times you have viewed an ad and where geographically the ad is served (but not your name, address, or other personal information). These companies may also use that information to serve ads about goods and services that may be of interest to you based upon aggregated demographic and location data. If you would like more information about this practice and to know your choices about not having this information used by these companies, click here.

Kargo may from time to time ask you to provide geographic location information. By voluntarily providing such information, you consent to its use in interactive forums, polls and elsewhere. Additionally, Kargo may obtain geographic location information via programming interfaces supplied by your mobile device service provider and may utilize it in the aforementioned ways. Such information may also be used for targeted advertising purposes, as described in the preceding paragraph.

Our privacy policy does not cover use of information by your mobile device service provider or its partner and subcontractor companies. To learn more about your provider's privacy practices, you should consult its privacy policy. Except as described in this Privacy Statement, Information gathered by Kargo is not presently used to compile mailing lists for solicitations from unaffiliated third parties, and is not presently shared with other companies for these purposes.

We may also disclose anonymous, aggregated user statistics to third parties for a variety of purposes. For example, we may disclose how many individuals visited certain areas of our Web Site or purchased a particular type of product.

4. Children and Age Restrictions

Children under age 13 are currently not permitted to register for the Services or web sites. In the case of certain services that may be appropriate for children, we will require express parental permission for individuals between the ages of 13 and 17. Kargo will not contact children under age 13 about special offers or for marketing purposes without a parent's permission, and Kargo will only ask children under age 13 for personal information that is reasonably necessary to permit the child to participate in a particular service, activity or promotion. Otherwise, Kargo will not knowingly collect personal information from children under the age of 13, without the express consent of a parent or guardian. Parents and/or guardians should understand that Kargo has no way to determine whether or not a child is using a mobile device purchased or registered by an adult or a service purchased using an adult's credit card. Kargo is not responsible for the consequences of such use. Users must be at 18 years of age to register for a Kargo subscription service or to order any other product or service that requires payment of a fee. By providing your billing information, you represent to Kargo that you are 18 years of age or older.

5. Your Privacy Rights and Right to Opt Out

Users can prevent future disclosures of their personally identifiable information, at no charge, by exercising their "opt out" rights using the "opt out" procedures described below:

1. You can send email to: info@kargo.com or
2. You can send mail to the following postal address:
Kargo Global, Inc.
36 East 12th Street, 6th Floor
New York, NY 10003
Attn: COO
Kargo's "opt out" policy is intended fully to comply with Section 1798.83 (c)(2) of the California Civil Code. California residents should click here for an explanation of their California Privacy Rights.

6. Cookies

We use the standard "cookie" feature of major browser applications to allow us to store data about your visit (such data is stored in the aggregate form). Cookies help us learn which areas of our site are useful and which areas need improvement. We may use cookies in a number of ways, including keeping track of user return visits to Kargo Web Sites or our advertisers' or business partners' websites; accumulating and reporting aggregate, statistical information in connection with Kargo Web Sites user visits; and to deliver to our users content specific to their interests; to save Users ID, passwords, subscriber I.D. and IMEI or other information. Advertisements displayed on Kargo Web Sites, and links to other websites may also contain cookies. We may also use third parties to display or serve advertising on sites Kargo manages and to distribute emails or newsletters. These third party companies may employ cookie and other technologies to measure advertising effectiveness. You should be aware that different rules may apply to the collection, or use of the personally identifiable information you disclose to these third parties.

Cookies, by themselves, do not tell us your e-mail address or other personally identifiable information unless you choose to provide this information to us by, for example, registering on the Service. However, once you become a Customer and furnish the site with personally identifiable information, this information may be linked to the data stored in the cookie using your subscriber identifying information or by other means.

You may adjust your browser to reject cookies from us or from any other Web Site. Please consult the "Help" section of your browser for more information. However, certain areas of our site can be accessed only in conjunction with cookies or similar devices and you should be aware that disabling cookies or similar devices might prevent you from accessing some of our content.

7. Data Security

We have put in place certain physical, electronic, and managerial procedures to help prevent unauthorized access and maintain data security, such as use of firewalls and encryption. However, due to the open nature of Internet communications, we cannot guarantee that communications between you and us will be free from unauthorized access by third parties. Visitors to the Web Site and Customers use our services and web sites at their own risk.

8. Changes to Privacy Policy

We may, from time to time, update this privacy notice and such changes shall be effectively immediately and without further notice to you.

Questions/Concerns?

If you have any questions, comments, or concerns regarding our privacy policy, please contact us at: info@kargo.com

9. Effective Date

This notice was updated on or about June 1, 2012.

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