Brighthand Media INC.
PRIVACY POLICY

Last Updated: September 3, 2008

Brighthand Media, Inc. ("Brighthand Media", "we", or "us") operates one or more websites ("Network Sites" or "Network") offering a variety of products and services.

Brighthand Media makes the Network and various email offers available to (1) those individuals who register directly with any website within the Network, (2) those individuals who have opted to receive offers from us on third party websites, and (3) other individuals whose information has been provided to Brighthand Media by third parties (in accordance with their respective privacy policies) (collectively, "Members"), subject to this privacy policy (the "Policy"). This Policy explains what information Brighthand Media collects about Members of the Network Sites, how Brighthand Media uses and/or shares this information, and how such information is maintained. By using the Network, or by continuing your membership with Brighthand Media, you signify your acceptance of this Policy.

Note that this Policy applies only with respect to the information collected by Brighthand Media and not any information collected or obtained through other methods or sources.

Collection of Personally Identifiable Information

Brighthand Media collects Member personally identifiable information ("PII") that is volunteered by Members during the member registration process or in response to specific information requests explicitly presented to Members. Brighthand Media also collects PII that is provided by third parties to Brighthand Media in accordance with their respective privacy policies. Examples of PII that may be requested and/or collected include: first and last name, title, address, email address, telephone number, gender, date of birth, personal interests, education, and household income. From time to time, Brighthand Media may also present opportunities for Members to voluntarily provide additional information about themselves.

Use and Sharing of PII

Brighthand Media reserves the right to use Member PII: (1) for the specific purpose for which such information was provided; (2) as disclosed at the time such information is provided; and/or (3) as disclosed in this Policy. However, please note that Brighthand Media may change this Policy at any time (See "Changes to this Policy," below), and that therefore Brighthand Media may in the future use Member PII for additional purposes not currently included in this Policy.

Member PII collected by us may be added to our databases and used for future telemarketing, SMS text-messaging, e-mails or postal mailings. By using this site, you agree that you may be contacted in any manner contemplated in this section even if your number is found on a do not call registry, in-house list or similar registry.

Members understand and agree that Brighthand Media may share their PII with third parties. Brighthand Media may share Member PII with its partners, sponsors, advertisers, service providers and marketers, lookup and reference services, and any other entities that Brighthand Media believes are able to provide Members with special offers and opportunities. Note that although Brighthand Media advises everyone who receives Member PII from Brighthand Media to support this Policy, Brighthand Media has no control over such party's information handling practices and is not responsible for any failure of such party to adhere to this Policy.

When you become a Member of any website in the Network, you may be automatically registered to become a Member of any of the other websites in the Network. Accordingly, Brighthand Media may share Member PII between Network Sites.

Brighthand Media may share Member PII in aggregate, non-personal form, with select companies that wish to reach a particular Member target audience.

Brighthand Media may disclose Member PII in order to: (1) comply with applicable laws (including, without limitation, the CAN-SPAM Act); (2) respond to governmental inquiries; (3) comply with valid legal process; and (4) protect the rights or property of Brighthand Media, the Network Sites or other Members and users of the Network Sites.

By using the Network Sites, Members acknowledge that the processing of their PII for the purposes described above may involve the transfer of such PII from within the European Economic Area ("EEA") to countries outside the EEA whose data protection regulation may not be as stringent as that within the European Union.

CALIFORNIA RESIDENTS: YOUR PRIVACY RIGHTS

Effective January 1, 2005, companies that collect PII from California residents and disclose such information to third parties (including affiliated entities) for marketing purposes must, in response to a request by a consumer, either (1) provide a list detailing the categories of information shared and the entities to which such information was provided or (2) provide a mechanism by which a consumer may opt-out of having their information shared with third parties. We have elected the second option and you may request that your PII not be shared with third parties by sending your request, including your full name, email address and postal address to Brighthand Media at the address listed at the bottom of this page. Please mail your envelope to the Attention of "California Privacy Officer".

Non-Personally Identifiable Information

Brighthand Media also collects certain non-personally identifiable information, including the non-personally identifiable information more fully described below.

Cookies. Brighthand Media uses "cookies" on the Network Sites. Cookies are small pieces of information that Brighthand Media's server places on an individual's computer hard drive to enable the individual to more easily communicate and interact with the Network Sites. For example, Brighthand Media may place a cookie on a Member's computer when he/she initially clicks on a link in an email from Brighthand Media. The next time that Member opens an email from Brighthand Media and clicks on the link, Brighthand Media's server will recognize the cookie (and the Member) and allow the Member to perform certain actions immediately without signing in.

While some Web browsers allow a Member to automatically reject all cookies or be notified when a cookie is about to be placed on the Member's computer, disabling this feature may compromise the efficiency and added services that cookies provide.

IP Address. Brighthand Media collects your IP (Internet Protocol) address to help diagnose problems with Brighthand Media's server, and to administer the Network Sites and Brighthand Media email offers. An IP address is a number that is assigned to your computer when you use the Internet. Your IP address is also used to help identify you during a particular session and to gather broad demographic data.

Clear GIFs. Brighthand Media uses email delivery and marketing companies that you have agreed to receive messages from. Pixel tags and cookies are used in those email messages and at our website to help us measure the effectiveness of our advertising and how visitors use our sites. A Clear GIF, or "graphic interface format" is a small graphic (in fact, truly a 1x1 pixel) that Brighthand Media (or a partner of Brighthand Media) places on the Network Sites or in an email. GIFs, which do not contain any PII, provide Brighthand Media with important information about how Members respond to email messages. With this information, Brighthand Media is better able to track the performance of certain promotions and understand the effectiveness of particular creative email presentations. Brighthand Media may also allow its advertisers and promotional partners the ability to use GIFs on the Network solely to track Members who link from their respective websites to Network Sites, but this ability to track such activity does not allow these entities access to Member PII.

Although the information collected through the foregoing methods does not itself contain any PII, Brighthand Media may analyze and match such information with other information that you provide (including PII) as well as information that Brighthand Media may obtain elsewhere, and Brighthand Media may share all or some of such information with partners, prospective partners, and other third parties.

Brighthand Media may also disclose non-personally identifiable information in order to (1) comply with applicable laws, (2) respond to governmental inquiries, (3) comply with valid legal process, or (4) protect the rights or property of Brighthand Media or its Members and users of the Network Sites.

Linking of Information

Brighthand Media may combine information provided by a Member with information obtained from other sources. Enhancing Member files with this other information will allow Brighthand Media to provide Members with more relevant services, email promotional offers, and direct mail pieces. For example, a Member's user profile may be automatically updated with any information that user enters on any of the Network Sites. Likewise, any information provided to Brighthand Media will be used to update the Member's profile on all of the Network Sites.

Opt-Out of Brighthand Media Promotions

When you become a Member, you will automatically be registered to receive promotional offers and updates, via emails, from Brighthand Media and our partners.

Members may, at any time, choose not to receive promotional emails from Brighthand Media, the Network Sites or partners of Brighthand Media by following the "unsubscribe" instructions in the applicable email. Alternatively, Members may contact us directly to have their names removed from our promotional offers and updates distribution list. Notwithstanding the foregoing, Brighthand Media may continue to contact Members for the purpose of communicating information about their membership with Brighthand Media, or similar information relating to Brighthand Media, the Network Sites or your membership, as well as to facilitate, complete or confirm any transaction that Members' enter into or in response to or fulfillment of Members' inquiries or requests.

Access to Information If you want to review, correct or change your Member account information, please contact us.

Third Party Services

Certain information and services available to Members are provided by entities not affiliated with Brighthand Media. For example, if you choose to purchase a product or service from an email, the information you provide in connection with such purchase may be made available to a third party to satisfy that purpose. Although Brighthand Media advises all of its partners to support this Policy, Brighthand Media has no control over their information handling practices and is not responsible for any failure of such partners to adhere to this Policy.

Third Party Cookies

In the course of serving advertisements to users in emails, third-party advertisers or ad servers may place or recognize a unique cookie on your browser. The use of cookies by such third party advertisers or ad servers is not subject to this Policy, but is subject to their own respective privacy policies.

Links from Email

Brighthand Media provides links to many of Brighthand Media's advertiser and partner websites and other websites. If you link to any of these third party websites, this Policy will not apply to your use of, and activities on, those sites. We encourage you to read the legal notices posted on these sites, including their privacy policies. Brighthand Media shall have no responsibility or liability for your visitation to, and the data collection and use practices of, these sites.

Note Concerning Users Under 18 Years of Age

The Network Sites, Brighthand Media emails and the content available in connection therewith, are neither intended for, nor directed to, children under the age of 18. You must be at least 18 years old to have our permission to use our websites. If Brighthand Media learns that a person who is a Member is under the age of 18, Brighthand Media will promptly terminate that individual's membership.

Security

While Brighthand Media takes reasonable precautions to safeguard information transmitted between Brighthand Media and Members and/or users of the Network Sites, Brighthand Media may be unable to prevent unauthorized access to such information by third parties or inadvertent disclosure of such information. Members and users acknowledge this risk when communicating with Brighthand Media.

Consent to Processing

By providing PII and other information to Brighthand Media, Members and users of the Network Sites fully understand and unambiguously consent to the collection and processing of such information in, and the transfer of such information to, the United States and other countries or territories, in accordance with the terms of this Policy.

Transfer in Certain Circumstances

In its sole discretion, Brighthand Media may transfer, sell or assign information collected on or about Members of the Network Sites, including without limitation, PII and other Member provided information, to one or more third parties, as a result of the sale, merger, consolidation, change in control, transfer of substantial assets, reorganization or liquidation of Brighthand Media.

Changes to This Policy

Brighthand Media may, from time to time, amend this Policy, in whole or part, in its sole discretion. Any changes to this Policy will be effective immediately upon the posting of the revised policy. By continuing to use the Network Sites following any changes, you will be deemed to have agreed to such changes.

Brighthand Media, Inc.
4613 N. University Drive
Suite 394
Coral Springs, FL 33067
corp@brighthandmedia.com