PRIVACY POLICY

Effective June 2007

This page sets forth the privacy policies and practices of the Traffic Marketplace ("Traffic Marketplace") corporate site www.trafficmarketplace.com ("Traffic Marketplace Site").

Please read this privacy policy carefully since by visiting this site and sharing information with Traffic Marketplace you agree to be bound by the terms and conditions of this Privacy Policy unless you offer different terms which are accepted by Traffic Marketplace in writing. To the extent there is a conflict between the terms of this Privacy Policy and a written agreement to which Traffic Marketplace is party, the terms of such agreement shall prevail with respect to the parties to that agreement.
For more information about Traffic Marketplace and other Connexus companies please visit www.connexuscorp.com.

STATEMENT OF RESPONSIBLE ONLINE MARKETING

The Traffic Marketplace information usage practices are based on two beliefs: first, that protecting user privacy is essential to the growth and prosperity of the Internet; second, that a personalized web experience can provide significant benefits to Internet end users if done properly. In accordance with these beliefs, Traffic Marketplace creates results for advertisers and publishers in revolutionary ways without compromising individual privacy.

I. INFORMATION WE COLLECT

Traffic Marketplace is the corporate entity that manages the Traffic Marketplace marketing, technology and e-commerce companies and divisions. The Traffic Marketplace Site is not directed towards individual Internet consumers nor does it seek any personally identifiable information ("PII") from such consumers. PII may be collected should a consumer contact Traffic Marketplace on his/her own accord and volunteer PII. The information collection practices of the various Traffic Marketplace companies and divisions are detailed on their individual sites.

Like most standard website servers, we use log files to collect Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, platform type, and date/time stamp. We use the information to analyze site usage, administer the site, understand usage and navigation trends in aggregate, and determine the relevance of content.

II. INFORMATION MANAGEMENT

Traffic Marketplace may share information with its affiliated entities for or in connection with the sale, merger, consolidation, change in control, transfer of substantial asset, reorganization or liquidation of any of the Connexus companies. Traffic Marketplace also may release information when we believe release is appropriate to respond to a subpoena or otherwise comply with the law; enforce or apply our agreements; or protect the rights, property, or safety of Traffic Marketplace or others. This includes exchanging information with other companies and organizations for fraud protection.

III. CONSUMER CHOICE AND ACCESS

Because the Traffic Marketplace Site is not directed towards individual Internet users and does not use cookies, we do not maintain a process for an individual consumer to review and/or request changes to any PII collected.

IV. SECURITY

Traffic Marketplace employs industry standard security measures to ensure the security of all data. Any data that is stored on Traffic Marketplace servers is treated as proprietary and confidential and is not available to the public. Traffic Marketplace has an internal security policy with respect to the confidentiality of customer and other data, allowing access only to those employees or third parties who have a need to know such information for the purpose of effectively delivering Traffic Marketplace products and services by means of user login and password requirements. Traffic Marketplace routinely evaluates its data security practices to identify security threats or opportunities for improvement.

No transmission of data over the Internet, however, is guaranteed to be completely secure. It may be possible for third parties not under the control of Traffic Marketplace to intercept or access transmissions or private communications unlawfully. While we strive to protect your information, Traffic Marketplace cannot ensure or warrant the security of any information you transmit to us. You acknowledge and assume this risk when communicating with us.

V. CONSENT AND CHANGES

Traffic Marketplace may find it necessary or be legally obligated to update this Privacy Policy from time to time. When we do, we will post those changes on this page and update the effective date so that you are always aware of the information we collect, how we use it, and under what circumstances we disclose it. Except as otherwise required by law, modifications to this Privacy Policy will not affect the privacy of data collected by Traffic Marketplace prior to the effective date of the policy change unless we provide you direct notice and the opportunity to opt-out.

VI. CHILDREN'S PRIVACY AND SPAM

Traffic Marketplace is very sensitive to the issue of children's privacy and makes every effort to protect the privacy of children using the Internet. Traffic Marketplace web site, products, and services are not developed for or directed at children. Children (persons under the age of 18) are not eligible to do business with us and we do not collect personal information from any person we actually know is under the age of 13. Traffic Marketplace is committed to proper Internet practices and full compliance with the CAN-SPAM Act of 2003 (15 U.S.C. § 7701). It is our policy to prohibit the sending of unsolicited or "Spam" e-mail by Traffic Marketplace or any of its marketing partners.

VII. DATA PROCESSING/SAFE HARBOR

The European Union ("EU") maintains strict privacy laws. These rules differ significantly from US laws. To reconcile these differences, the US and the EU have created a Safe Harbor that defines mutually acceptable privacy operations.

Traffic Marketplace adheres to the Safe Harbor principals. For more information see www.export.gov/safeharbor.

By providing information to Traffic Marketplace, you acknowledge that they operate in the United States and agree to (i) permit Traffic Marketplace to transmit and use your User information anywhere necessary, including across international boundaries, to affect the services and transactions provided by this Site; and (ii) that such use by Traffic Marketplace shall be subject to the terms and conditions stated in this Privacy Statement and applicable Terms and Conditions and Policies.

VIII. LIMITATION OF LIABILITY, THIRD PARTY INFORMATION & LANGUAGE

YOU UNDERSTAND AND AGREE THAT ANY DISPUTE OVER THE PRIVACY OF TRAFFIC MARKETPLACE DATA OR TRAFFIC MARKETPLACE PRACTICES IS SUBJECT TO THE PROVISIONS OF THIS PRIVACY POLICY AND ANY APPLICABLE TERMS AND CONDITIONS (WHICH MAY INCLUDE LIMITATIONS ON DAMAGES AND/OR ARBITRATION OF DISPUTES). YOU AGREE THAT TRAFFIC MARKETPLACE LIABILITY FOR ANY BREACH OF THIS PRIVACY POLICY SHALL BE LIMITED TO THE GREATER OF THE VALUE OF THE TRANSACTIONS OR SERVICES PROVIDED TO YOU BY TRAFFIC MARKETPLACE OR $100 TO THE EXTENT SUCH CLAIM IS NOT OTHERWISE BARRED BY OUR TERMS AND CONDITIONS. YOU FURTHER AGREE THAT THIS AGREEMENT IS GOVERNED BY CALIFORNIA LAW WITHOUT REGARD TO CHOICE OF LAW PRINCIPLES AND THAT ANY ACTION ARISING FROM OR RELATED TO THIS POLICY WILL BE EXCLUSIVELY VENUED IN A STATE OR FEDERAL COURT SITUATED IN LOS ANGELES COUNTY, CALIFORNIA.

You also agree that you have provided notice to, and obtained consent from, any third party individuals whose personal data you supply to Traffic Marketplace with regard to: (a) the purposes for which such third party's personal data has been collected; (b) the intended recipients or categories of recipients of the third party's personal data; (c) which of the third party's data are obligatory and which data, if any, are voluntary; and (d) how the third party can access and, if necessary, rectify the data held about them.

CONTACT US

For more information or if you have questions or concerns regarding this Privacy Policy, please send correspondence to the following address: Traffic Marketplace, Privacy Officer, 2101 Rosecrans Ave., Suite 2000, El Segundo, CA 90245.