PredictoMobile™ Canada Privacy Policy
Effective Date: September 30, 2009

Predicto Mobile, LLC (“Predicto” “we” or “us”) operates the Predicto website located at ca.predicto.com (the “Website”), and the Predicto service that includes the provision of interactive mobile content, such as news alerts, sweepstakes, surveys and quizzes, available online or via text messaging (“Service”). This privacy policy (“Privacy Policy”) outlines the privacy practices associated with the Website and the Service and covers our treatment of personal information that we collect when you: (a) visit the Website; (b) register for the Service, either as a premium member (“Premium Member”) or a basic member (“Basic Member” and together with Premium Members, “Members”); (c) enter any of the various drawings and/or sweepstakes that we may offer from time to time (“Sweepstakes”); (d) respond to any of our surveys or quizzes (“Surveys”); and/or (e) submit any other material to us, such as comments on surveys, user profile information or personal quotes relating to redeeming Loyalty Points or winning a Sweepstakes. By visiting the Website, subscribing for the Service, responding to a Survey or entering a Sweepstakes, you agree to be bound by the terms of this Privacy Policy. It is important that Website visitors, Members and Sweepstakes entrants are fully informed about the use of their personal information.

Personal Information We Collect From You

Registration. When you register for our Service as a Premium Member, we require that you provide your mobile telephone number and provide and retain the PIN number that we supply to you. If you register on our Website for a Basic Membership or if your Premium Membership is converted into a Basic Membership, we require that you provide your email address. Basic Members must also supply a two digit number from the range of 00 to 99 which will be their “Grand Prize Key.” (The Grand Prize Key may be used to determine if a Basic Member is eligible to win a prize if their entry is selected in certain Sweepstake per the applicable Sweepstakes Rules.) On our registration page we ask our Members to provide their: (a) first and last name; (b) home address; (c) email address; (d) home telephone number; (e) date of birth; (f) time zone; (g) screen name; (h) an icon or photograph; (i) a personal quote; and/or (j) any other information from or about an individual that we may request from time to time. This information is not required in order to complete registration. We also collect your IP address when you register. We refer to information that identifies you such as your name, cell phone number, email address and home address as “Personally Identifiable Information” in this Privacy Policy.

Website Visitors. We collect information when you visit the Website through cookies, clear gifs and other means such as your IP address, browser type, ISP, referring/exit pages, operating system, date/time stamp and clickstream data. We store this information (“Log File Information”) in log files.

Sweepstakes. If you are not a Member and mail in an entry for a given Sweepstakes, we collect your name and mailing address, home or cell phone number, and Sweepstakes ID when you enter the Sweepstakes. We do not collect Social Insurance Numbers . If you win one of our Sweepstakes, you will be required to provide your mailing address if we have not already collected it and a copy of a government issued photo identification. If you win one of our Sweepstakes, we also require that you complete and submit a release which allows us to identify you as a winner on the Website and in other promotional materials. We may also ask you for a quote and a photograph, which may display on the Website, all without additional compensation.

How We Use Personal Information

Any personal information that you submit to us remains your property however, we may use this personal information to administer the Website, Service and Sweepstakes as described below.

Text Messages and Other Communications. Premium Members will receive surveys and other communications periodically, typically weekly. Premium Members may control the frequency with which they receive communications by changing their account preferences on the Website. Basic Members may also receive communications from us, typically via email.

Service-Related Announcements. We will send you service-related announcements when it is necessary to do so. For instance, for Premium Members we send text messages monthly to remind you that your membership is being renewed. If you cancel your membership, we may send you a confirmatory text message or an email.

Customer Service. Based upon the Personally Identifiable Information that you provide to us, we will send you a welcoming text message or, for Basic Members, an email verifying your username and password. We will also communicate with you in response to your inquiries, to provide the services you request and to manage your account.

Supplementation Information. We verify the cell phone numbers submitted by Premium Members when they sign up with information provided by a third party.

Log File Information. When you visit our Website and use our Service, we use Log File Information and survey responses to create a “profile” of your preferences. We tie your Personally Identifiable Information and your Survey responses to information in the profile to tailor the Surveys that we send to you, and to improve the content of the Website. We also use this information to analyze trends, administer the Website, track users’ movements around the Website and gather demographic information about our user base as a whole. We link this automatically-collected data to Personally Identifiable Information.

Website. If you supply us with a photograph and/or a personal quote or comment, we may, for promotional and community building purposes, post these on the Website and attribute them to you without any compensation to you. As noted above, we may also ask you for a quote and/or a photograph if you win one of our Sweepstakes and may post them on the winner’s page on the Website, also without compensation to you.

We do not share your profile with other third parties.

Information Sharing and Disclosure

Aggregate Information (Non-Personally Identifiable Information). We compile aggregated demographic information about our Members to better focus our Service to meet our Members’ needs, preferences and to assist in our marketing efforts. We may also share aggregated data about our Member base including the number of Members that we have.

We compile Survey responses and post the results on the Website and may use the results in advertisements and other promotional materials. We may also compare a Member’s response to a particular Survey to determine the number of loyalty points awarded.

Except as noted above, we do not link aggregate user data with Personally Identifiable Information.

Personally Identifiable Information. We do not share Personally Identifiable Information with third parties for promotional purposes. We reserve the right to change this policy; if we do so, we will inform you of the change and afford you the opportunity to opt-out of having your Personal Identifiable Information shared.

Service Providers. For Premium Members, we share your cell phone number with third party billing companies, cell phone carriers and our third party customer care call center to facilitate billings, to process credits and refunds, for customer service and to communicate with you via text message. We may, from time-to-time, supplement the information we collect from you with outside records (e.g., information we obtain from other companies, including wireless providers) to enhance our ability to serve you. We may also share your Personally Identifiable Information with third parties so that we can award prizes to Sweepstakes winners and when Members redeem loyalty points. These third parties are prohibited from using your Personally Identifiable Information for any other purpose.

Legal Disclaimer. We reserve the right to disclose your Personally Identifiable Information: (a) as required by law and/or to comply with a judicial proceeding, court order or legal process served on the Website or Predicto; (b) when we believe that disclosure is necessary to protect our rights; (c) if we believe that you are in violation of the terms and conditions of this Privacy Policy, our Terms of Service, any applicable Sweepstakes Rules or any other of our operating rules, policies and other supplemental terms and conditions or documents that may be made available by us from time to time; or (d) if Predicto is, or its assets are, sold or acquired.

Cookies and Pixel Tags

“Cookies" are small pieces of information that are stored by your web browser software on your computer. The use of cookies is now an industry standard and used by most major websites. We use cookies to recognize you and personalize your viewing experience on the Website. For example, we use cookies to recognize user access privileges to the Website, to track Website usage and traffic patterns and to estimate our Website traffic. Although most web browsers are initially set up to accept cookies, if you prefer, you can decline the placement of a cookie on your hard drive by using the appropriate feature(s) of your web browser software (if available) to delete the cookie. Please note, however, that certain areas of the Website may not function properly if your web browser does not accept cookies.

A "pixel tag" is an invisible tag consisting of a few lines of computer coding placed on certain pages of websites you may visit. We may use “pixel tags” to do "pixel tracking." Pixel tracking, a common practice, uses pixel tags to track an individual user's online activity in connection with online advertisements. Pixel tracking measures the effectiveness of these advertisements and compiles aggregate and specific usage statistics. For example, if you sign up for our Service or visit the Website from an advertisement on another website, or in an HTML based email, the pixel tag will allow the advertiser to track that their advertisement brought you to our designated landing page and/or the Website. If you visit our Website and we provide links to another website, we may also be able to determine that you were sent to and/or transacted with that third party website from our Website. This data is collected for use in our marketing and research. Personally Identifiable Information about you is not collected by us in connection with this process.

Links to Other Websites

The Website may contain links to other websites that are not owned or controlled by us. In that event, please be aware that we are not responsible for the privacy practices of such other websites. We encourage you to be aware when you leave our Website and to read the privacy statements of each and every website that you visit.

This Privacy Policy applies only to information collected by the Website.

Bulletin Boards / Chat Rooms / Public Profile Page

If you use a bulletin board or chat room on the Website, you should be aware that any Personally Identifiable Information that you submit there can be read, collected and/or used by other users of those forums, and could be used to send you unsolicited messages. We are not responsible for the Personally Identifiable Information that you choose to submit in those forums. We reserve the right to terminate the Member status of anyone who uses those forums in a manner inconsistent with our Terms of Service.

Access to Personally Identifiable Information

If your Personally Identifiable Information changes, or if you no longer desire our Service, you may correct, update or delete your Personally Identifiable Information by making the change(s) or deletions, as applicable, on your MyProfile page on the Website, by emailing our Customer Support at cs_support_ca@predicto.com or by contacting us by telephone or postal mail at the contact information listed below.

Minors

No information should be submitted to, or posted at, the Website by visitors under nineteen (19) years of age without parental consent, and we do not knowingly collect Personal Identifiable Information from such individuals without parental consent. The Website and Service are not for use by individuals under thirteen (13) years of age. If you are older than thirteen (13) years of age but under nineteen (19) years of age, you may use the Website and/or Service, but only where you have a parent’s consent to use the Service. We encourage parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children.

Security

The security of your personal information is important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security, and therefore you transmit information to us at your own risk. Once we receive your transmission, we make reasonable efforts to ensure its security on our systems. Access to this personal information is strictly limited, and not accessible to the public. All of our users’ personal information is restricted in our offices. Only employees who need the information to perform a specific job are granted access to personal information. Our employees are dedicated to ensuring the security and privacy of all Predicto user personal information. Employees not adhering to our written firm policies are subject to disciplinary action. In compliance with any applicable federal and provincial , we will notify you and any applicable regulatory agencies if we learn of an information security breach of your Personal Identifiable Information. We will notify via email if there’s such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.

The personal data a Member or entrant submits upon registration will be stored on servers in the United States of America (“U.S.”) and may be accessed by our service providers in other countries abroad. Information which is processed and stored in the US and abroad is subject to disclosure to the governments, courts or law enforcement or regulatory agencies in accordance with the applicable country’s laws. Use of the Services constitutes a Member’s or an entrant's consent to the export of his/her personal data to the U.S. and its use there for the purposes indentified in this Privacy Policy. The servers are controlled by Predicto and/or its Administrator who adhere to the rules of the Safe Harbor Framework available under http://www.export.gov/safeharbor/eg_main_018247.asp.

If you have any questions about the security practices of the Website, you can email us at cs_support_ca@predicto.com.

Business Transitions

If we go through a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Personally Identifiable Information will likely be among the assets transferred. You will be notified of any such change in ownership or control of your Personal Identifiable Information.

Changes in this Privacy Statement

We reserve the right to modify this Privacy Policy at any time, so please review it frequently. If we decide to change this Privacy Policy, we will post those changes to this Privacy Policy, and provide notice via email, on the Website homepage and/or other means that 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. Your continued use of the Website and/or Service following notice of changes to this Privacy Policy will constitute your acceptance of any changes.

Contacting Us About Privacy Questions or Concerns

If you have any questions about this Privacy Policy, the Service, Sweepstakes, Surveys or the Website, you may obtain support at any time through the Website at http://ca.predicto.com/support, via email at cs_support_ca@predicto.com, or via telephone at 800-360-0518. You may also text “HELP” to 654654 at any time to receive summary information about your Predicto account and instructions on how to access customer service.