Our Privacy Commitment
Vivendi Games, Inc., is a global leader in multi-platform interactive entertainment. Vivendi Games and its subsidiary companies (collectively "Vivendi Games") has developed its websites with the goal of creating an enjoyable experience for all users. This Kids Privacy Policy is designed to answer your questions regarding our privacy policies and principles concerning kids under the age of 13. We take kids' privacy and safety online very seriously, and strive to constantly improve our practices.

Building on our general Privacy Policy, we recognize the need to provide additional privacy protections when children visit the sites on which this Kids' Privacy Policy is posted. We explain those additional protections in this Kids Privacy Policy.

The Children's Online Privacy Protection Act ("COPPA") requires that we inform parents and legal guardians about how we collect, use, and disclose personal information from children under 13 years of age; and that we obtain the verifiable consent of parents and guardians for children under 13 years of age to use certain features of our Web sites. Below we explain how we do that for these "kids." Also, when we use the term "parent" below, we mean to include legal guardians.

This certification seal shown on this page confirms that Vivendi Games is a member in good standing of ESRB's Privacy Online Program. ESRB's Privacy Online Program is designed to ensure that our website's information disclosure practices are responsible and appropriate. To protect your privacy, we have voluntarily undertaken this privacy initiative and all of our websites have been reviewed and certified by ESRB Privacy Online to meet established online information collection and use practices. As part of this privacy program, ESRB independently audits our websites, and administers other enforcement and accountability mechanisms.

Table of Contents
Q1. What types of information do we collect about kids?
Q2. How do we use and share the personally identifiable information that we collect from kids?
Q3. How do we notify and obtain consent from parents for the collection of personal information from their kids?
Q4. How can parents access, change or delete personally identifiable information about their kids?
Q5. What kinds of security measures do we take to safeguard kids' personally identifiable information?
Q6. How will we notify parents if our Kids' Privacy Policy changes?
Q7. Who do guests contact with questions or concerns about our Kids' Privacy Policy?

Q1: What types of information do we collect about kids?

A1: Kids can surf Vivendi Games' websites, view content, and enjoy many features without any personal information being collected. We don't collect personal information from kids while they use our sites unless they voluntarily register on Vivendi Games' sites.

All of the personal information we receive comes directly from our guests. We collect personal information from kids to:

1. register for our website
2. subscribe to our newsletter
3. participate in polls, surveys, and questionnaires
4. receive customer or technical support

1. name
2. email address
3. mailing address
4. telephone number; and
5. name and e-mail address of the child's parent

Note that all commercial websites directed to children under 13 are prohibited by U.S. law from conditioning a kid's participation in an online activity on the kid's providing more personal information than is reasonably necessary.

Some areas of our website may offer features that allow kids to submit personal information (e.g., email address) without first disclosing their age or obtaining verifiable parental consent. These areas of our website offer services in a way that doesn't require prior verifiable parental consent.

Finally, we may collect demographic information about a kid. For example, if a kid participates in a survey, we may collect those responses. Among them, we may collect age, gender, hobbies, and interests or other demographic information about gaming and preferences. We also use some passive technologies, including cookies and web beacons, to monitor traffic on our websites. This demographic information may be associated with a child's personal information.

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Q2: How do we use and share the personally identifiable information that we collect from kids?

A2: We may collect personal information from parents to allow kids to participate in certain activities offered on our websites and within our kids' subscription products.

Operational Use. We may use your child's information to allow your child to send questions or request customer support or request promotional information about new products and features and to participate in polls, surveys, or questionnaires. We also will use that information to send your child email and messages with promotional information about new products and features, special offers, and other interesting events concerning new products, events and other information about Vivendi Games.

Generally, parents have the option of allowing Vivendi Games to collect and use their child's personal information without consenting to the disclosure of their child's personal information to third parties.

If a parent allows us to collect personal information about their kid, we may link certain information collected through technology (e.g. IP address) to that personal information.

We may use the information that we collect from and about kids for our business purposes, including record-keeping, transaction fulfillment, and marketing. The contact information gathered from a child is used to obtain consent from their parents.

After registration, contact information may also be used to notify users of promotional activities such as contests, sweepstakes, newsletters, or new products, or functional changes to our website or privacy policy. Finally, we may use personal and demographic information for our internal marketing and study ways to better improve our services.

Vendors. We may share kids' personal information with outside entities hired to assist with internal website support operations (e.g., online product fulfillment, email services, or technical support). These entities have agreed to maintain confidentiality, security, and integrity of all the personal information belonging to kids obtained from us.

We do not share any information about a kid with any third parties unless the disclosure is reasonably necessary to:

1. comply with law, including, for example, to comply with a court order or subpoena;
2. enforce our Terms of Service, or site or game/promotion rules;
3. in connection with the purchase or sale of assets, a merger, reorganization, bankruptcy or similar corporate transaction; or
4. protect the safety and security of our Guests and our websites.

Q3: How do we notify and obtain consent from parents for the collection of personal information from their kids?

A3: We use PrivoLock's (www.privo.com) registration system to safely register child users. Privo specializes in designing child registration and verifiable parental permission systems. The process is free and secure.

When a child under the age of 13 attempts to register on our website, we ask a parent or guardian to set up an account. This helps us reasonably secure that the person providing parental consent is a verified adult. Among other benefits, this parent account enables parents or guardians to better manage a child's online experiences on our websites, and any other PrivoLock-enabled website.

After a parent or guardian grants us permission to register his or her child, the child will receive an activation e-mail from PrivoLock. Once activated, PrivoLock will securely redirect the child to the proper registration area on our sites. During the registration process, parents may choose to allow us to send promotional newsletters or updates to the child.

If the parent ignores or refuses to register their child, we will delete all contact information within a reasonable time from our database. If the parent permits the registration, their child will be granted access to the features described in the notice.

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Q4: How can parents access, change or delete personally identifiable information about their kids?

A4: At any time, a parent can contact us to access, update, or delete the personal information that we have collected from his or her child. Given the sensitive nature of this information, parents can manage their child's information using our "Parents Manage Accounts" web area or PrivoLock's account management tool. In this area, you can change permissions, access personal information belonging to parent or child, update your information, or ask us to delete it. To protect your child user's sensitive information, we will take reasonable steps to verify the parent's identify before disclosing this personal information.

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Q5: What kinds of security measures do we take to safeguard kids' personally identifiable information?

A5: We take the security and confidentiality of kids' information very seriously. We have implemented technical, administrative, and physical security measures to protect kids' personal information from unauthorized access and improper use. From time to time, we review our security procedures to consider appropriate new technology and methods. However, please understand that, despite our best efforts, no security measure is perfect or impenetrable.

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Q6: How will we notify parents if our Kids' Privacy Policy changes?

A6: We may amend our Kids' Privacy Policy at any time. We will provide parents notice by e-mail of any material changes in the way we intend to collect, use, or share kids' personal information. Please note that, at all times, parents should update their personal information to provide us current e-mail addresses. We will apply material changes in our Kids' Privacy Policy only in conformance with applicable law, including any applicable provisions of COPPA that require parental consent.

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Q7: Who do guests contact with questions or concerns about our Kids' Privacy Policy?

A7: If you have questions or wish to send us comments about this Privacy Policy, please send an e-mail with your questions or comments to privacy@vgames.com or write us:

Vivendi Games Privacy Policy
Attn.: Privacy Policy Administrator
6060 Center Drive, 5th Floor
Los Angeles, CA 90045
(310) 431-4554

Last updated May 1, 2007
© 2007 Vivendi Games, Inc.