1. 1. A Special Note About Children

   Children under eighteen years of age are prohibited from using Our Websites or any of our services. We ask that children not submit information to us.

2. 2. About Information FFN Collects

   During the registration process for any of the FFN Websites, you may provide us with certain Personally Identifiable Information ("PII") including, but not limited to, your name, address, email address, and credit card and bank information.

   FFN Websites also use "cookies" to store and sometimes track information to make your online experience easier and more personalized. Cookies are small pieces of data that are stored by a user's web browser on the user's hard drive. Cookies may record information a user accesses on one webpage to simplify subsequent interactions with that website by the same user, or to use the information to streamline the user's transactions on related webpages. Cookies make it easier for a user to move from webpage to webpage and to complete transactions over the Internet.

   Most major web browsers are set up so that they will initially accept cookies, but you may modify your computer's preferences to issue you an alert when a cookie is downloaded, or to disable the ability of third parties to download a cookie to you. If you choose to reject all cookies, there are areas of FFN Websites that may not function properly. You may obtain further information about cookies and how they function at: http://en.wikipedia.org/wiki/HTTP_cookie.

   We may also use standard Internet technology, such as web beacons or 1x1 "gifs" and other similar technologies (collectively "Pixel Tags"), to track your use of Our Websites. A Pixel Tag is an electronic image, often a single pixel (1x1), that is ordinarily not visible to Site visitors and may be associated with cookies on the visitors' hard drives. We also may include Pixel Tags in advertisements or promotional or other e-mail messages, or to determine whether messages have been opened and acted upon. The information enables us to customize the services we offer.

   If you send us personal correspondence, such as emails or letters, or if other FFN Website users or third parties send us correspondence about your activities or postings on any FFN Website, we may collect such information into a file that is accessed only by authorized FFN personnel or representatives. We may also collect other Members' comments about you.

   On some of Our Websites, you may choose to use our referral service to tell a friend or friends about us. In this case, we will ask you for your friend's name and email address and email your friend a invite to him or her to visit Our Website. We maintain this information for the sole purpose of sending email and tracking the status of the referral. Your friend or friends may contact us by email at privacy@ffn.com to request that we remove their email address from our records.

3. 3. Our Use of Your Personally Identifiable Information

   We use your PII internally to improve our marketing efforts, analyze FFN Website usage, improve our content and product offerings and customize Our Websites' content and layout. We believe these uses allow us to improve Our Websites and better tailor your online experience.

   We may also use your PII to deliver information that, in some cases, is targeted to your interests, such as banners and promotions.

   We also send you periodic informational updates via email.

   We may use PII to resolve disputes, troubleshoot problems and enforce any agreements, policies and rules governing the use of FFN Websites.

4. 4. Our Disclosure of Your Information

   We DO NOT sell or rent any of your PII to third parties for marketing purposes without your permission. We do, however, provide your PII to our service providers (e.g., credit card processing companies, billing services) as reasonably necessary or appropriate to provide services on the FFN Websites.

   We do disclose information in the aggregate to advertisers and for other marketing and promotional purposes. However, in these situations, we DO NOT disclose information in any form that could be used to identify you personally such as your FFN Website password, credit card number, and bank account number.

   In response to compulsory (required) governmental and/or third party inquiries, we may disclose PII to comply with a court order, subpoena, and search warrant. We expressly reserve the right to disclose your PII when we have a good faith belief that disclosure is necessary to protect our rights, or to enforce our agreements, policies, and rules governing your use of the FFN website, or to cooperate voluntarily with law enforcement inquiries.

   We may share or transfer some or all of your PII among our FFN family of companies, or to one or more non-FFN family entities that acquire some or all of the business in which that PII is used or maintained.

5. 5. Your Use of FFN Websites' Members' Information

   You may not use another FFN Websites' Members' information, whether private or not, for commercial purposes, to spam, to harass, or to make unlawful threats. We reserve the right to terminate those who misuse other Members' information or who otherwise violate any user agreements, policies, or rules governing the use of any FFN Website.

6. 6. Do Not Disclose Your PII or Password

   Please DO NOT post, share or disclose in public forums, e.g., chat rooms, blogs, any PII that you do not wish other Members to know. We encourage you to ask questions before you disclose your PII to others. Similarly, you should never disclose or share your password with anyone else. If you lose control of your password, you may lose substantial control over your PII and may be subject to legally binding actions taken on your behalf. If your password has been compromised for any reason, you should immediately change your password and/or contact us at privacy@ffn.com.

7. 7. Reviewing, Changing or Removing Your Personally Identifiable Information

   Once you register, you will be able to review and change much of your PII including, but not limited to:

   • Your email address
   • Your city, state, ZIP or other postal code, country
   • Your password
   • Your profile

   Please promptly update your information by logging in to your account and following the screen prompts. We strongly urge you to change your password periodically to help reduce the risk of unauthorized access to your account information.

   Upon your request, we will remove your credit card number and credit card expiration date from our main databases. To make this request, email us at privacy@ffn.com. Despite the foregoing and even though you have requested us to remove information, we will retain in our files certain data such as credit card information used to resolve disputes, troubleshoot problems, comply with credit card merchant banking and association agreements, enhance security, reduce fraud, comply with Federal and State law, or to enforce any agreements, policies, and rules governing your use of FFN Websites. Removed information also may persist in backup copies and/or other users' caches. For example, any information exchange with other Members may remain in their e-mail boxes, computer caches, or instant message archive. Whether your exchanged information is kept by another Member is beyond the control of any FFN Websites. Any such information retained by FFN or under its control is not available to third parties except as provided in this Policy.

8. 8. Third Party Collections of Information; Ad Tracking

   This Policy only addresses the use and disclosure of information we collect from you. To the extent that you disclose your PII to others while using Our Websites or other sites throughout the internet, different rules may apply to its use, maintenance, or disclosure. FFN does not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable.

   We may use third party companies to serve ads on our behalf. These companies may employ cookies or Pixel Tags to measure advertising effectiveness.

9. 9. Security

   FFN Websites use reasonable security measures to help protect and prevent the loss, misuse, and alteration of the information under our control. We use industry standard efforts, such as firewalls, to safeguard your PII information. While "perfect security" does not exist on the Internet, or elsewhere, our technical staff works hard to help ensure your secure use of our services.

10. 10. EU Safe Harbor Privacy Framework Participation

    (Please note: this section applies to European Union residents only.) We participate in the EU Safe Harbor Privacy Framework as set forth by the United States Department of Commerce. As part of such participation, we have agreed to Better Business Bureau ("BBB EU Safe Harbor") dispute resolution for disputes relating to our compliance with the Safe Harbor Privacy Framework. If you have complaints regarding our compliance with the Safe Harbor, you should contact us by email at privacy@ffn.com. If contacting us does not resolve your complaint, you may raise your complaint by emailing BBB EU Safe Harbor at eusafeharbor@council.bbb.org.

11. 11. Location

    FFN Websites are located in the United States. If you are visiting Our Websites from outside the United States, you are on notice that your information may be transferred to, stored, and processed in the United States. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country.

12. 12. Update/Delete/Opt-Out

    You have the following choices to modify or delete your PII from our database:

    * Send an email to privacy@ffn.com
    * Log in with your password and modify/delete your profile
    * Send a snail mail to Friendfinder Networks Inc. at 220 Humboldt Ct, Sunnyvale, CA 94089, United States, Attn: Privacy
    * Call us at (408)702-1040
13. 13. Revisions to this Privacy Policy

    FFN reserves its right, in their sole and absolute discretion, to revise, amend, modify or revoke this Privacy Policy at any time and in any manner to the fullest extent permitted by law. Changes to this Policy will be effective by posting revisions on the FFN Websites.

FRIENDFINDER NETWORKS INC. PRIVACY POLICY Effective on: 8/27/09