Flickitup-Privacy Policy page

Privacy Policy

Flickitup.com Video strives to offer its visitors the many advantages of Internet technology and to provide an interactive and personalized experience. We may use Personally Identifiable Information (your name, e-mail address, ) subject to the terms of this privacy policy. We will never sell, barter, or rent your email address to any unauthorized third party. Period."

How we gather information from users

How we collect and store information depends on the page you are visiting, the activities in which you elect to participate and the services provided. For example, you may be asked to provide information when you register for access to certain portions of our site or request certain features, such as newsletters or when you make a purchase. You may provide information when you participate in sweepstakes and contests, message boards and chat rooms, and other interactive areas of our site. Like most Web sites, Flickitup.com Video also collects information automatically and through the use of electronic tools that may be transparent to our visitors. For example, we may log the name of your Internet Service Provider or use cookie technology to recognize you and hold information from your visit. Among other things, the cookie may store your user name and password, sparing you from having to re-enter that information each time you visit, or may control the number of times you encounter a particular advertisement while visiting our site. As we adopt additional technology, we may also gather information through other means. In certain cases, you can choose not to provide us with information, for example by setting your browser to refuse to accept cookies, but if you do you may be unable to access certain portions of the site or may be asked to re-enter your user name and password, and we may not be able to customize the site's features according to your preferences.

What we do with the information we collect

Like other Web publishers, we collect information to enhance your visit and deliver more individualized content and advertising. We respect your privacy and do not share your information with anyone.

Aggregated Information (information that does not personally identify you) may be used in many ways. For example, we may combine information about your usage patterns with similar information obtained from other users to help enhance our site and services (e.g., to learn which pages are visited most or what features are most attractive). Aggregated Information may occasionally be shared with our advertisers and business partners. Again, this information does not include any Personally Identifiable Information about you or allow anyone to identify you individually.

We may use Personally Identifiable Information collected on Flickitup.com Video to communicate with you about your registration and customization preferences; our Terms of Service and privacy policy; services and products offered by Flickitup.com Video and other topics we think you might find of interest.

Personally Identifiable Information collected by Flickitup.com Video may also be used for other purposes, including but not limited to site administration, troubleshooting, processing of e-commerce transactions, administration of sweepstakes and contests, and other communications with you. Certain third parties who provide technical support for the operation of our site (our Web hosting service for example) may access such information. We will use your information only as permitted by law. In addition, from time to time as we continue to develop our business, we may sell, buy, merge or partner with other companies or businesses. In such transactions, user information may be among the transferred assets. We may also disclose your information in response to a court order, at other times when we believe we are reasonably required to do so by law, in connection with the collection of amounts you may owe to us, and/or to law enforcement authorities whenever we deem it appropriate or necessary. Please note we may not provide you with notice prior to disclosure in such cases.

Affiliated sites, linked sites and advertisements

Flickitup.com Video expects its partners, advertisers and affiliates to respect the privacy of our users. Be aware, however, that third parties, including our partners, advertisers, affiliates and other content providers accessible through our site, may have their own privacy and data collection policies and practices. For example, during your visit to our site you may link to, or view as part of a frame on a Flickitup.com Video page, certain content that is actually created or hosted by a third party. Also, through Flickitup.com Video you may be introduced to, or be able to access, information, Web sites, features, contests or sweepstakes offered by other parties. Flickitup.com Video is not responsible for the actions or policies of such third parties. You should check the applicable privacy policies of those third parties when providing information on a feature or page operated by a third party.

While on our site, our advertisers, promotional partners or other third parties may use cookies or other technology to attempt to identify some of your preferences or retrieve information about you. For example, some of our advertising is served by third parties and may include cookies that enable the advertiser to determine whether you have seen a particular advertisement before. Other features available on our site may offer services operated by third parties and may use cookies or other technology to gather information. 21 st Century Video does not control the use of this technology by third parties or the resulting information, and is not responsible for any actions or policies of such third parties.

You should also be aware that if you voluntarily disclose Personally Identifiable Information on message boards or in chat areas, that information can be viewed publicly and can be collected and used by third parties without our knowledge and may result in unsolicited messages from other individuals or third parties. Such activities are beyond the control of Flickitup.com Video and this policy.

Children

Flickitup.com Video does not knowingly collect or solicit Personally Identifiable Information from or about children under 13 except as permitted by law. If we discover we have received any information from a child under 13 in violation of this policy, we will delete that information immediately

We use third-party advertising companies to serve ads when you visit our website. These companies may use information (not including your name, address, email address or telephone number) about your visits to this and other websites in order to provide advertisements about goods and services of interest to you. If you would like more information about this practice and would like to know your options in relation to·not having this information used by these companies, SEE BELOW

NETWORK ADVERTISING INITIATIVE

SELF-REGULATORY PRINCIPLES

FOR ONLINE PREFERENCE MARKETING

BY NETWORK ADVERTISERS

I. Network Advertising Initiative ("NAI") Overview

A. Network advertisers will adhere to the Online Privacy Alliance ("OPA") Privacy Policies

Guidelines for personally identifiable information.

B. Network advertisers will not use sensitive personally identifiable data for online preference

marketing.

C. Network advertisers will not, without prior affirmative consent ("opt-in"), merge

personally identifiable information with information previously collected as non-

personally identifiable information.

D. Network advertisers will provide consumers with robust notice and choice regarding

the merger of personally identifiable information with non-personally identifiable

information collected on a going forward basis for online preference marketing.

E. Network advertisers will not use personally identifiable information ("PII") consisting of PII

collected offline merged with PII collected online for online preference marketing unless

the consumer has been afforded robust notice and choice about such merger before it

occurs.

F. Network advertisers will require Web publishers with which they have contractual

relationships to provide notice and choice regarding the collection of non-personally

identifiable information for online preference marketing.

II. NAI's Statement of Purpose

The following principles were developed by the signatories to this Network Advertising

Initiative ("NAI") to guide business practices with respect to online advertising services

delivered by Internet network advertisers (hereinafter "network advertisers"). NAI companies

represent the vast majority of business-to-business, third-party network advertising companies

that serve commercial Web sites. Network advertisers facilitate Web advertising through ad

serving, hosting and ad sales services on the Web. For a Web site visitor, network advertisers

provide advertisements that are more likely to be of interest and eliminate duplicative

advertising. For a Web advertiser, network advertisers' services allow advertisers to reach

cost-effectively the audience most likely to be interested in a product or service.

Network advertisers believe that, just as they play an important role in electronic

commerce itself, they can play an important role in increasing consumer trust and confidence

in electronic commerce. To that end, network advertisers are committed to educating

consumers about the services they provide, enhancing consumers' ability to control the use of

information generated during use of the Internet, and working with their corporate customers

and clients to create an environment of trust that fosters protection for consumers' privacy

online and in electronic commerce.

NAI companies are among the leading providers of solutions for Web network

advertising products and services, such as banner advertising. Network advertisers in general

provide a variety of services to Web sites; chief among them is delivering advertising that is

tailored to demonstrated or predicted consumer characteristics or preferences. The collection

and use of data by network advertisers to understand consumer preferences is often called

"Profiling," but which is more accurately termed online preference marketing ("OPM"). OPM,

as used herein, is a process used by network advertisers whereby data is typically collected

over time and across Web pages to determine or predict consumer characteristics or

preferences for use in ad delivery on the Web. The OPM process can use non-personally

identifiable information or a combination of personally identifiable information and non-

personally identifiable information.

Effective Internet advertising is fundamental to the accessibility and dynamism of this

revolutionary medium. Advertising underwrites the rich variety of online content choices

available to consumers at no cost or at a far lower cost than would otherwise be possible. By

delivering customized advertising, network advertisers offer substantial benefits for consumers

and the advertiser. In addition, many small and emerging Web companies depend on network

advertisers to compete against more well-established companies and their Web sites.

Effective Internet advertising thus helps to maintain the low barriers to entry that have played a

crucial role in the robust competition and innovation that have fueled this medium.

Network advertisers realize that they have a strong interest in informing consumers of

their business practices because the network advertisers' practices and services are generally

not obvious to the consumer. Network advertisers commit to providing consumers notice and

choice about OPM. Network advertisers commit to the fair information practices articulated by

the Online Privacy Alliance ("OPA") (www.privacyalliance.org) for personally identifiable

information and to the consumer-friendly data management practices described below for non-

personally identifiable information. Adherence to these principles will provide consumers with

meaningful notice, appropriate opportunity to exercise choice, and increased confidence in

online advertising. To this end, and as described herein, network advertisers will: (1)

undertake business and consumer outreach; (2) disclose their data collection and use

practices; (3) provide consumers with effective notice and the ability easily to opt-out of the use

of data for OPM purposes; and (4) decline to merge personally identifiable information with

information previously collected as non-personally identifiable information, without the

consumer's prior affirmative consent ("opt-in") to any such merger.

III. Online Privacy Alliance ("OPA") Principles and Personally

Identifiable Information

Network advertisers affirm and agree to abide by the Guidelines for Online Privacy

Policies set forth by the OPA at: http://www.privacyalliance.org/resources/ppguidelines.shtml/.

Personally Identifiable Information (PII) is data used to identify, contact or locate a person,

including name, address, telephone number, or E-mail address. As it relates to PII specifically,

the OPA states that its member companies must abide by the principles of notice, choice,

access and security as defined by the OPA Guidelines.

IV. Principles for Online Preference Marketing by Network Advertisers

OPM, as used herein, is a process used by network advertisers whereby data is

typically collected over time and across Web pages to determine or predict consumer

characteristics or preferences for use in ad delivery on the Web. The OPM process can use

non-personally identifiable information or a combination of personally identifiable information

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with non-personally identifiable information. OPM does not refer to the use of data by network

advertisers for Ad Delivery and Reporting (see infra at p. 6). OPM excludes the use of data

provided by a Web site or advertiser directly to the network advertiser and used by that

network advertiser for Internet advertising solely on behalf of such Web site or advertiser.

A. General OPM Safeguards

1. Sensitive Data - Network advertisers shall neither use personally

identifiable information about sensitive medical or financial data, sexual

behavior or sexual orientation, nor social security numbers, for OPM.

2. Collection from Reliable Sources - Network advertisers shall

make reasonable efforts to ensure that they are obtaining data for OPM from

reliable sources.

3. Protection of Collected Data - Network advertisers shall make

reasonable efforts to protect the data they collect for OPM from loss, misuse,

alteration, destruction or improper access.

4. Dissemination Restrictions - Network advertisers shall

contractually require that any third parties to which they provide PII data

adhere to, at a minimum, OPA Guidelines. For third parties to which they

provide non-aggregate non-personally identifiable data to be merged with PII

data possessed by the third party, network advertisers shall contractually

require those transferees to adhere to these NAI Self-Regulatory Principles

(unless the non-personally identifiable data is the proprietary data of the

particular third-party publisher or advertiser).

B. Non-Personally Identifiable OPM by Network Advertisers

1. OPM Using Non-Personally Identifiable Information

(Non-PII): Non-PII used for OPM by network advertisers is not linked to a

particular person and is typically compiled from click stream information as a

browser moves among different Web sites (or a single Web site) serviced by

a network advertiser or from information provided to a network advertiser by

third parties (so long as that information is not personally identifiable to the

network advertiser).

(a) Notice and Choice Policy - Network advertisers that

collect or use Non-PII online for OPM shall post clear and

conspicuous notice on the network advertiser's Web site about their

data collection and use practices, and each shall give consumers an

opportunity to opt out of OPM by that network advertiser. The opt-

out may be accessed at a designated location on the network

advertiser's Web site (which can be co-located with the company's

privacy policy) or through the gateway educational Web site

designed and supported by NAI companies for that purpose.

(www.networkadvertising.org)

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(b) Notice by Network Advertisers - Such notice by the

network advertiser shall include, without limitation, clear descriptions

of the following:

-Profiling activities undertaken by the network advertiser;

-what types of Non-PII are collected by the network advertiser;

-how such Non-PII will be used by the network advertiser

including transfer, if any, of non-aggregate data to a third party;

-procedures for opting out of such data use (including a

description of the circumstances that would make it necessary

for a consumer to renew their opt-out, such as when a

consumer changes computers, changes browsers, or deletes

relevant cookies); and

- the approximate length of time that such Non-PII will be retained

by the network advertiser.

(c) Choice -The opportunity to opt-out of OPM using Non-PII may be

accessed at a designated location on the network advertiser's Web

site (which can be co-located with the company's privacy policy) or

through the gateway educational Web site designed and supported

by NAI companies for that purpose. (www.networkadvertising.org)

(d) Customer Compliance -- Network advertisers, when

entering into a contract with publisher customers for services which

include OPM, shall require that their customers: (1) post a privacy

policy that clearly and conspicuously discloses (a) the customer's

use of the network advertiser services for OPM; (b) the type of

information that may be collected by the network advertiser; and (c)

the consumer's ability to choose not to participate; and (2) provide a

clear and conspicuous link to the Non-PII Opt-Out Page of the NAI

gateway educational site (or, if only one network advertiser services

the Web site, the customer may instead provide a link to a screen at

the site of the network advertiser with which it does business that

has on that screen either the ability to opt-out or a hyperlink to the

ability to opt-out) . A network advertiser "services" a Web site when

it collects Non-PII or PII data from that Web-site for the purposes of

OPM. If network advertisers know or have reason to know that a

publisher customer is in breach of the above-specified contractual

requirement, then the network advertiser will make reasonable

efforts to enforce the contract.

In the absence of a contractual relationship, as part of NAI's

business outreach efforts, network advertisers shall make

reasonable efforts to ensure that publishers: (1) post a privacy policy

that discloses (a) network advertiser OPM on their Web site; (b) the

type of information that may be collected by the network advertiser;

and (c) the consumer's ability to choose not to participate; and (2)

provide a link to either the network advertiser or the NAI gateway

educational site.

Appendix A provides a sample of acceptable notice language for

publisher customers to disclose OPM using Non-PII. (Samples are

illustrative only and do not establish a "one-size-fits-all" requirement.)

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At the NAI gateway educational site, the consumers who choose not

to participate will be afforded the ability readily to opt-out at a central

Web page. Appendix B provides a "screen shot" of the proposed

design of the NAI Non-PII Opt-Out Page. This page is being

designed to ensure that consumers will easily find a concise

description of the privacy practices of each of the NAI companies

and have the ability readily to opt-out from the OPM practices of

each NAI company at a central Web page. The Non-PII Opt-Out

Page is being designed so that its length will approximate two

conventional screen-lengths.

(e) Compliance with Laws and Regulations - Network

advertisers shall comply with all applicable laws and regulations

governing the collection and use of Non-PII.

(f) Change in Policy - If a network advertiser materially changes

its data collection and use policy, prior notice will be posted on its

Web site. Any such material change in policy shall apply only to

information collected following the change in policy. Information

collected prior to the material change in policy shall continue to be

governed by the policy in effect at the time the information was

collected, unless the consumer provides affirmative consent ("optin") to the previously collected information being governed by the

new policy.

2. Ad Delivery and Reporting

(a) Apart from OPM, some Non-PII is used for ad delivery and reporting

purposes ("Ad Delivery and Reporting"). Ad Delivery and Reporting

includes: (1) providing a specific advertisement based on a

particular type of browser or time of day; (2) statistical reporting in

connection with the activity on a Web site; (3) tracking the number of

ads served on a particular day to a particular Web site; and (4) other

non-OPM uses. Data used for Ad Delivery and Reporting can

include: type of browser, operating system, domain name, day and

time of visit, page(s) visited and search term (if any) and other data

(not including the use of clickstream data across Web sites for OPM)

that is not used to identify, contact or locate an individual. Web sites

are not required to disclose the collection of Non-PII for Ad Delivery

and Reporting purposes. To help promote public understanding of

these issues and of the different categories of information use,

however, network advertisers agree to disclose on the network

advertiser's Web site in a clear and conspicuous manner their Ad

Delivery and Reporting practices, including the type of information

collected and maintained for Ad Delivery and Reporting, and how

long that information is maintained.

(b) If a consumer elects to opt out of Non-PII OPM, Non-PII data

regarding that consumer's browser will be used by the network

advertiser only for Ad Delivery and Reporting purposes.

C. Merger of Non-PII with PII by Network Advertisers for OPM

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1. Network advertisers will not merge personally identifiable

information with information previously collected as Non-

PII, without the consumer's prior affirmative consent

("opt-in") to any such merger.

(a) Notice and Choice Policy - This category of merger of

Non-PII with PII by network advertisers for OPM applies to any OPM

activity that links previously collected Non-PII (as defined in sec.

IV.A.1) to personally identifiable information. PII is data used to

identify, contact, or locate a person, including but not limited by

name, address, telephone number, or E-mail address. Network

advertisers or organizations acting on their behalf will not merge

previously collected Non-PII with PII for OPM without the consumer's

prior affirmative consent ("opt-in") to any such merger.

(b) Notice by Network Advertisers -Such notice shall

include, without limitation, clear descriptions of the following:

-Profiling activities undertaken by the network advertiser;

-what types of PII and Non-PII previously collected will be

merged by the network advertiser;

-how the merged information will be used by the network

advertiser, including transfer, if any, to a third party;

-procedures for opting in to such data use (including a description

of the circumstances that would make it necessary for a

consumer to renew their opt-in, such as when a consumer

changes computers, changes browsers, or deletes relevant

cookies); and

- the approximate length of time that such information will be

retained by the network advertiser.

(c) Customer Compliance -When the PII is to be merged with

Non-PII that was previously collected, the consumer must give

affirmative consent ("opt-in") to such merger at the time such PII is

collected online or, if collected offline, first used online.

Appendix A provides a sample of acceptable notice language at the

time and place that PII is collected online for purposes of merger with

previously collected Non-PII. (Samples are illustrative only and do

not establish a "one-size-fits-all" disclosure requirement.)

Appendix C provides a sample "mock-up" of notice provided at the

time and place of collection of PII for purposes of merger with

previously collected Non-PII. (This sample is illustrative only.)

(d) Notwithstanding the above affirmative consent ("opt-in") option,

network advertisers will not merge Non-PII with PII if that Non-PII

was collected pursuant to a privacy policy that stated that such

information would never be merged with PII.

(e) Network advertisers will collect PII for OPM purposes only from the

sites of publisher customers with which they have contractual

relationships. If network advertisers know or have reason to know

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that a publisher customer is in breach of the above-specified

contractual requirement for Customer Compliance, then the network

advertiser will make reasonable efforts to enforce the contract.

(f) Access to PII - Network advertisers shall provide consumers

with reasonable access to PII and other information that is

associated with PII retained by the network advertiser for OPM uses.

2. Network advertisers will not merge PII with Non-PII

collected on a going forward basis (i.e., after the user

provides PII) for OPM unless the consumer has been

afforded robust notice and choice about such merger

before it occurs. This practice will be referred to as the

merger of PII with prospective Non-PII.

(a) Robust Notice and Choice Policy - This category of

merger of Non-PII with PII by network advertisers for OPM applies to

any OPM activity that links personally identifiable information to Non-

PII (as defined in sec. IV.A.1) collected on a prospective basis only.

Network advertisers or organizations acting on their behalf will not

merge prospective Non-PII with PII for OPM unless the consumer

has been afforded robust notice and choice about such merger

before it occurs. For notice to be robust, the consumer must be

afforded clear and conspicuous notice about the scope of the Non-

PII that would be made personally identifiable and how the Non-PII

will be used as a result of such merger.

(b) Network advertisers also will not use PII consisting of PII collected

offline merged with PII collected online for OPM purposes unless the

consumer has been afforded robust notice and choice about such

merger before it occurs.

(c) Notice by Network Advertisers -Such notice shall

include, without limitation, clear descriptions of the following:

-Profiling activities undertaken by the network advertiser;

-what types of PII and Non-PII will be merged by the network

advertiser;

-how the merged information will be used by the network

advertiser, including transfer, if any, to a third party;

-procedures for opting out of such data use (including a

description of the circumstances that would make it necessary

for a consumer to renew their opt-out, such as when a

consumer changes computers, changes browsers, or deletes

relevant cookies); and

- the approximate length of time that such information will be

retained by the network advertiser.

(d) Customer Compliance -When the PII is to be merged with

Non-PII that will be collected on a prospective basis only, the

consumer must be afforded a clear and conspicuous opportunity to

opt-out of such merger at the time and place such PII is collected

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online or, if collected offline, first used online. The notice at the time

and place of collection of the PII must disclose (a) that the PII is

shared with a network advertiser for purposes of OPM; (b) the type

of information that may be collected and linked by the network

advertiser; (c) the consequent loss or partial loss of anonymity to the

advertising company of future Web usage; and (d) the ability of the

consumer to choose not to participate. For purposes of merger of

PII with prospective Non-PII, the notice and ability to opt-out must be

provided above or before the button to submit the PII. For that

network advertiser, the opt-out shall be at least for the purpose

defined in the disclosure and shall occur either at the Web publisher

site, the network advertiser's Web site or at the Merger Opt-Out

Page of the NAI gateway educational site,

www.networkadvertising.org. Because consumers may not know for

which network advertiser they have opted out or whether they have

done so for the life of the browser, the consumer may also opt-out of

the merger of Non-PII and PII at the Merger Opt-Out Page of the NAI

gateway educational site, www.networkadvertising.org, at any

subsequent point in time. Once a user has opted out at the NAI

gateway educational site, the user has done so for the life of the

browser or until the user deletes the opt-out cookie.

Appendix A provides a sample of acceptable notice language at

the time and place that PII is collected online for purposes of

merger with prospective Non-PII. (Samples are illustrative only

and do not establish a "one-size-fits-all" disclosure requirement.)

Appendix B provides a "screen shot" of the proposed design of the

NAI Merger Opt-Out Page. This page is being designed to ensure

that consumers will easily find a concise description of the privacy

practices of each of the NAI companies that merge PII and Non-PII

and have the ability readily to opt-out from the OPM merger

practices of those NAI companies at a central Web page. The

Merger Opt-Out Page is being designed so that its length will

approximate two conventional screen-lengths.

Appendix D provides a sample "mock-up" of robust notice and

choice provided at the time and place of collection of PII for purposes

of merger with prospective Non-PII. The sample notice is clear and

conspicuous in the context of this particular Web-site mock-up. This

sample is illustrative only, because the Web sites on which such

notices will appear will be of infinite variety. However, for this

category of merger, all such opt-out notices in the screen presented

to the user shall be substantially similar in clarity and prominence to

this sample notice.

(e) Ad Delivery and Reporting -- Non-PII collected solely for

purposes of Ad Delivery and Reporting following a consumer's

election to opt out of the collection of data for OPM may not, under

any circumstances, be combined with PII.

(f) Change in Policy - If a network advertiser materially changes

its data collection and use policy, prior notice will be posted on its

Web site. Any such material change in policy shall apply only to

information collected following the change in policy. Information

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collected prior to the material change in policy shall continue to be

governed by the policy in effect at the time the information was

collected, unless the consumer provides affirmative consent ("optin") to the previously collected information being governed by the

new policy. For this consent to be effective, the consumer must be

advised clearly about the scope of the Non-PII that would be made

personally identifiable as a result of such merger.

(g) Network advertisers will collect PII for OPM purposes only from the

sites of publisher customers with which they have contractual

relationships. If network advertisers know or have reason to know

that a publisher customer is in breach of the above-specified

contractual requirement for Customer Compliance, then the network

advertiser will make reasonable efforts to enforce the contract.

V. NAI Educational Efforts Aimed at Businesses and Consumers

A. Business Outreach - NAI companies shall undertake to educate their

business customers about the data collection and use issues associated with Internet

advertising and services, the NAI Principles described herein, and the benefits of the

responsible flow of information.

B. Consumer Outreach - NAI companies shall undertake to educate consumers

about the data collection and use issues associated with Internet advertising on their

own Web sites and in the privacy statements of their customers. In addition, NAI has

established a Web site, located at http://www.networkadvertising.org/, in order to

facilitate consumer awareness and provide a convenient mechanism for consumers to

exercise choice regarding such data collection and/or use.

VI. Compliance

NAI members shall be obligated to implement these Principles within six (6) months of

the adoption of the Principles. However, the conditions on the merging of PII and Non-PII data

shall be effective immediately upon the release of these Principles. All future members of NAI

will be obligated to implement these Principles within six (6) months of joining NAI. However,

the conditions on PII and the merging of PII and Non-PII data shall be effective immediately at

the time the company joins NAI.

VII. Enforcement

NAI members agree to work with a Privacy Compliance Program that certifies third-

party ad serving and/or network advertisers to establish a Privacy Compliance Program that

will govern compliance with the NAI Principles for Online Preference Marketing by Network

Advertisers, and to join such a program, within six months of the adoption of the Principles.

The Privacy Compliance Program will include elements typical of a "seal" program,

including: random audits by the third-party enforcer; the ability of consumers to file complaints

and the third-party enforcer to investigate; for those network advertisers found not in

compliance, an opportunity to redress the shortcomings of a report by the third-party enforcer;

and, finally, if the network advertiser remains not in compliance after a reasonable opportunity

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to redress, the possibility of sanctions, including revocation of the seal and making such action

publicly available at some designated central point as well to the Federal Trade Commission.

If no third party enforcement program that certifies third party ad serving and / or

network advertisers is in place within six months of the adoption of the Principles, the NAI

members will use independent audits of their practices to certify compliance with the NAI

Principles. The summary report of such audits shall be made publicly available at the NAI

Gateway Educational site.

VIII. Amendments to Principles

These principles may be amended by a four-fifths vote of the signatories to this

document after thirty days prior written notice has been provided to the Privacy Compliance

Program, the Federal Trade Commission and the Commerce Department.

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APPENDIX A

SAMPLE NOTICE LANGUAGE

SAMPLES ARE ILLUSTRATIVE ONLY AND DO NOT ESTABLISH

A "ONE-SIZE-FITS-ALL" STANDARD

Within the categories of Non-PII and Merger of PII with Non-PII, the business models employed

by a third-party advertiser can vary significantly. The key facts that must be disclosed to consumers in

an appropriate notice disclosure, therefore, can also vary.

As a consequence, one should expect that clear and factually accurate notice disclosures can be

narrowly tailored depending on the actual business model employed in any specific case. Adequate

notice disclosures may therefore vary across advertising company and Web publisher site. So long as

the notice disclosure is accurate, it need not be overbroad nor track the notice language that may be

appropriate in another setting. Nevertheless, in all instances, notice must be factually accurate and

objectively lead the reader to know about certain key aspects of the profiling practices of the third-party

advertiser, as well as the consumer's ability to choose not to participate.

Sample Notice Language for Non-PII

We use third-party advertising companies to serve ads when you visit our Web site. These

companies may use information (not including your name, address email address or telephone

number) about your visits to this and other Web sites in order to provide advertisements about goods

and services 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, click here.

Sample Notice Language for Merger of PII and (Previously Collected)

Non-PII

Please click here to allow us to share this information with our third party advertising company so

it can market more effectively to you. Because our advertising company may link your name, address

and e-mail address to your past Web usage, some of your past and future Web activity will no longer

be anonymous to them. To learn more about this practice, click here.

Sample Notice Language for Merger of PII and (Prospective) Non-PII

We share this information with our third-party advertising company in order to market more

effectively to you. Our advertising company may link your name, address and e-mail address to other

information which they collect, such as past purchase information and your future Web usage from

other sites. By providing your personal information here, some of your future Web usage will no longer

be anonymous to our advertising company. To learn more about this practice, click here. To choose

not to have this information used by our third party advertising partner, click here.

Page 11

APPENDIX B

NAI GATEWAY SITE: ABILITY READILY TO OPT-OUT

FROM A SINGLE WEB LOCATION

Consumer Opt-Out Page

For Non-Personally Identifiable (Anonymous)

Online Preference Marketing

The eight companies listed below collect non-personally identifiable (anonymous) data about your

browser's Web activity to serve ads tailored to your interests. You may opt out of any of these

companies' anonymous data collection by checking the box after reading a summary of the company's

privacy policy.

Adforce is xxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxx xxxx xxxxxxxxxxx xxxxxxxxxxx xxxxxxxx

xxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxx xxxx xxxxxxxxxxx xxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxx

xxxxxxxxxxxxxxxxxxxx xxxx xxxxxxxxxxx xxxxxxxxxxx xxxxxxx xxxx xxx xxx xxxxxxxx xxxxxxxxxxxxxx

xxxx xxxxxxxxxxx xxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxx xxxxxxxx xxxxxx xxxxx xxxx xxxxxxxxxxx

xxxxxxxxxxx xxxxxxxx xxxxxxxxxxxxx xxxxx xxxxx xx xxxxxxxx xxxx