PRIVACY

Massive Incorporated is firmly committed to protecting the privacy of game players and fostering confidence in online gaming and in-game advertising. We continue to focus on innovative ways to protect game player privacy while also offering game developers and publishers the ability to use data regarding online interactions with their game players. Please note that because of the changing nature of privacy laws, our business and game players’ needs, we may modify this Privacy Policy from time to time without specific notice. Accordingly, since we want to help you clearly understand our Privacy Policy, and any revisions to our Privacy Policy, we encourage you to review our Privacy Policy periodically to become aware of any changes that may have occurred. We also invite you to contact us with any questions or concerns.

The purpose of this privacy policy is to inform you of what kinds of information we may gather from game activity powered by Massive Incorporated in-game advertising services, how we may use that information, when information may be disclosed to anyone, and the choices you may have regarding whether and how we gather and use information related to you. While this Privacy Policy applies to the global operations of Massive Incorporated, including our operations in Europe, the information we collect is stored and processed in the United States and we will refer here only to Massive Incorporated to make reading this Privacy Policy easier. Finally, please note that this Privacy Policy applies only to Massive Incorporated and, as specifically stated, games that use Massive Incorporated technology and services, and not to any other companies or organizations.

Four important points underlie our privacy policy:

1. We do not collect personally identifiable information ("PII").
PII generally includes information that Massive or other third parties could use to determine the identity of a game player, such as name, address, phone number, or email address. We currently do not collect PII when we deliver in-game advertisements. However, as stated below, we do not have the ability to prevent our game publisher or developer partners, or game console manufacturers, from collecting PII about game players. Accordingly, we encourage you always to read the privacy policies and end-user license agreements associated with the games you play, and the game consoles you purchase, to understand issues relating to your online privacy.

2. We do not currently utilize cookies to deliver in-game advertising and we do not place persistent data or install persistent tracking mechanisms on game players’ computers.

3. We require that our game publisher and developer partners, as well as console manufacturers, promise to comply with applicable law and we encourage them to engage in fair information practices.

We request that our partners acknowledge and comply with applicable law including laws relating to online privacy. We also encourage our partners to create privacy policies and to provide game players with access to their privacy policies through end-user license agreements. Although we cannot monitor every in-game interaction tracked by each of our many game publisher and developer partners and match it to each respective partner's privacy policy, we may monitor our partner’s privacy policies to determine whether we believe they have complied with their obligations under applicable privacy laws.

4. We strive to keep promises we make about information we gather online.

We may change our privacy policy as we add new services or change existing services, but we endeavor to treat information we possess (including information collected from our corporate Web site) in a manner consistent with the policy under which it was collected.

If part or all of our assets or business operations are acquired or otherwise transferred, we will take steps to ensure that these same principles continue to apply to the acquiring company, but cannot guarantee the policy or practice of any third party.

WHAT INFORMATION ABOUT GAMING ACTIVITY DO WE COLLECT?

We may collect non-personally identifiable information ("Non-PII") to help our partners better determine which advertisements or content to show or not to show game players, and for the other uses described in this Privacy Policy. Non-PII may include the following:

1. Internet Protocol (“IP”) Address. We collect IP addresses when game players play video games that connect to our servers. Many IP Addresses are commonly associated with Internet service providers, universities, or major corporations in specific regions or localities and cannot be used to identify a particular game player.

2. Length of Game Session. We collect the start time and stop time of game sessions.

3. Game Title. We collect the titles of video games that connect to our servers.

4. Advertising Delivered. We collect basic information about advertisements that we deliver to video games that connect to our servers as well as aggregate metrics associated with how advertisements are rendered (i.e. time and size on screen).

In addition, we may collect anonymous data, and in some cases, player registration data that we use to categorize a specific computer or gaming platform. We often convert this data into a non-reversible unique number to count unique players, somewhat like an indicator noting, "This game platform connected to the Massive Ad server at this time." It also tells us that a game player’s game platform has viewed an advertisement at a specific time and how many times an advertisement was seen. When our game publisher partners contract with us to deliver ads on their behalf, we assign a unique number to every game platform that connects to our ad servers. We do not associate the unique game platform data with, and we do not have access to, a game player’s name, address, phone number, email address or other PII.

WHAT DATA IS COLLECTED ON THE MASSIVE INCORPORATED CORPORATE WEB SITE?

You may be asked to provide PII in certain fields on this Web site to better help our staff respond to your inquiries. We use PII collected on this site only for the purpose for which it is requested, and will not be processed in a way that is incompatible with that purpose.
In order to respond to your inquiries we may request that you voluntarily provide the following information through our Web site:

1. Contact information for potential partners or persons seeking business information may be collected by us in order to contact that person to provide information about our services. Such information is usually deleted as space requires or in the normal course of business, but can be amended or deleted upon request.

2. Contact information, such as your name, address, telephone number or email address, for consumers, investors or partners with questions, concerns, complaints, inquiries, requests for information or technical support questions, may be used to respond to your request for information. Such information is usually deleted as space requires or in the normal course of business, but can be amended or deleted upon request.

Contact us to review, amend or delete your any information you have provided us through our Web site.

From time to time, we may use cookies or web beacons on our Web site, but not in connection with the in-game advertising services we deliver, to help us better understand how users interact with our Web site and to help us build a better Web presence. We do not use cookies and web beacons to collect any PII about our users.

WITH WHOM DO WE SHARE COLLECTED INFORMATION?

We may share information collected from video games that connect to our servers with our advertisers and game publisher partners only in accordance with these privacy policies. We may also share aggregate information about our systems with our auditors and providers of technology or services upon which we rely to deliver our services. Other than with respect to information specific to an advertiser or game publisher, we do not collect or sell the ownership of PII or Non-PII for our own commercial purposes. From time to time, we may publish or report aggregate statistics related to our business. When we report or publish such statistics, we do not include or reveal any information specific to game players.

The anonymous information that we collect on behalf of our advertiser and game publisher and developer partners is useful only to the specific partner who employs us to deliver advertising, and generally only in the context of our selection of advertising content, reporting of advertising effectiveness and billing. In order to assess an advertising campaign's effectiveness, our partners may hire us to report to them our analysis of the anonymous data in a summarized format. On occasion, our partners ask us to share with them, or their agents, data that is collected through specific video games. In these situations, we share only anonymous data. We recommend that you review the privacy policies and end-user license agreements associated with the video games you play online and contact game publishers and/or game developers directly if you have questions about their information practices. Some of our partners, or their agents, might receive anonymous information relating to game play from us. Our partners typically warrant that the information they receive shall be used in compliance with applicable laws. We may also disclose certain information in response to subpoenas, court orders or legal process.

We do not have the ability to prevent our game publisher or developer partners, or game console manufacturers, from collecting PII about game players. They may do this, without our knowledge, through games and consoles that are enabled with Internet connectivity. Accordingly, we encourage you always to read the privacy policies and end-user license agreements associated with the games you play, and the game consoles you purchase, to understand issues relating to your online privacy when using these products.

If all or part of our company is acquired or otherwise transferred to another entity, any PII you have provided at this Web site may be transferred as part of that transaction. We will take steps to assure that such PII, if any, is used in a manner consistent with the privacy policy under which it was collected, but cannot guarantee the policies or practices of third parties. Please note that PII provided to us in connection with this Web site is subject to disclosure pursuant to judicial or other government subpoenas, warrants or orders. We may purge from our databases any information (whether PII or Non-PII) about users of our Web site without notice to any user. Contact us to review, amend or delete your any information you have provided us through our Web site.

WHAT POLICIES GOVERN SECURITY AND ACCESS TO COLLECTED INFORMATION?

We maintain data security systems intended to prevent specific information from being made available to any unauthorized person and in order to protect information from loss, misuse and unauthorized access, disclosure, alteration or destruction. Our employees are made aware of and are accountable for compliance with our privacy policy. Any information collected by us on behalf of our partners is stored on our dedicated servers or databases. We use a multi-level, password protected security system to control access to information stored about video game activity. We also maintain physical security of our properties and facilities and with the purpose of providing access only to authorized personnel.

HOW ARE DISCLOSURE AND CHANGES TO MASSIVE INCORPORATED'S PRIVACY POLICY MADE?

We publish our Privacy Policy and practices at www.massiveincorporated.com/privacy. Any material change to our Privacy Policy will be noted in our privacy policy, which is accessible from our main Web page at www.massiveincorporated.com.
You may contact us at privacy@massiveincorporated.com with any questions or concerns regarding our Privacy Policy. You may also contact us in writing at 627 Broadway, 7th Floor, New York, New York 10012, Attention: Legal Department.

WHAT ARE SOME OTHER PRIVACY RESOURCES?

The following is a list of selected links to privacy-related resources that can be found on the World Wide Web:

Association for Interactive Media (AIM)
http://www.interactivehq.org

Federal Trade Commission
http://www.ftc.gov/privacy

Network Advertising Initiative
http://www.networkadvertising.org

Online Privacy Alliance
http://www.privacyalliance.org

Privacy.org
http://www.privacy.org

U.S. Commerce Department
http://www.export.gov/safeharbor/index.html

CAUTION REGARDING LINKED WEB SITES:
This Web site contains links to other Web sites. We are not responsible for the privacy practices or the content of such Web sites. We encourage you to read the privacy statements of these linked Web sites, as their privacy policies may differ from ours.

WHERE CAN YOU GO FOR MORE INFORMATION?

Please contact us for more information about Massive Incorporated. Please email questions or requests for more information about Massive Incorporated's privacy policie.

EFFECTIVE DATE OF THIS POLICY
This policy was last updated on and is effective as of September 26, 2005.