NetInformer Privacy Policy

Version: March 31, 2007

NetInformer LLC operates Xtra! Mobile Coupons and other wireless information services. At NetInformer, we strive to develop innovative services to better serve our users. We recognize that privacy is an important issue, so we design and operate our services with the protection of your privacy in mind. This Privacy Policy outlines the types of personal information we gather when you use NetInformer's services, as well as some of the steps we take to safeguard it. We promise that we will take steps to use your personal information only in ways that are compatible with this Privacy Policy.

The following principles apply to the personally identifying information we ask for and that you provide. "Personally identifying information" is information that individually identifies you, such as your name, phone number, physical address or email address.

Data Collection

• NetInformer collects limited non-personally identifying information your wireless phone service makes available whenever you participate in one of our services. This log information includes your phone number, your mobile phone carrier, the date and time of your participation and your inbound message. We use this information to operate, develop and improve our services.
• Some of our services may require you to register for an account. NetInformer asks you for some personal information that will identify you in order to create an account (typically your name, email address and a password for your account) and we will use that information to provide the service. Personal information may include e-mail address, zip code, birth date, age, gender and geographic location. We may also ask you to select a user name and password. In some cases, when you interact with a NetInformer campaign or promotion, or redeem promotional materials, you may be asked to provide personal information to the provider of the goods or services. That information would be subject to the privacy policy of the provider.
• When we require personally identifying information, we will inform you about the types of information we collect and how we use it. We hope this will help you make an informed decision about sharing your personal information with us.

Information Sharing

• We do not rent or sell your personally identifying information to other companies or individuals, unless we have your consent. We may share such information in any of the following limited circumstances:
• We have your consent.
• We provide such information to trusted businesses or persons for the sole purpose of processing personally identifying information on our behalf. When this is done, it is subject to agreements that oblige those parties to process such information only on our instructions and in compliance with this Privacy Policy and appropriate confidentiality and security measures.
• We conclude that we are required by law or have a good faith belief that access, preservation or disclosure of such information is reasonably necessary to protect the rights, property or safety of NetInformer, its users or the public.
• If you have an account, we may share the information submitted under your account among all of our services in order to provide you with a seamless experience and to improve the quality of our services. We will not disclose your account information to other people or non-affiliated companies, except in the limited circumstances described in this Policy or with your consent.
• We may store and process personal information collected on our site in the United States or any other country in which NetInformer LLC or its agents maintain facilities. By using our services, you consent to the transfer of your information among these facilities, including those located outside your country.
• NetInformer will not provide or release your personal information to a third party unless you have opted-in for a promotion. Traffic data and personal data may be used by NetInformer for editorial and feedback purposes, for marketing and promotional purposes, for statistical analysis of users' behavior, for product development, for content improvement, and to inform advertisers of how many visitors have viewed their advertisements. In these cases, data is reported on an aggregate (i.e., group) basis. We may share this information with other parties, but when we do so it is not traceable to any particular user. In addition, traffic and personal data may be used to customize and tailor your experience on your phone, by displaying content that we think you may be interested in.
• We will, without specific or further notice to you, release your traffic data and personal data when we believe such disclosure is appropriate to: protect the rights, property or safety of NetInformer, the site, our users or others; enforce our terms and conditions of usage; to provide the services you directly request from us through the NetInformer sites; comply with law, a court order or other legal process; in the course of responding to any claim by a third party that you are using services provided through the NetInformer sites in connection with an infringing, illegal or improper activity or that data you placed on a NetInformer site infringes rights of the third party; in response to request for identification in connection with a claim of copyright or trademark infringement by you; to an affiliate or service provider engaged to maintain or host NetInformer sites, subject to that party's agreement to honor this Privacy Policy.
• In the event of a transfer of ownership of NetInformer LLC, such as acquisition by or merger with another company, we will provide notice before any personally identifying information is transferred and becomes subject to a different privacy policy.

Public Forums

• We may provide you with chat features, instant messaging, message boards, and/or news groups. Please remember that any information that you may disclose in the public areas will become public information, and any information that is disclosed in a private forum will become accessible to all other members of that forum. We do not intend to monitor, moderate, screen or otherwise be responsible for the contents of postings. You should exercise caution when deciding to disclose your personal information in public or private forums.

Information Security

• We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data.
• We restrict access to your personally identifying information to employees who need to know that information in order to operate, develop or improve our services.

Updating Your Information

• We provide mechanisms for updating and correcting your personally identifying information for many of our services. For more information, please see the help pages for each service.

Opt-In and Opt-Out Choices

• We will always provide you with the opportunity to opt-in and opt-out of receiving further communication from our partners and us. Using the original service, you may send a request to remove your information from our database, stop future communication, limit the use of your information, or to review and modify information that you may have previously provided. The format of such Opt-Out requests will be provided when you Opt-In via the service used (wireless, SMS, internet, etc.). In the event that you cannot utilize the original service to Opt-Out, we will immediately honor any Opt-Out requests via the NetInformer web site using the "Contact Us" Section.

Contact Us

• To exercise your opt-out privileges, modify your user information, or if you have any questions regarding this Privacy Policy, the practices of NetInformer, or other matters regarding your experiences with NetInformer, please contact us by e-mail, post, telephone or fax. Please include your appropriate identifying information such as mobile phone number, campaign, contest, username, password, etc.
  
  NetInformer LLC
  2551 San Ramon Valley Blvd
  Suite 217
  San Ramon, CA 94583
  Phone: 925-275-1110
  Fax: 925-264-0011
  info@netinformer.com

Changes to this Policy

• Please note this Privacy Policy will change from time to time. We expect most such changes to be minor, but there may be changes that are more significant. Regardless, we will post those changes on this page and, if the changes are significant, we will also provide a more prominent notice. Each version will be noted at the top of the page. Prior versions of this Privacy Policy will be kept in an archive for you to view.
• For more information about our practices regarding specific information or services that are not covered in this Privacy Policy or if you have any additional questions, please feel free to contact us any time at info@NetInformer.com.