Orbitz Games Privacy Policy Effective September 4, 2008 Your privacy is very important to Orbitz, LLC ("we" or "us"). This Privacy Policy describes the principles and practices that apply to Personal Information (defined below) collected from users of this Site ("you"), in telephone or e-mail communications, or in interviews, surveys, sweepstakes, contests, or raffles. Simply put: We will not collect Personal Information without your knowledge and permission; We will not knowingly disclose your Personal Information to third parties, except as provided in this Privacy Policy; We will allow you to view, correct or remove your Personal Information; and We will take reasonable steps to protect the security of the Personal Information we collect from you. Your California Privacy Rights Under California Law, California residents have the right to request in writing from businesses with whom they have an established business relationship, (1) a list of the categories of personal information, such as name, address, e-mail address, and the type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties' direct marketing purposes, and (2) the names and addresses of all such third parties. To request the above information, please e-mail us at: customerservice@orbitz.com, or write to us at: Customer Service, Orbitz, LLC, 500 West Madison Street, Suite 1000, Chicago, IL 60661 with a reference to California Disclosure Information. We will respond to such written requests within 30 days following receipt at the e-mail or mailing address stated above. If we receive your request at a different e-mail or mailing address, we will respond within a reasonable period of time, but not to exceed 150 days from the date received. Please note that we are only required to respond to each customer once per calendar year. The remainder of this policy describes our Personal Information handling practices in detail. 1. Definitions 2. Consent 3. What Personal Information we collect 4. How we use the information we collect 5. To whom we disclose Personal Information 6. How we retain and store Personal Information 7. How we protect Personal Information 8. How to access, modify or delete your Personal Information 9. Privacy 10. Changes to the Privacy Policy 11. Disputes 12. Contact Information 1. Definitions In this Privacy Policy, terms that commence with a capital letter are defined in this Section or in the preamble. "Guest" means an individual who visits the Site but does not register. "Member" means an individual who has registered with the Site. Members choose a Screen Name and Pass Code. "Orbitz" or "we" means Orbitz, LLC and its subsidiaries and affiliates. "Pass Code" means the code you use to login to our Site. "Personal Information" means any information, recorded in any form, about an identified individual, or an individual whose identity may be inferred from the information. This includes, for example, name, e-mail and mailing address and telephone number. "Screen Name" means the name you will be identified by on the Site. Your screen name will appear in the community section of the Site. "Session Data" means usage information, such as the type of Internet browser and operating system an individual uses, the domain name of the site from which the individual came, the date, time and duration of the visit, number of visits, average time spent on the individual's site, pages viewed, domain name of the individual, and number of cookies accumulated. "Site" means the www.orbitzgames.com site and its respective sub sites together with the respective content, products and services available from these sites and sub sites. 2. Consent BY SUBMITTING PERSONAL INFORMATION TO US, AND/OR BY USING OUR SITE, YOU AGREE THAT WE MAY COLLECT, USE AND DISCLOSE SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY AND AS PERMITTED OR REQUIRED BY LAW. If you do not agree with these terms, do not provide any Personal Information to us. If you refuse or withdraw your consent, or if you choose not to provide us with any required Personal Information, we may not be able to provide you with Products or Services that can be offered on our Site only if we have access to certain Personal Information. Minors: Minors (as defined under the laws of their jurisdiction or residence) are not eligible to register for or use the Site. We do not knowingly collect Personal Information from any Minor, and will not use this information if we discover that it has been provided by a Minor. 3. What Personal Information we collect We collect only such information as necessary to provide the games and fulfill the promotions available on the Site to you. When you are just visiting: You can visit certain areas of our Site without revealing who you are or signing-in. When you visit our Site as a Guest, or Member, we collect Session Data through Cookies and pixel tags. When you register as a Member: If you register with us as a Member, we collect Personal Information that is necessary to fulfill the promotions offered on our Site. We require that you provide your name, birth date, country of residence, phone number and e-mail address. We only use this information to inform you that you have won a promotion or to send you Orbitz Games and Orbitz.com emails if you elected to receive them. You may elect to provide other information, for example, your usual departure airport. You also need to choose a Screen Name, which will be required to gain access to portions of our Site reserved for Member use, and will need to choose a Pass Code to log onto the Site. When you use the Site as a "Guest": If you are not a Member, you may elect to use our Site as a Guest. However, as a Guest you will not be able to access the games. When you participate in contests, promotions, raffles, or sweepstakes: We may offer you the chance to win a variety of travel related prizes by sponsoring contests, promotions, raffles, or sweepstakes. If you choose to participate, we will collect Personal Information, such as your full name, e-mail address, or mailing address. If a third party administers the contest, your participation may be subject to that other party's terms and conditions and privacy policy. Detailed information about or a link to these terms will be provided on the applicable form you will be asked to fill out. When you participate in a survey or a focus group: From time to time, we may invite you to participate in a survey or a focus group. You are free to participate or not. We will collect the responses you provide, and will make them anonymous to aggregate them with those of other participants. When we advertise on third party sites: When you visit a site on which we advertise, and click through our advertisement, we may place cookies on your computer, or use pixel tags. The information that we collect through this technology is not personally identifiable. When you call or write to our Customer Service: When you call or write to our Customer Service, we collect contact information (name, phone number, mailing address or e-mail address) and information as necessary to assist you. When we send e-mails or e-newsletters: When we send e-mails, e-newsletters, or when you forward a promotion or search results to a third party, using the "Send to a Friend" feature, we may insert a pixel tag in the e-mail. 4. How we use the information we collect We use Personal Information in order to provide the games and fulfill the promotions offered on our Site: To provide tips or guidance on how to use our Site, inform you of new features on our Site, or provide other information that may be of interest to users; To personalize the service we provide to you and tailor your experience at our Site to your interests; To send you e-mails, e-newsletters, personalized offers via direct messaging or other communications about our services, if you have subscribed to receive this information; To manage our Site, diagnose technical problems, improve content, and allocate the resources of our systems so that your experience with our Site is as efficient as possible; To investigate, detect and protect Orbitz and other third parties against error, negligence, breach of contract, fraud, theft and other illegal activities; To effect a corporate transaction, in connection with the sale, merger, spin-off, or other corporate reorganization of our corporation, where the information is provided to the new controlling entity in regular course of business; To audit compliance with our policies and contractual obligations; As permitted by, and to comply with, any legal or regulatory requirements or provisions; or For any other purpose to which you consent. Contests - Promotions - Raffles - Sweepstakes: If you participate in a contest, promotion, raffle, sweepstake, we will only use your Personal Information to notify you if you win. We may send you additional communications only if you have specifically requested to receive our newsletters, e-mails, personalized offers or other promotional materials when filling out the contest or promotion form. We will share the information with the entities with which we may have teamed to propose the joint promotion. If a third party administers the contest, your participation may be subject to additional terms and conditions and that third party's privacy policy. We are not responsible for such third parties. You should carefully review these third parties' terms and conditions. Session Data: We use Session Data, collected through cookies and pixel tags, to better understand how our Site is navigated, how many visitors arrive at specific pages, the length and frequency of stays at our Site, the variety of searches of our Site's database, the types of browsers and computer operating systems used by our visitors and the Internet Protocol addresses from which visitors connect to our Site. We also use this information to improve our Site content and ease of use, to personalize and improve your individual viewing experiences on our Site, and provide information that may be of interest to you. Pixel Tags: We use pixel tags to monitor the open rate of our communications. This helps us understand the effectiveness of communications we send. We do not use this information for any other purpose. Survey and Focus Groups: When you participate in surveys or focus groups, your participation and responses will be kept confidential, and will not be shared outside Orbitz without your permission, except with our service providers. Aggregated Information: Aggregated information is information, recorded in any form, about more than one individual, where the identity of the individual is not known, and cannot be inferred from the information. We may use aggregated information to describe our user base to current or potential partners investors and advertisers; after a survey, to understand and respond to market needs and preferences; or to make recommendations to other users of our Site. What we do NOT do: We do not and will not, at any time, request your credit card information, pass code, or national identification numbers in a non-secure or unsolicited e-mail or telephone communication. Identity theft and the practice currently known as "phishing" are of great concern to us. Safeguarding information to help protect your from identity theft is our priority. For more information about phishing, you may want to visit the Federal Trade Commission at http://www.ftc.gov/bcp/conline/pubs/alerts/phishingalrt.htm. 5. To whom we disclose Personal Information From time to time, we may disclose your Personal Information as follows: To organizations that perform services for or on behalf of Orbitz, for example to provide customer service, for research, marketing, data processing, to measure the use of our Site, or to facilitate usage by a Visitor. We will share with these companies only that Personal Information which they need to work on our behalf. Some of these service providers may be located in other countries. Your Personal Information will be provided to these organizations only if they agree to use such information solely for the purpose of providing services to Orbitz, and under the instructions of Orbitz, and with respect to that information, to act in a manner consistent with the relevant principles articulated in this Policy. Some of these service providers may be located in countries outside the US and outside the European Economic Area ("EEA"). Your Personal Information will be provided to these organizations only if they agree to use such information solely for the purpose of providing services to Orbitz, and under the instructions of Orbitz, and with respect to that information, to act in a manner consistent with the relevant principles articulated in this Policy. By submitting your personal data, you agree to the transfer, storing and processing of your data outside the US and outside the EEA. We may collaborate with other companies to offer you products or services, for example, through sweepstakes, raffles, and promotions. We will share Personal Information that is necessary for these other companies to provide the products or services that you have requested. This policy will not cover the use of your Personal Information by these other companies. We encourage you to read a company's privacy policy before requesting any of its products or services. To protect our Site and our rights under our Terms and Conditions of Use; to protect ourselves against liability or prevent fraudulent activity; or where it is necessary to permit us to pursue available remedies or limit any damages that we may sustain. To effect a corporate transaction, in connection with the sale, merger, spin-off, or other corporate reorganization of our corporation, where the information is provided to the new controlling entity in regular course of business. Where the information is public. To our insurers and to regulatory agencies. Disclosure without consent: Please note that there are circumstances where the use or disclosure of Personal Information may be justified or permitted, or where Orbitz may be obligated to disclose information without consent. Such circumstances may include: If required to comply with a subpoena or warrant issued or an order made by a court, person or body with jurisdiction to compel the production of information, or to comply with the rules or court relating to the production of records. If we receive a formal request to disclose your Personal Information in connection with a legal action, we will attempt to contact you about it, if permitted by law, via the e-mail address you provided during registration, before we respond to that request. If we believe in good faith that a law, regulation, rule or guideline requires it. To a person who needs the information because of an emergency that threatens the life, health, or security of an identifiable person or group. Where it is necessary to collect monies owing to us. 6. How we retain and store Personal information My Account: If you become an Orbitz Games Member, we combine some of your Personal Information in what we call "My Account". You can access My Account from the Homepage of our Site, after logging onto our Site as a registered Member. My Account contains your screen name, state and country where you are from and information about your travel experiences, if you provided it. Retention and storage: We will retain your Personal Information in our databases in accordance with our records management policy and applicable laws. This period may extend beyond the end of your relationship with us, but it will be only as long as it is necessary for us to have sufficient information to respond to any issues that may arise later. For example, we may need or be required to retain to prevent fraudulent activity; to protect ourselves against liability, permit us to pursue available remedies or limit any damages that we may sustain; or if we believe in good faith that a law, regulation, rule or guideline requires it. Your Personal Information will be stored in secured locations, and on servers controlled by Orbitz, located either at our offices, or at the offices of our service providers, as described in How we protect Personal Information. 7. How we protect Personal Information Orbitz employs physical, administrative and technical safeguards to help protect the confidentiality and integrity of Personal Information and to reduce the risk of loss, misuse, unauthorized access, disclosure or modification of Personal Information. When Personal Information is sent to our service providers, we require, in our contracts with them, that they protect all Personal Information in a manner consistent with the principles articulated in this Privacy Policy. If you choose to contact Orbitz through the Site, you should be aware that any information transmitted electronically via the World Wide Web might not be secure. Orbitz assumes no liability for the loss of any information that you transmit to us via the World Wide Web. In communicating with you, we may send e-mail as unencrypted plain text because we are aware that most Members and Visitors cannot readily process encrypted e-mail. This is done for your convenience, but with the security concern that, if misrouted or intercepted, it could be read more easily than encrypted e-mail. 8. How to access, modify or delete your Personal Information We endeavor to ensure that Personal Information is as accurate, complete, and current as necessary for the purposes for which we use that information. If you need to update your name, email address or phone number for this Site, you can do so in My Account. If you wish to modify or delete other Personal Information, you can do so by contacting us as indicated in Contact Information. If you request that we remove all of the Personal Information stored in My Account, we will promptly do so, to the extent possible. Once required Personal Information is removed from My Account, however, you will not be able to use many of the services available on our Site to Members, unless you re-register. Please remember that we may not be able to honor your request if we are legally obligated to retain that information, or for other reasons, as described in our Retention and Storage policy. 9. Privacy Cookies and pixel tags: A Cookie is a small text file that our computer sends to your computer, and that your computer sends back to us each time you make a request from our Site. A cookie contains a unique identification number that identifies the visitor's browser, but not necessarily the visitor. A pixel tag is a small graphic image similar to a cookie. In addition to cookies and pixel tags, we utilize Macromedia Flash Player. When you access our Site, our computer may seek to place "cookies" or "pixel tags" on your personal computer to collect Session Data. Cookies, pixel tags and Flash Player help us recognize you when you visit our Site again. Unless a visitor specifically informs us of his/her identity (e.g. by registering with us), we will not know who the individual visitor is. Most Internet browsers automatically accept cookies. You can instruct your browser, by editing its options, to stop accepting cookies or prompt you before accepting a cookie from the sites you visit. You can learn more about the use of cookies by visiting http://networkadvertising.org or http://www.allaboutcookies.org. Regardless of how you may have configured your browser, you have the election to permit or deny the Flash Player application permission to store the information. You can also specify how much disk space the stored information can occupy. You can learn more about updating your Flash Player settings by visiting macromedia.com If you decide not to accept our cookies or the Flash player, you will be able to access those parts of our Site that are available to the general public, but you will not be able to access many of the Services offered at our Site. Third Party Advertisers: Third parties advertise on our Site. We do not share any Personal Information about you with these advertisers unless you give us permission to do so, separate from any permission you provide during the Member registration process. These advertisers may seek to use cookies and pixel tags to track Session Data about the ads you have seen and types of things in which you appear interested. These advertisers may also use combined information about your visits to our Site and other sites in order to provide advertisements about related goods and services that may be of interest to you. When you click on one of these advertisers' links, you are leaving our Site and entering another site. We are not responsible for such third party's sites. You should carefully review the privacy statements of any other site you visit, because those privacy statements will apply to your visit to that site, and may be very different from our policy. Opting-Out: As part of the registration process, we give you the ability to receive via e-mail or direct messaging information about Orbitz' products and services, new Orbitz Games announcements, Orbitz Games cheats and clues, updates to the Orbitz Games and Orbitz.com Site, customized advertisements and promotions that are targeted to your specific interest, such as flight specials, promotions, contests, sweepstakes and other travel opportunities available on our Site and/or sponsored by our travel service providers and advertisers. We send this information directly ourselves, or via third party service providers. If you do not opt-out from receiving these communications about our Site, we will send them to you., You can opt-out from receiving these communications by updating the preferences in your My Account, by clicking here, or by unsubscribing to the emails when you receive them. Each email contains instructions on how to unsubscribe if you do not want to receive any future marketing or promotional e-mails from us. Monitoring: Orbitz may from time to time monitor and review any information transmitted or received through the Site, or through telephone or email communications, for quality assurance and other purposes. We reserve the right to censor, edit, remove, or prohibit the transmission or receipt of any information that Orbitz deems inappropriate, or in violation of these Terms and Conditions. During monitoring, the information may be examined, recorded, or copied. Links: For your convenience, our Site provides links to other sites. When you click on one of these links, you are leaving our Site and entering another site. We are not responsible for such third party sites. You should carefully review the privacy statements of any other sites you visit, because those privacy statements will apply to your visit to such other sites. Tell-A-Friend Emails: If you choose to use our referral service to tell a friend about our site or a promotion, we will send your friend a one-time email inviting him or her to visit the site. Our tell-a-friend functionality works through your own email client, so we do not collect or store any of the names or email addresses of your friends. 10. Provisions of this Privacy Policy Changes to the Privacy Policy and Changes in Ownership: We may change or supplement this Privacy Policy from time to time. We may also undergo a change of ownership. Privacy Policy changes will apply to the information collected from the date we post the revised Privacy Policy to the Site, as well as to existing information held by us. If we decide to change this policy in a material way, we will obtain the necessary consents required under applicable privacy laws if we seek to collect, use or disclose Personal Information for purposes other than those to which consent has been obtained, unless otherwise required or permitted by law. If any proposed change is unacceptable to you, you may request that we remove your Personal Information from our records, by contacting us at the contact information provided below. 11. Disputes Orbitz is a licensee of the TRUSTe Privacy Program. TRUSTe is an independent, non-profit organization whose mission is to build users' trust and confidence in the Internet by promoting the use of fair information practices. Because Orbitz wants to demonstrate its commitment to privacy, it has agreed to disclose its information practices and have its privacy practices reviewed for compliance by TRUSTe. If you have questions or concerns regarding Orbitz privacy practices, you should first contact the Orbitz Chief Privacy Officer. If you feel your inquiry has not been satisfactorily addressed, you should then contact TRUSTe http://www.truste.org/consumers/watchdog_complaint.php. TRUSTe will then serve as a liaison with Orbitz to resolve your concerns. 12. Contact Information If you have any questions or concerns about (a) access to Personal Information, (b) the collection, use, management or disclosure of Personal Information, or (c) this policy or our information handling practices, (d) with whom your Personal Information is shared, or if you need further assistance with respect to our Privacy Policy, you may contact our Chief Privacy Officer, or our Customer Service department as indicated below. We will attempt to respond to your questions or concerns promptly after we receive them. E-mail: privacy@orbitz.com Mailing address: Chief Privacy Officer Orbitz, LLC 500 West Madison Street, Suite 1000, Chicago IL 60661 Telephone: 888-656-4546 (within the United States) 312-416-0018 (Outside the United States)