April 15, 2010

Online Privacy Policy of CyberStep Communications, Inc.

Who We Are

CyberStep Communications, Inc. ("CSCI") is committed to protecting the personal information you provide to us when you register for a game account and obtain membership to play the online game serviced by CSCI (“Game”), and we encourage you to read the Privacy Policy set forth below which explains how we use and protect data we collect through the website for the Game (the "Website").

Who May Play Game

In order to play the Game, you must register as a "Member." If you are a Member residing in the United States or Canada, you must be at least 13 years of age. If you are under 18 years of age, you must obtain the consent of a parent or legal guardian before you register. Members in other countries/regions must meet the relevant laws and regulations of the countries/regions where you reside, including the laws and regulations concerning the age. Your registration for a game account shall be considered as your representation that you meet such laws and regulations.

What Information This Privacy Policy Covers

This Privacy Policy relates to all personal data provided to us through our Website. Please note that this Privacy Policy does not apply to any websites maintained by any of our international affiliates or to any websites maintained by other entities to which we link.

Changes to Privacy Policy

A condition of your download and use of a Game is your acceptance of this Privacy Policy. The terms of this Privacy Policy are subject to all applicable laws. Please note that we may amend this Privacy Policy at any time. The date at the top is the effective date of this version of the Privacy Policy. If we make any material changes to the Privacy Policy, we will prominently post a notice on the Website, and such material changes will be effective 30 calendar days following our posting of the notice of the changes on the Website.

Types of Information We Collect through Our Website

Information Automatically Collected:

You can visit our Website without downloading or registering to play a Game, and in that case, we do not ask you to provide any personal information. In some cases, though, our Website may automatically collect information about you that is not personally identifiable. Examples of this type of information include information about the operating system of your computer, the type of Internet browser you are using, your IP address (which is information associated with your Internet service provider or other manner in which you access the Internet), and the URL (Internet address) of the page from which you linked to our Website. Also, as explained below, our Website may use "cookies" and "Web beacons."

Automatic Updates to Game Software:

Once you have downloaded the game and registered as a Member for a Game, in accordance with the section on "Updates" in the End User License Agreement, our server may also check the version of the game residing in your personal computer to ensure that you have the most recent version (and if you do not have the most recent version, to automatically download to your personal computer the latest version).

Information You Provide to Us:

Before you can register to play a Game, we require that you provide us personal information about you. Additionally, there may be other features of our Website through which we collect personal information which you provide to us. Such features may include, but are not limited to, registration for online surveys, online contests or promotions, e-cards, emails you send from our Website (e.g.,"share" features), and emails to customer or technical support.

Personal information includes, but is not limited to, information such as your name, your date of birth, your email address, your credit card information (including cardholder name and billing address) and game setting preferences.

Cookies and Web Beacons:

Our Website may also use cookies and Web beacons to collect and store personal information. Cookies are small files sent to your computer from a website while you are viewing that website. Our Website may use cookies for a variety of purposes. For example, when you return to our Website after logging in, cookies may provide information to our Website so that the Website will remember you. The default setting on most Internet browsers allows the acceptance of cookies without any user action. However, you can choose to have your computer warn you each time a cookie is sent, or you can choose to turn off all cookies. (Each Internet browser is a little different, so look at your browser's Help menu to learn about modifying cookie settings.) If you turn cookies off, some of our Website's services may not function properly.

Web beacons are small pieces of data that are embedded in images on the pages of websites and in email communications. We may use Web beacons to analyze information about the use of our Website, such as the frequency with which Members visit various areas of our Website. Web beacon information may be transmitted to us directly or to another entity authorized by us to collect information and analyze data on our behalf. We may also use Web beacons in HTML emails that we send our Website guests to determine whether our guests have opened those emails or clicked on links in those emails.

Information Collected by Advertisers on Our Website:

Advertisements that are managed by third parties may be placed on our Website, and when you click on those advertisements or move your cursor over those advertisements, cookies and Web beacons contained in those advertisements will collect non-personal information about you. You may not realize this information is being collected. In some cases, we may have access to information from cookies and Web beacons used by third-party advertisers on our Website, and this information may permit us to identify other websites that you have visited that are also associated with the third-party advertiser. Please note that once you've clicked on an advertisement or third-party logo and have left our Website, our Privacy Policy no longer applies, and you must read the privacy policy of the advertiser to see how your personal information will be handled by that advertiser.

How We Use Your Personal Information

We will only collect information to the extent reasonably necessary to fulfill your requests and our legitimate business objectives. If you choose to play the Game through our service, then at a minimum, to allow you to access the service, we must know your email address. If you choose to make any purchases using credit card, then we must also collect credit card and billing information. In no event will we share your personal information (including email address) with any third party with whom CSCI has no affiliation. Details about specific situations in which we use your personal information are provided below.

E-Cards:

When you send an e-card, we delete both sender and recipient email address information after sending your e-card.

Forums and Message Boards:

If you register for access to our forums or message boards, we may use your personal information to enable you to view and post messages on the boards. You should understand, however, that community forums, blogs, and message boards are tools that allow you to communicate with members of the online community. So whenever you give out personal information in public areas, such as the "My Page" area, that information can be collected and used by people you don't know.

Service Providers:

We may employ other companies to perform services necessary to our internal operations. For example, we may partner with other companies to personalize our Website, analyze Members' interaction with our Website, and process online surveys. While providing services for us, these companies may access your personal information. Those companies storing or maintaining personal information for us have agreed to use secure methods.

Business Information:

Personal information you submit to us in a business capacity (e.g. resumes or inquiries about employment opportunities, inquiries about event sponsorship, etc.) may be shared with third parties, depending on the nature of the information or inquiry. Unless we explicitly state otherwise, we may share such information with third parties at our discretion.

Business Transfer:

In the event that CSCI sells or otherwise transfers management of a Game business, your personal information may be transferred as a part of the transfer. However, the terms of any such transfer will include a provision to treat your personal information in the same way required by the Privacy Policy that is in effect at the time of the transfer. The provisions of this paragraph will also apply if the business is sold as part of bankruptcy proceedings.

Disclosures Required by Law:

We may disclose any personal information when the law requires that we do so.

Disclosures to Protect Our Website and/or Other Users:

We may also disclose any personal information if we make a good faith determination that such disclosure is necessary to protect any of our legal rights, to enforce any of our rules, or to ensure the safety of others. We may also disclose personal information to our auditors or legal advisors who also have a duty to maintain the confidentiality of the information we provide.

Aggregate Information:

We may take your personal information and make it non-personally identifiable. We do this either by combining it with information about other individuals (aggregating your information with information about other individuals), and by removing characteristics (e.g., your name) that make the information personally identifiable to you. This process is known as de-personalizing your information. We may use de-personalized information in any way and share it with third parties.

What to Do If You Disagree with Our Privacy Policy

If you ever disagree with any of the terms of our Privacy Policy, you may immediately delete your account and stop playing the Game. (For information about how to delete your account, see the appropriate section on the Website, e.g. "How to Update or Delete Your Personal Information and Profile" section.)

If you signed up to receive emails from us, you can opt out any time simply by clicking the "unsubscribe" link at the bottom of the email.

We also encourage your feedback and inquiries about our Privacy Policy, and you may contact us by sending an email to the email address provided on the Website for general inquiry.

Your California Privacy Rights

California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not share our customers' personal information (i.e., non-aggregate information) with unaffiliated third parties for their own direct marketing purposes. Any information we provide to third parties falls under the statute's definition of "disclosures not deemed to be disclosures of personal information by a business for a third party's direct marketing purposes."

For inquires regarding our disclosure policy, please send us an e-mail to the mail address provided on the Website for general inquiry.

How We Safeguard Your Personal Information

To protect personal information, our server encrypts all information submitted on our Website using Secure Sockets Layer (SSL) software. In addition to our technical measures, we also take administrative measures to protect your personal information from unauthorized access and improper use. We also review our security procedures periodically to consider appropriate new technology and updated methods. However, despite our reasonable efforts, no security measure is ever perfect or impenetrable. We also encourage all Members to take care to protect their Member IDs and their passwords.

How to Update or Delete Your Personal Information and Profile

You may update or delete your personal information or modify your account preferences by accessing the appropriate section of the Website (e.g. "My Account" section). If you wish to delete your email address from our system, your account will also need to be deleted. You may also contact us directly with questions about your account by sending an email to the email address provided on the Website for this purpose.

Special Policies for Children 13-17

If you are a resident in Canada or United States, the game may be downloaded and played only by those 13 years of age or older. Minors (i.e., those under 18 years of age) may download and play only with the consent of a parent or guardian, and they must let a parent or guardian know about this Privacy Policy and get his or her permission before they submit any personal information on our Website. If you are a resident in other countries/regions, different laws and regulations may apply, and you behavior regarding the Game must meet such relevant laws and regulations.

Obtaining Parental Consent:

When a minor 13 to 17 years of age attempts to register on our Website as a Member, he or she must represent and warrant that he or she has obtained the consent of a parent or legal guardian to register with us.

Receipt of Prizes:

For safety and privacy reasons, Members, especially those who are minors, should never post or reveal their real names or contact information. If a minor wins any prizes offered through the Website, the minor's parent or guardian will need to send us written confirmation via email that the minor's participation in the contest was permitted by that parent or guardian and that he or she will accept the prize on behalf of the minor.

Modifications to Personal Information:

A parent or guardian who has given permission for his or her minor child to play the game may contact us to inquire about or delete personal information collected from his or her child by writing to us at the email address provided on the Website for general inquiry. Please provide a phone number where you can be reached during the day. Our representatives will take reasonable steps to verify your identity before disclosing your child's information. Please note that some personal information is required to play the game, so the deletion of some information may make the child ineligible to play the game.

Participation by Children under 13 Not Allowed

The Website is not directed to children under the age of 13, and we do not permit children under 13 to register as a Member. No personally identifiable information is collected from anyone who visits the Website without registering as a Member. Accordingly, we do not collect any personal information from children under 13.