Privacy policy

Freeway Interactive, LLC . ("Freeway") respects your privacy and is committed to protecting the Personal Information (defined below) that you may provide us while using Freeway’s Game Services (as defined below). Your use of the Game Services is subject to your agreement to the terms of this privacy policy ("Privacy Policy") and Freeway’s current Terms of Service. This Privacy Policy explains the basis on which any Personal Information Freeway collects from you, or that you provide, will be processed by Freeway. This Privacy Policy is intended to provide you with notice of the following:

• Your rights with respect to the processing of your Personal Information

• Disclosure of your Personal Information to third parties

• The web sites and services covered by this Privacy Policy

• Freeway’s policies concerning Children's Personal Information

• What "Personal Information" (Information that directly or indirectly identifies a particular individual. For example; the individual's full name, postal address, and email address) Freeway may collect from you

• What non-Personal Information Freeway may collect from you

• Information on Freeway's use of "cookies" and related technology

• How and for what purposes Freeway processes, uses and shares the information that Freeway collects from you

• Information about co-published games

• Information about links and third parties related to Freeway’s Game Services

• How you may access, change or delete the information you have provided to Freeway

• Other important agreements that govern your use of the Freeway’s Game Services

• Information for persons outside the United States

• Freeway’s commitment to secure the Personal Information Freeway has collected

• Notice of changes to this Privacy Policy

Your Privacy Rights

As further discussed in this Privacy Policy, Freeway may from time to time provide you with the opportunity to receive information about products and services offered by Freeway and/or Freeway’s third-party partners. You can prevent future disclosures of your Personal Information to Freeway’s third-party partners, at no charge, by exercising your "opt out" rights sending an e-mail expressly making such request to: [email protected]. Because Freeway provide you with the ability to exercise your "opt out" rights as described above, Freeway does not provide the names and addresses of third-parties that received Personal Information from us.

Freeway’s policies concerning children

Please take note that most content, games and services provided by Freeway are not directed towards children under the age of 13 ("Children" and individually each, a "Child"). Therefore, except as otherwise expressly permitted by Freeway’s Terms of Service and Freeway’s Privacy Policy, membership and/or registration for access to such content, games and services by Children is strictly prohibited. In any event individuals under the age of 18 should consult their parents or legal guardians before providing us with any of their Personal Information.

Information for Parents

Parents are encouraged to spend time online with their kids under the age of 18 and to become familiar with the types of content available from Freeway and the Internet in general. Parents should regularly oversee their kid's use of e-mail and other online communications and transactional features. Control tools are available from online services and software manufacturers that can help provide a safe online environment for kids. You can find out about software that protects your Children at the Direct Marketing Association's home page at: http://www.ftc.gov/bcp/edu/pubs/consumer/tech/tec08.shtm and at http://kids.getnetwise.org/tools/. If your son or daughter has used your credit card on any Freeway Service without your permission, contact us immediately at [email protected]

What Personal Information Freeway collect from you

Freeway does not collect any Personal Information from you, unless you provide it to us voluntarily (e.g. through interaction with the Service). If you decide to provide us your Personal Information (e.g., name, e-mail address, and mailing address), Freeway will only collect the Personal Information which is needed to fulfill your requests and/or Freeway’s legitimate business objectives, as set out in this Privacy Policy, and Freeway will keep it no longer than is necessary to fulfill such purposes and objectives. If you refuse to divulge your Personal Information when requested, and the disclosure of such Personal Information is indicated as being required (rather than voluntary), you may not be able to access certain functionality of Freeway’s services.

Memberships and Registration

Some of Freeway’s services may allow you to visit as a guest and remain anonymous, but you may not be able to access all the content and features of those areas without registering. Important information regarding account registration procedures and the security of your account is set out in Freeway’s Terms of Services.

E-mail Newsletters and Friend to Friend Promotions

Typically you need to have an account in order to receive e-mails from us, provided that you may receive e-mail communications from us on a one-time basis if you have contacted us directly with regard to a specific request or if you do not have an account and have expressly agreed to receive e-mail communications for promotion and/or marketing, or for

e-mail newsletters. You may be asked for additional Personal Information when you subscribe. You can opt-out of receiving future marketing e-mails from us by following the directions contained in the e-mail to "unsubscribe." Also, except in jurisdictions where it may be prohibited by law to do so, Freeway’s services may allow you to submit information about other people. For example, Freeway may offer "Send to a Friend" promotions. In these situations, you may provide the e-mail address and, sometimes, the name of a friend. In Freeway’s communication to your friend in this circumstance, he or she will also be presented with an opportunity to "opt-out" from receiving future e-mails from us. You might also submit a person's name and other information if you purchase a gift and want to have it sent directly to the recipient. A record of that transaction will be maintained as allowed and/or required by law.

Sweepstakes, Contests, and Promotions

To participate in some of Freeway’s sweepstakes, contests, surveys, and other promotions, you may be asked to provide additional Personal Information such as your mailing address. This information may be collected by Freeway or by third parties such as co-sponsors or vendors for the promotion. Potential winners may be required to provide additional Personal Information for the purpose of verifying eligibility and awarding prizes, and for tax purposes. Freeway’s use of any such information will be governed by this Privacy Policy. The names of third parties such as co-sponsors will be disclosed to you when you are asked to sign up for the promotion. You should review such third parties' privacy policies to see how they may use any information that they collect.

EOnline Purchases and Technical Support

When you sign up to play one of Freeway’s fee-based games or you make certain online purchases from the us, Freeway may also require that you provide us with the necessary billing information such as your real name, credit card or payment information, street address, etc., so that Freeway may provide the content, game, service, or product to you (according to the terms of the sale, including for example the end user license agreements and terms of use for Freeway’s fee-based games). In order to resolve issues related to customer service, billing questions, technical and computer support, etc., Freeway may also require you to provide us with some Personal Information so that Freeway may resolve such issues properly.

Online Games

When you play any of the games offered and/or served by Freeway, or use certain of the communication features on Freeway’s services, your IP address (the Internet protocol address from which you access any of the above) may be stored in Freeway’s records. When any game is updated or "patched," Freeway’s systems may check your computer to see that you have the most recent version of game-specific files; when you communicate within any game or any other communication feature within Freeway’s services (e.g. live chat, instant message services and the like), even "privately" to another person, you do so with the understanding that those communications go through Freeway’s servers, you expressly agree to waive any rights of confidentiality that you may have in and to your communications (if any) when using any of these communication features, you agree you have no expectation of privacy in any of those communications and, accordingly, and where and to the extent permitted by applicable law, you expressly consent to monitoring of communications (including technical support and customer service communications) that you send and receive. When you log into one of Freeway’s online games, your system specifications (such as OS, RAM, video card, monitor, system configuration, crash data etc.) may be reviewed/ recorded by us for the purposes of analyzing and optimizing your game experience and in order to provide you with customer service.

Consent to Monitor

Please note that, when running, some Freeway’s services may monitor your computer's random access memory ("RAM"), media access control ("MAC") address, configuration files and system files, etc., for unauthorized third party programs running concurrently with Freeway’s services which, in SOE's sole determination: (i) enable or facilitate cheating of any type; (ii) allow users to modify or hack the applicable service interface, environment, and/or experience in any way not expressly authorized by Freeway; or (iii) intercept, "mine" or otherwise collect information from or through the applicable Freeway service (an "Unauthorized Third Party Program"). In the event that we detect an Unauthorized Third Party Program, (a) the service may communicate information back to Freeway, including without limitation your account username, details about the Unauthorized Third Party Program detected and the activities or functions performed thereby, and/or details about your computer, and/or (b) Freeway may exercise any or all of its rights and remedies under this Agreement or the applicable Freeway Terms of Service without prior notice to the user linked to such Unauthorized Third Party Program. You acknowledge that any and all data that is stored and is resident on Freeway’s servers, and any and all communications that you make within Freeway’s services (including, but not limited to, messages solely directed at another player or group of players) traverse through Freeway’s servers, may or may not be monitored by Freeway’s agents (to the extent permitted by applicable law), you have no expectation of privacy in any such communications and expressly consent to such monitoring of communications you send and receive. You expressly agree to waive any rights of confidentiality that you may have in and to your communications (if any) when using any of Freeway’s service communication features, you agree you have no expectation of privacy in any of those communications and, accordingly, and you expressly consent to such monitoring of communications (including technical support and customer service communications) that you send and receive.

Indirect Collection of Personal Information

Please note that, as mentioned elsewhere in this Privacy Policy and/or Freeway’s Terms of Service, Freeway may collect from you Personal Information relating to certain third parties, such as your Parents, other family members, friends, etc. ("Indirect Personal Information"). Except as provided by applicable laws and/or as described in this Privacy Policy, you will not give any such Indirect Personal Information to us and/or any to thirdparty without the relevant third party's consent.

What non-Personal Information Freeway Collects from You

General, aggregated, demographic, and non-Personal Information may be collected by Freeway. It will not be linked to any of your Personal Information, through cookies or other means, without your consent. This type of anonymous, aggregated profiling and session data may include information that you have provided to us through surveys, polls, etc., but will not be tied to any Personal Information, without your consent. It may also include aggregated anonymous information about web site usage and the customer base. As part of the registration process for some services, you may be asked to provide information that does not personally identify you. For example, you may be asked to provide information concerning your entertainment preferences, purchasing habits, and the like. This information is generally optional, but where provided it may be included in your account profile and you hereby consent to this information being tied to your Personal Information. Freeway requests this information to understand you better and to also bring to your attention new services, programs, or offers that may be of interest to you. Where Freeway automatically collects non-Personal Information as stated above, and it is possible to link this information to your Personal Information, you hereby consent to Freeway linking relevant non-Personal information to your Personal Information. In many cases, Freeway will automatically collect certain non-Personal Information about your use of Freeway’s Services. Freeway might collect, among other things, information concerning the type of Internet browser or computer operating system you are using, the domain name of your Internet service provider, your "click path" through a Site, and the web site or advertisement that was linked to or from a Site when you visited. To do this, Freeway may

use cookies and other technology (see below). Your visits to Freeway’s Services, and information provided through these technologies, will be anonymous unless you provide us with Personal Information or have provided such information in the past. For example, if you've created an account, your account information (including e-mail address, and billing and shipping information) may be linked to the items you purchased at Freeway’s online store (i.e., purchase order history).

Information on cookies and related technology

Freeway’s Services, and some services and advertisements displayed or made available thereon, may contain "cookies." A cookie is a piece of data that is sent to your browser, which will store the cookie on your computer if your browser is enabled to accept cookies. Technology and tools such as clear gifs (also known as "web beacons") assist in the delivery of cookies. Freeway uses cookies, clear gifs, frames, server log analysis and other technology to:

• store information about your preferences, so as to allow us to customize your experience with Freeway’s Services and its subsites;

• estimate Freeway’s audience size and usage patterns;

• to speed up your searches; and

• recognize you when you return to Freeway’s site.

Cookies can either be permanent (i.e., they remain on your computer until you delete them) or temporary (i.e., they last only until you close your browser). Certain cookies are required to allow or facilitate electronic communications or are necessary to allow the provision of online services at the request of the user. On their own, cookies or related technologies do not contain or reveal any Personal Information but can be combined with and use to process Personal Information. Personal Information collected through the use of these technologies will be collected, stored and processed according to this Privacy Policy. Most internet browsers will allow you to erase cookies from your computer hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. You should refer to your browser instructions or "Help" screen to learn more about how to manage cookies. Please note, however, that if you block cookies, some portions of Freeway’s Services may not function properly. Freeway does not control cookies in third party ads, and visitors are encouraged to check the privacy policies of advertisers and/or ad services to learn about their use of cookies and other technology. The ads appearing on Freeway’s Services may be delivered to you by thirdparty advertising companies. These companies may use information about your visits to this and other web sites in order to provide advertisements on Freeway’s Services and other sites about goods and services that may be of interest to you. If you would like more information about this practice and to know your choices about not having this information used by these companies, please click here http://www.networkadvertising.org/optout_nonppii.asp.

How Freeway uses information that Freeway collect from you

Personal Information which Freeway collect for a particular purpose will only be saved and used for that purpose, unless you have agreed to allow us to use it for some other purpose, as described in this Privacy Policy. For example, if you make an online purchase from us, unless you have given us permission to do otherwise, Freeway will only collect and save the Personal Information you provided to us, including your billing and delivery information, in order to (1) complete the sale, (2) comply with tax and other applicable statutes, (3) maintain accurate business and financial records (in accordance with accepted standards), and (4) assist with customer service and returns. Freeway may use the Personal Information Freeway collected from you to enable us to:

• provide you with technical support, customer service, and account maintenance;

• learn what you like and tailor your experience accordingly;

• to improve Freeway’s Services and its subsites and Freeway’s other products and services;

• provide services or products you request;

• allow you to participate in or use the Freeway Communication Features;

• allow you to play one of Freeway’s fee-based games, or free games and download any other game;

• allow you to benefit from any other services, as the case may be, such as sweepstakes, contests and promotions;

• manage your Station Account and respond to your potential orders, requests and online purchases;

• inform you of any changes made to Freeway’s Services and its subsites; and

• inform you of products, services, promotions and offers which you may find interesting.

If you do not want us to use your Personal Information in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which Freeway collects your data.

Information Freeway provide to third parties

Where and to the extent required by the applicable laws, you hereby expressly consent to your Personal Information being shared with or otherwise transferred by Freeway to third parties. When you have provided Personal Information to us for a particular purpose, Freeway may disclose your information to other companies that Freeway have engaged to assist us in fulfilling your request and who Freeway subjects to confidentiality requirements. This may include, but is not limited to, fulfillment houses, billing services, transaction managers, credit verification services, and other third party service providers. Freeway may also disclose any of your Personal Information to law enforcement or other appropriate third parties in connection with criminal investigations, investigation of fraud, infringement of intellectual property rights, or other suspected illegal activities, or as otherwise may be required by applicable laws, or, as Freeway deems necessary in Freeway’s sole discretion, in order to protect the rights, property or safety of Freeway, Freeway’s customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction. Freeway will also provide your Personal Information to third party processors so that it can be administered and processed for the purposes notified to you in the Privacy Policy and Freeway’s Services Terms of Service, and Freeway may also share details with third parties (such as auditors or legal advisors) in order to obtain professional advice. Any such processing will be governed by an agreement in the form required by applicable laws, preserving any and all of your statutory data protection rights. Except as described in this policy, Freeway will not give any of your Personal Information to any third party without your express approval, and other than with respect to Personal Information disclosed in connection with co-published games (as further described below), the only Personal Information Freeway will request to share with third parties is your name, mailing address and e-mail address. If you don't want us to share your Personal Information with third parties, you can "opt-out" in the manner discussed under "Your Privacy Rights" set forth on the first page of this Privacy Policy. Freeway sometimes share general, demographic, or aggregated non-Personal Information with third parties about Freeway’s user base, but that information does not include any Personal Information. You will be deemed to have consented to the disclosure to, and use by, a subsequent owner or operator of Freeway’s Services, of any Personal Information contained in the Freeway database for such site, if Freeway or one of its companies assigns all of its rights and obligations regarding the use of your Personal Information at the time of a bankruptcy, merger, acquisition, sale of all or substantially all of the Site's assets to a subsequent owner or operator, or similar event.

Information about Co-Published Games

Certain Freeway services, may be provided to you in conjunction with a third party. During the registration process for such games, you may be notified that such third party wishes access to some of your Personal Information. In such a situation, you will be given an opportunity to consent to the sharing of that information before such information is disclosed to the applicable third party. However, if you do not provide consent then you may be unable to participate in the applicable service.

Information about links and third parties related to Freeway’s Services

You have the right to access information held about you by Freeway. Your right of access can be exercised in accordance with applicable data protection and privacy laws. This Privacy Policy applies only to information collected online by Freeway through Freeway’s Services, as maintained by Freeway and affiliated companies that Freeway may own or control. From time to time, Freeway may provide links to third party web sites. This Privacy Policy does not apply to third party web sites, whether Freeway provide a link to such sites or not, so Freeway encourage you to review the policies of all such sites carefully, as your rights will be governed by those third party policies and not by Freeway. Additionally, there may be unauthorized third party web sites that may be providing links from their sites to Freeway’s Services without Freeway’s knowledge or control. Freeway are not responsible for the content of any third party web sites, expressly disclaim any statements or assertions made on such web sites, and deny all liability associated with your use of, and the content on, such other sites or advertisements contained therein.

Other important agreements that govern your use of Freeway’s Services

In addition to this Privacy Policy, your rights and obligations concerning Freeway’s Services are governed by Freeway’s Services Terms of Servcie, and where appropriate, the applicable subsite terms of service or terms of sale, the applicable game's end user license agreement and/or terms of use, and other applicable policies, guidelines, FAQ's and requirements. When you sign up to use Freeway’s Services and/or any of Freeway’s services, please review each such agreements carefully, as you must agree to be bound by each such agreement before you may use Freeway’s Services and/or the relevant service.

Securing the Personal Information

While Freeway takes reasonable precautions against possible breaches of Freeway’s Services and customer databases, no web site or Internet transmission is completely secure. Consequently, Freeway cannot and does not guarantee that unauthorized access, hacking, data loss, or other breaches will never occur, but Freeway have in place reasonable technical and organizational security measures to protect your Personal Information against accidental or intentional manipulation, loss, destruction, or against unauthorized disclosure or access to the information Freeway collect online. Freeway urges you to take steps to keep your Personal Information safe by memorizing your password or keeping it in a safe place (separate from your account information), logging out of your user account, and closing your web browser.

Notice of changes to this Privacy Policy

Freeway reserves the right to change this Privacy Policy at any time by posting the new Privacy Policy on Freeway’s Services. All changes to the Privacy Policy will be effective when

posted, and your continued use of any of the Freeway services after the posting will constitute your acceptance of, and agreement to be bound by, those changes.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed via email to: [email protected]

Last updated: October 10, 2011