I. WEBTEXT™ International Privacy Policy Notice and Choices:

As set forth in the Conditions of Use, WEBTEXT provides (a) computing and information services and (b) telecommunications services (including the WEBTEXT SMS Service) (collectively the “Services” or the “WEBTEXT Services”) to persons who join WEBTEXT as non-paying Members or Premium Users (“Members” or “Users” or “you”). As part of the registration process for the Services, You are asked to provide certain personal information and (if applicable) credit card or other billing information. The policy of WEBTEXT is to protect the privacy of WEBTEXT Members who are using any of the WEBTEXT Services. Please be aware, however, that as a condition of membership and use of the WEBTEXT Services, WEBTEXT users agree to receive marketing materials from WEBTEXT.

Please recognize that it is the policy of WEBTEXT to protect the privacy of its Members, and thus WEBTEXT will only allow third parties to have access to information concerning Users (“User Information”) in the following situations:

(i) WEBTEXT will provide access to certain User Information to third-party suppliers in order for them to perform certain functions for us as necessitated by the Member’s use of any of the Services — for example, credit card numbers are sent to a credit card processing company for billing. These suppliers are not authorized to release this information to other third parties.

(ii) WEBTEXT will disclose User Information in cases where, in its discretion, it deems such disclosure required or appropriate in order to comply with applicable laws and regulations.

(iii) WEBTEXT will disclose User Information if the User gives permission, requests products that require identifying information for fulfillment, or we are required to do so by law or regulatory authority.

(iv) Notwithstanding anything else contained in this Privacy Policy, WEBTEXT reserves the right to sell or otherwise transfer Your User Information to one or more third parties in connection with a sale of all or substantially all of the assets of WEBTEXT or in connection with the sale of all or substantially all of the stock or ownership interests in WEBTEXT.

(v) WEBTEXT may provide details of messages including message content as required by upstream providers or telecom regulators or law enforcement officials investigating potential or actual SMS spam and/or abuse/criminality.

WEBTEXT may send Users periodic emails containing information about WEBTEXT, administrative notices about a User’s account (such as notices about pending activities), updates on new Service features, usage tips relating to the Services, information about WEBTEXT or third party products and services that are likely to be of interest to you, and user satisfaction questionnaires. WEBTEXT may also access user information for the following administrative purposes: (a) to examine system accounting logs and other company records to resolve SMS, email and other system errors or problems and (b) for billing purposes.

II. Credit Card Information:

If any person uses a credit or debit card to pay for any of the Services offered by WEBTEXT requiring payment of a fee or fees, WEBTEXT will continue to charge Your account until You provide WEBTEXT notice of termination of use of the service (in accordance with the Conditions of Use) and all usage fees have been paid. Notwithstanding termination by a User of Services, WEBTEXT will not refund any portion of the annual fee. Unless You advise WEBTEXT of Your desire to cancel Service, Your membership will be automatically renewed and service fees will be charged to the credit or debit card You provided. If You give us credit or debit card information for any other purpose or to pay for any other type of purchase, it will be used one time only to fulfill one order, and WEBTEXT will not store Your credit card information. Each User is responsible for all charges resulting from use of the Services, including unauthorized use prior to Your notifying WEBTEXT of such use and taking steps to prevent its further occurrence. Further, each User agrees to be financially responsible for use of the Services (as well as for use of Your account by others, including minors living with you) and to comply with Your responsibilities and obligations as stated in this Agreement.

III. Children May Not Use these Services unless supervised by an adult at all times.

IV. WEBTEXT Information Practice, Access and Security:

A. Please be aware that use of the WEBTEXT Services is subject to the Terms and Conditions (as applicable to the WEBTEXT Site and each of the Services) as well as this Privacy Policy.

B. WEBTEXT will limit the information we collect about Members to what is needed to accurately provide the Services or products requested by Members. WEBTEXT will only use or release User Information in accordance with this Privacy Policy (as set forth in Section I above).

C. WEBTEXT will be aggressive in terminating accounts of users who violate WEBTEXT’s Conditions of Use. If we must deny a consumer’s application for service or terminate a consumer’s relationship with us, in cases other than fraud or violations of any law, rule or regulation, we will provide upon request the reasons, nature, substance, and information WEBTEXT used in the decision.

D. WEBTEXT is concerned about protecting User Information (including any credit card information) and therefore we work to protect this information by utilizing all appropriate technology to prevent unauthorized access to the information You provide WEBTEXT. To prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of information, we have put in place appropriate physical, electronic, and managerial procedures to protect the information we collect online, including SSL security for credit card submissions.

V. WEBTEXT Employee Standards

A. Only those employees needed to carry out the business functions may have access to information on individual WEBTEXT customers. We employ security techniques to safeguard User Information.

B. Each employee has a personal responsibility for maintaining Member confidence in WEBTEXT. We train each employee on the WEBTEXT Privacy Principles, and those violating these principles will be subject to disciplinary action, including dismissal in appropriate cases.

VI. Conditions of Use and Revisions

A. Please be aware that use of the WEBTEXT Services is subject to the Conditions of Use and this Privacy Policy.

B. Since offerings and technologies change, we reserve the right to change, modify, add or remove portions of our Privacy Policy or Conditions of Use at any time without prior notice. Please periodically review our Privacy Policy and the Conditions of Use for changes. YOU ARE RESPONSIBLE FOR REGULARLY REVIEWING THE WEBTEXT WEBSITE TO OBTAIN TIMELY NOTICE OF SUCH MODIFICATIONS. YOU SHALL BE DEEMED TO HAVE ACCEPTED SUCH MODIFICATIONS BY CONTINUING TO USE THE SERVICES AFTER SUCH MODIFICATIONS HAVE BEEN POSTED OR INFORMATION REGARDING SUCH MODIFICATIONS HAS BEEN SENT TO YOU. If at any time You are uncomfortable with any change, amendment or modification to the Privacy Policy or Conditions of Use and wish to cancel Your membership, please notify WEBTEXT at cancel(at)webtext.com

C. The internet community is a rapidly changing environment and therefore WEBTEXT may sell or liquidate its assets or its business or may purchase the assets or business of other companies (“business transfers”). In such transactions, user information generally is one of the transferred business assets and therefore WEBTEXT Users should be aware that such business transfers may occur.

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