LUDIA, INC. PRIVACY POLICY

I.                LUDIA PRIVACY POLICY

Ludia, Inc (Ludia) and its subsidiary companies respect the privacy rights of our online visitors and recognize the importance of protecting the information collected about you.

If you have any questions, complaints, or comments regarding our privacy statement or policies, please contact privacy@ludia.com .

This privacy policy applies to the following web sites operated by Ludia:

Ludia.com
PlayTPIR.com

In addition, Ludia will from time to time add new web sites that may or may not be listed above. Please note that this policy applies only to sites maintained by Ludia or its subsidiaries, and not to web sites maintained by other companies or organizations to which we link. This Privacy Policy applies only to information collected by Ludia online, not offline.    

Third Party Sites.
If you click on a link to a third party site, including on an advertisement, an Ad company, or other service provider, you will leave the Ludia site you are visiting and go to the site you selected.  Because we cannot control the activities of third parties or other service providers, we cannot accept responsibility for any use of your personal information by such third parties, and we cannot guarantee that they will adhere to the same privacy and security practices as Ludia. We encourage you to review the privacy policies of any other service provider from whom you request services. If you visit a third party web site that is linked to a Ludia web site, you should consult that site’s privacy policy before providing any personal information.

What is personal information and when does Ludia collect it?
Personal information is information that identifies you and may be used to contact you on-line or off-line. Ludia may collectpersonal information from our online visitors during (1) contests (registration or claiming a prize), (2) warranty registration and/or during customer support or technical service requests, (3) player match up or other online services, (4) registration for games or special game-specific event participation, (5) marketing surveys and email campaigns, (6) registration for membership on our sites, (7) when you order products or subscriptions from us online, or (8) when you request services from third party service providers on our site or (9) through use of our software or online services.

Information collected will vary depending upon the activity and may include your name, e-mail address, phone number, mobile number, home address, birth date, and credit card information. In addition, we may collect demographic information such as gender, zip code or postal code, information about your computer, hardware, software, platform, media, Internet IP address and connection, information about online activity such as feature usage, game play statistics and scores, user rankings and click paths and other data that you may provide in surveys or online profiles, for instance. We may combine demographic information with personal information.  Prize winners may also be required to provide Social Security, Social Identification Number or Social Insurance Number for tax purposes. 

We do not require personal information to obtain access to any of our sites; however, you will not be able to access areas that require registration. 

Whatever the purpose may be, we will only collect information to the extent reasonably necessary to fulfill your requests and our legitimate business objectives.

Job Postings
Ludia allows for the online submission of resumes and employment related information. Please note that the information (including personal information) collected and services related to the online job application process are not subject to this privacy policy. However, we want to assure you that information obtained from our job site will be used solely for the purpose of accepting and evaluating your submission for possible employment and the related purposes described on our jobs site.

Statistical and Usage Data
When you play our games on your PC, we may retrieve information about your hardware system and how your game is used, including your Internet Protocol Address.  We use this information to enable you to play your game over the Internet.  We also use this information to better understand the behavior and preferences of our customers, so that we can improve our products and services.  We will never use this information to personally identify you without your knowledge or consent. 

In-Game Advertising
Our games may incorporate dynamic advertisement serving technology offered by our Advertising Network Providers (“Ad Providers”), which enables advertising to be temporarily uploaded into the game on your PCand replaced while you play online. Logged data may include Internet Protocol Address or player’s user name, in game location, length of time an advertisement was visible, size of the advertisements, and angle of view. Your game may be assigned an id number, which is stored on your PC or console, and used by Ad Providers to calculate the number of unique and repeat views of dynamic in game advertising. The id number is not associated with any personal data. No logged information is used to personally identify you. The servers used by the Ad Providers may be located outside your country of residence.  This ad serving technology is integrated into the game; if you do not want to use this technology, do not play the game while connected to the Internet.

Public Data
Your participation in online game events is conditional upon you agreeing to us collecting, using, storing, transmitting and publicly displaying statistical data (such as your scores, rankings and achievements) generated through your participation.

What happens to the information provided?
Ludia does not disclose any personal information about children under 18 years of age who have registered on any of our web sites to third parties, regardless of parental consent, or share or disclose personal information other than as set forth in this policy, provided however, that in the event of a merger, acquisition, or the unlikely event of bankruptcy, management of Ludia’ customer information may be transferred to its successor or assign.

You may register for other services from our web site(s). If you opt in to any of these services, we may collect additional information requested by a service provider and pass this information, together with all other registration information (including personal information), to that service provider. Use of your information by a service provider will be governed by that service provider’s terms of service and privacy policy. We may also retain any additional information collected for use in accordance with the terms of this Privacy Policy. Participation in these other related services is optional and is not required to play Ludia games, or participate in any of our other web sites.

The personal information you provide will allow us to alert you to new products, features and enhancements; special offers; upgrade opportunities; and contests and events of interest. From time to time, we are approached by companies and organizations that provide products or services that we believe may be of interest to you, and we may provide your personal information to such third parties. We see this as a value-added service helping you to find useful products or services. We strive to limit use of the information you provide to those offers that we think you would appreciate receiving. You may opt out of this service. See the opt-out information below.  We may send emails that may contain information regarding third-party products or services; however, this doesn’t mean that we’ve traded your personal information to any party.

Finally, we may use your personal information for our internal marketing and demographic studies, so we can consistently improve our sites to better meet our visitors' needs. To enforce legal rights and comply with the law, or to comply with an order from a government entity or other competent authority, or when we have reason to believe that a disclosure is necessary to address potential or actual injury or interference with our rights, property, operations, users or others who may be harmed or may suffer loss or damage, we may also disclose personal information to law enforcement, or the appropriate civil authorities.

Opt-out Provision
When we first collect information about you, we will offer you the opportunity to opt-out of having your personal information shared with parties outside of Ludia or its subsidiaries (except to the extent required by law, court order, or as requested by other government or law enforcement authority). In addition, if you do not want Ludia to send you e-mail or postal mail about our products and services, you can opt out at the time of registration or information collection. If, at a later date, you choose to have your name removed from our mailing list, you can do so by contacting privacy@ludia.com .

Safeguarding Your Personal Information
We will only collect and use personal information in accordance with this privacy policy to the extent deemed reasonably necessary to serve our legitimate business purposes, and we will maintain appropriate safeguards to ensure the security, integrity, accuracy and privacy of the information you have provided. In addition, we will take reasonable steps to assure that third parties to whom we transfer any personal information will provide sufficient protection of that information.

Review, Correction of Your Information and Requesting Removal from
Mailing Lists and Deactivating Your Account
If for any reason you are concerned that the personal information maintained by Ludia is not correct, or should you wish to be removed from our mailing list, please email privacy@ludia.com We will be happy to review, update or remove information as appropriate. We may still retain your information in our files however, to resolve disputes, enforce our user agreement, and due to technical and legal requirements and constraints related to the security, integrity and operation of our web sites.

By using this site, you signify your assent to the Ludia Privacy Policy. If you do not agree to this policy, please do not use any Ludia site. We reserve the right to make changes in this policy at any time. Please check the policy each time you use our web site to ensure you are aware of any changes in our privacy practices. Our privacy policy will indicate the date it was last updated. Also, if there is a substantive change in the way that we use your personal information, we will notify you via e-mail of the relevant changes. If you choose to opt-out of our changed practice, our e-mail will contain instructions on how to opt-out. Your continued use of our site will signify your acceptance of the changes to our Online Privacy Policy.

Last revision 20 December 2007.

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