The website www.netwinner.com (the "Website") and all services provided therein, including the NetWinner Sweepstakes (the "Service") is owned and operated by, and the sponsor of all sweepstakes is:

NetWinner, L.L.C.
1427 South Blvd #200
Charlotte, NC 28203

Customer Service Department:
support@netwinner.com
Your privacy and security is important to NetWinner, L.L.C. ("NetWinner"). As part of the operation of the NetWinner Service, certain information is gathered about those who visit and/or who register on the Website ("Participants"). This Privacy Policy sets forth the type of information we collect from Participants, what may be done with the information, and how to correct or change the information. This Privacy Policy is incorporated into our Terms of Service and the Official Rules of each sweepstakes, contest or game, as may be applicable, which can be found by clicking on the Terms of Service or Official Rules links on the Website.

BY REGISTERING ON THE WEBSITE OR OTHERWISE USING THE NETWINNER SERVICE, YOU AGREE TO THE TERMS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY YOU MAY NOT REGISTER. IF YOU ARE ALREADY REGISTERED, YOU MAY NOT PARTICIPATE IN THE SERVICE.

1. Visitors to our Website
   For each visitor to our Website, located at www.netwinner.com, our web servers automatically recognize the visitor's domain name, approximate geographic location and email address (when possible).
2. Collection of Personally Identifiable Information
   Personally Identifiable Information means the Participant's name, residence address, e-mail address, telephone number or other information from which the Participant's identity may be reasonably ascertained. NetWinner collects Personally Identifiable Information (PII) from our Participants at several different points on our Website. NetWinner is the sole owner of the information collected on our Website. In addition to the information provided by Participants, NetWinner may also collect information about our Participants from third party sources. Certain advertisements or links on our Website may take you to a third party website, in which case NetWinner is not responsible for any Personally Identifiable Information (PII) you may disclose.
3. Registration
   In order to use our Website, enter any sweepstakes, or otherwise participate in any aspect of the Service, you must first complete the registration form and create a user name and password.
   • 3.1 Required Information
     During registration you are required to give information such as name, gender, birth date, zip code, country of origin and email address. If a Participant wins certain prize levels, additional information may be required to claim the prize as set forth in the Terms of Service, this Privacy Policy (see Sweepstakes, Contests and Surveys below), any Prize Confirmation Emails or the Official Rules of any particular sweepstakes, promotion, game or contest, as may be applicable, each of which are incorporated herein by reference.
   • 3.2 Accurate Information
     It is important to provide accurate and valid information when you register, especially a working email that you check frequently. Our primary method of contact when you win any prize in a sweepstakes will be a Prize Confirmation Email sent to the email address entered in the Participant's registration information. As set forth in the Terms of Service Agreement, the name you register with must be your real name and will be verified for certain prize awards. Failure to provide accurate information may result in disqualification and forfeiture of any prize won as set forth in the Terms of Service.
   • 3.3 Administrative Matters
     We may also use the information collected to contact you regarding administrative matters, such as a change in our policies, or about any services on our site in which you have expressed interest. If you do not have a valid email address you may be deemed ineligible and forfeit any prize award pursuant to our Terms of Service.
   • 3.4 Optional Information
     After registration a Participant may, at his or her own option, voluntarily provide additional information, including personal and demographic information. Please note that you are not required to provide this information in order to play in the NetWinner Sweepstakes or otherwise participate in the Service.
4. Access to PII If your PII changes, or if you no longer desire to use our Website, enter any sweepstakes or otherwise participate in any aspect of the Service, you may correct, update, delete or deactivate your account by making any desired changes on your My Account page. You may also contact us by emailing our Customer Support at support@netwinner.com or contacting us by snail mail using the address located at the top of this page. NetWinner will respond to a request made through these methods as promptly as practicable.
5. E-mail Communications
   NetWinner uses various email forms as a way for users, partners, potential participants, Participants and others to communicate with NetWinner. We collect the information supplied by the sender of the particular email form in order to establish and maintain relationships with, partners, potential participants, Participants and others. We also use various e-mail links located on the different pages of the Website to allow anyone to contact us with questions or comments they may have. NetWinner welcomes these e-mail communications and makes efforts to respond to these communications in a timely manner where appropriate. E-mail communications and the ideas sent to NetWinner in these e-mail communications become the property of NetWinner. We will use the e-mail communications to evaluate and improve our services and the Website. We may also save these e-mail communications for future reference or use.
6. Choice/Opt-out
   In certain cases, you have the option to limit the personal information you provide. Whenever possible, we will provide you the opportunity to 'opt-out' of providing PII or having your PII used for certain purposes at the time we ask for this information. Further, you may opt out of certain communications by entering your preferences on your My Account page. If you no longer wish to receive our newsletters or other promotional communications, you may opt-out of receiving them by following the unsubscribe instructions included at the footer of each message. If for some reason you are unable to opt out, you may also contact us by emailing our Customer Support at support@netwinner.com or by snail mail using the address located at the top of this page. NetWinner will respond to a request made through these methods as promptly as practicable.
7. Non Opt-out Communications
   Notwithstanding anything to the contrary in the Privacy Policy, in the Terms of Service, or elsewhere, NetWinner does not allow Participants to opt out of specific types of communications or required disclosures of PII. Once you have registered and submitted the required PII, you may not participate and you must disable your account on the My Account page if you do not wish to receive the following emails: Administrative Emails and Prize Confirmation Emails.
8. Sweepstakes, Contests and Surveys
   NetWinner provides you the opportunity to participate in the NetWinner Sweepstakes and other promotions, contests and games through the Service on our Website. In order for you to participate, you must register and if you win, we must request certain PII from you. NetWinner uses Participant information to monitor, interpret, analyze and report Sweepstakes results. Participation in the NetWinner Sweepstakes or any other aspect of the Service is completely voluntary and you therefore have a choice whether or not to disclose this information.
   • 8.1
     The required information typically includes contact information (name, email address, etc...) and demographic information (zip code, age, etc...). Other information may be required if you enter and win any prize (postal address, phone number). In the case of cash winners who win prizes in excess of $600 in any calendar year we will also require information such as Social Security Number and Picture ID as may be required to properly identify the winner and comply with any governmental or tax obligations. You may also be required to sign certain waivers and releases as a pre-condition to obtain any prize award, as may be more fully explained in our Terms of Service or Official Rules that may be applicable to any sweepstakes, promotion, contest or game. This information will not be collected or stored online.
   • 8.2
     We may use a third party service provider to conduct certain surveys, contests or promotions. Any third party service provider shall be prohibited from using our Participants' personally identifiable information for any other purpose. NetWinner may use this information internally or share the information you provide through a contest or survey with selected partners to provide you with relevant information.
9. Cookies
   NetWinner uses cookies to make your experience more enjoyable on the Website. A cookie is a small amount of data sent to a user's browser and stored on a user's computer for record-keeping purposes. In order to provide the highest level of service, we do link the information we store in cookies to any PII you submit while on our site. We use both session ID cookies and persistent cookies. We use session cookies to make it easier for you to navigate our site. A session ID cookie expires when you close you browser. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your internet browser's "help" file. If you reject cookies, you may still use our site, but your ability to use some areas of our site, such as contests or surveys, may be limited. Certain areas of our Website that require sign in or that are customizable may require the acceptance of cookies. Some of our business partners (e.g., advertisers) may use cookies on our site when placing banner advertisements. We have no access to or control over these cookies. Cookies are also used to monitor responses of Participants and other users to various aspects of the Service including, among other things, contests, surveys, polls and advertising in order to generate reports and track history. With respect to cookies, you have a choice. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies, you will be unable to use those NetWinner services that require the use of cookies in order to participate.
10. Action Tags
    NetWinner may also use action tags on the Website and in e-mail communications with Participants. An Action Tag is a small graphic image that is 1 pixel x 1 pixel that NetWinner or one of our Partners places on a page of the Website. NetWinner may also occasionally place Action Tags in e-mail messages that we send to Participants or other users. Action Tags provide us with important information about how Participants use the Website, the Service in general and respond to e-mail messages. This helps us to more effectively track certain promotions and better understand our communications with Participants. NetWinner may also allow its advertisers and other Partners the ability to use Action Tags on the Website solely to track Participants or other users who link from their respective sites to our Website. This ability to use Action Tags and track such activity does not allow these entities any access to a Participant's PII to which they are not otherwise entitled.
11. Refer-A-Friend
    The NetWinner Refer-A-Friend service authorizes us to send an email to your friends on your behalf. If you choose to use our Refer-A-Friend service to tell your friends about our site, we will ask you for your friends' names and email addresses. We will automatically send your friends a one-time email inviting them to visit the Website and register. NetWinner stores this information for the sole purpose of sending email and tracking the success of our referral program. Your friend may contact us at support@netwinner.com to request we remove this information from our database. There will also be information on how to be automatically removed in the one-time email.
12. Certain Uses of Information
    NetWinner uses PII and other aggregate information to deliver our Service. We may use the information users and Participants provide, among other things, to improve the content of our Website, to customize the content and/or layout of our Website for each individual Participant, to notify Participants about updates to our Website, to contact Participants for marketing purposes, to monitor site traffic, to personalize the site or to send Participants an email newsletter. Other than Prize Confirmation Emails and Administrative Emails, NetWinner participants may receive periodic email notices including exclusive special offers, promotions, surveys, newsletters and other relevant information. A Participant's email will be used by NetWinner to contact that Participant about Participant selected interests. As we are always trying to improve the NetWinner experience and provide Participants with information they may be most interested in, we may also conduct internal research on our Participants' demographics, interests and behavior based upon information Participants provide directly to NetWinner, information we may collect from the Website and information we may collect from third-party sources and/or through the use of cookies and session ID information (see above). Net Winner may combine or otherwise overlay some or all of the foregoing information to build profiles about our Participants, which may be individual, specific, or in aggregate form. NetWinner does not use information about its Participants for any purposes unrelated to the services offered by NetWinner and its selected partners. If you no longer wish to receive these emails, you may opt-out of receiving them by following the instructions included at the bottom of the email. If you are unable to opt out, contact us by emailing our Customer Support at support@netwinner.com or by snail mail using the address located at the top of this page. NetWinner will respond to a request made through these methods as promptly as practicable.
13. Aggregate Information
    NetWinner may track and analyze non-identity and aggregate usage and statistical information from those who visit our Website. NetWinner monitors and may collect incoming and outgoing Website traffic data such as standard log file information and session ID information to, among other things, analyze site traffic, diagnose problems with servers, administer the Website, improve site performance and prevent fraud. Session IDs are bits of code on your computer that assist your browser in navigating our site. We do not associate PII with log file information except when needed to prevent fraud. NetWinner may also use this data in part to assemble aggregate demographic information about its Participants and visitors in general. As a result of this data collection and analysis, NetWinner can better provide relevant and targeted content, offers and information from NetWinner and its partners. Further, with respect to advertisements, NetWinner strives to bring Participants offers that may be of interest to them by using this aggregate information to create relationships with third parties that we will allow to place advertisements on our Website. As a result of your visit to our Website, third party companies may collect aggregate information such as your domain type, IP address and other non-identifying information
14. Confidentiality
    NetWinner does not provide PII of our Participants to third parties except as noted under Section 13 and elsewhere in this Privacy Policy. NetWinner uses proprietary technologies to preserve the anonymity of Participants while matching the Participants interests with targeted information sent via e-mail. It is solely the Participant's discretion if he or she chooses to provide or have NetWinner provide PII to a marketer by designating preferences, requesting additional information, requesting NetWinner transmit their information or communicating directly with a third party company or organization after visiting its website or otherwise.
    
    All NetWinner employees are required to comply with the terms of this Privacy Policy. This Privacy Policy provides that employees are obligated to keep Participant information confidential. This obligation continues once an employee has left our Company.
15. Exceptions to Confidentiality
    As a necessary part of our business activities, NetWinner may disclose certain information about our Participants to certain third parties, principally: (1) NetWinner's Partners; (2) Marketers who use NetWinner's network of Participants; (3) third parties who provide services to NetWinner; and, (4) NetWinner's advertisers. Below is the information and circumstances under which NetWinner may disclose information to third parties.
    • 15.1 Winners
      As set out in NetWinner's Terms of Service or otherwise in any Official Rules which may be applicable, each potential winner of cash or prizes totaling $600 or more in a calendar year will be required to sign an affidavit of eligibility, release of liability and publicity, including, but not limited to, the use of winner's name, hometown and photograph, without additional compensation (where lawful), which must be signed, notarized and returned within ten (10) business days of receipt, or the prize will be forfeited and the potential winner will be disqualified. Each winner's name, city and country of residence may be shown on the NetWinner Website for a period of time after the winning drawing and immediately on NetWinner's list of winners, which will include each winner's name, city and state, the value of the prize won, and the dates upon which the prize was won and delivered to all such winners. Except as provided in this Section 15 and subject to the exceptions set forth elsewhere herein, NetWinner will not provide any other PII about winners
    • 15.2 Partners
      If a NetWinner Participant registers through the website of a Partner, we may be obligated to disclose the information submitted by that Participant during the registration process to that particular Partner. In addition, NetWinner may also disclose aggregate level information to the Partner about NetWinner Participants who registered through that particular Partner's site. Such aggregate information may include, for example, the number of individuals who registered through the Partner's site; the turnover rate of Participants who have registered through the Partner's site; the response rates of the Participants who registered through the Partner's site with respect to any particular marketing campaign; and, statistics on the interest categories selected by the Participants who have registered through the Partner's site. Subject to the exceptions discussed herein, NetWinner will not knowingly disclose any PII about a NetWinner Participant to a Partner unless such PII was provided during the registration process through the Partner's website.
    • 15.3 Marketers
      NetWinner will disclose aggregate level information about our Participants to marketers as may be reasonably necessary to explain the services NetWinner can offer, to report on the advertising campaigns NetWinner undertakes for any particular marketer, to implement and explain campaign strategies and/or any other reason which may be necessary to effectuate marketing campaigns in the sole discretion of NetWinner. NetWinner may also share PII of Participants with marketers from time to time for the purposes of promoting prize awards, direct mail campaigns and telemarketing. NetWinner may from time-to-time share PII of Participants who have opted-in to receive messages from our advertisers with marketers for the purposes of direct mail campaigns, telemarketing, data appending processes and other such marketing services. By consenting to receive special offers from our marketing partners, you are consenting that we may share your information with our marketing partners so that they can contact you with information about products and services which may be relevant to you. These marketing partners provide services for direct marketing applications including lookup and reference, data enhancement, suppression and validation. Though we are selective with whom we partner, we do not control the practices of our marketing partners. Notwithstanding, you may opt-out from receiving future email messages from our partners by following the instructions which should included in all partner emails.
    • 15.4 Third Party Service Providers
      From time-to-time we contract with outside third parties to perform specific services in support of our products and services. We may disclose PII to such third parties. For example, we may use an independent survey company to help us conduct surveys, a polling company to assist with polls, or a contest company to offer drawings. In these cases, we will use reasonable efforts to obtain agreements from these third parties to safeguard any NetWinner Participant information that is protected by this Privacy Policy in a manner consistent with this Privacy Policy.
    • 15.5 Advertisers
      Some of our advertisers have asked us to help them with registration to their services. As a result, NetWinner might display some banners which automatically start a registration process for third party services. NetWinner will always give the choice to a Participant with at least one non-data transfer banner in the banner page. A transfer of the Participant's data (as may be entered by Participants during the NetWinner registration process) is originated by NetWinner. This data is sent to the advertiser. In order to protect your privacy, such banners clearly indicate this automated sign-up process, in addition, by clicking on such banners, Participants are taken to a page where they can cancel the data transfer at any time. These advertisers also have to allow NetWinner's Participants to unsubscribe from their service. We encourage Participants to notify us of any abuse if such requirements are not met by our advertisers. NetWinner may from time-to-time share PII of those Participants who have opted-in to receive messages from our advertisers with marketers for the purposes of e-mail campaigns, direct mail campaigns, telemarketing and other services. NetWinner may from time-to-time share PII of members having expressed an interest in a particular offer by responding to a form, poll or other query on the Website. By submitting an answer, Participants give permission to NetWinner to send them relevant offers.
    • 15.6 Legally Required Disclosures
      NetWinner reserves the right to disclose a participant's PII as may be required by law and when we believe disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on our Website. Due to the legal, regulatory and security environment in which we operate, under certain circumstances NetWinner may be required to disclose aggregate level and/or PII about our Participants. NetWinner will use its best reasonable efforts to limit such disclosure to the following: where NetWinner believes in good faith that it is required to do so in response to a subpoena, warrant or other legal process; where reasonably required to do so in order to maintain, update or otherwise implement NetWinner's data security measures, equipment, technical operations and the like; or where reasonably necessary to identify, contact or bring legal action against persons or entities to preserve and/or enforce NetWinner's rights. Further, we can, and you authorize us to, disclose your PII, including but not limited to, name, street address, city, state, zip code, country, phone number, e-mail, and company to third party agents as we, in our sole discretion, believe necessary or appropriate in connection with an investigation of fraud, intellectual property infringement, piracy or other unlawful activity or activity that may expose us to legal liability.
16. Children's Safety Ad Protection
    Childrens' safety and protection is very important to us at NetWinner. Our Website is a general audience site and it is not directed to children under the age of 13. Further, the NetWinner Service is not directed to or intended for anyone under the age of 13. NetWinner's Terms of Service and eligibility rules do not allow a person to register if they are under the age of 13. NetWinner will neither knowingly accept Participants who are under the age of 13 years nor will it knowingly collect or maintain PII from or about anyone under the age of 13 years. However, we have no way to actually verify age at registration and so NetWinner relies on the truthfulness of the information entered at registration when accepting new Participants. In the event that NetWinner receives information establishing that a registered Participant is under the age of 13 years, we reserve the right to terminate that Participant's eligibility or take other steps we believe are appropriate in the circumstances, such as providing parental notification. NetWinner may also delete all information in our databases about a Participant terminated for these reasons. If you believe NetWinner has any information from or about anyone under 13, please send us an email to support@netwinner.com.
17. Security
    The security of your PII is important to us and we will not knowingly allow access to this information to anyone outside NetWinner other than to the Participant or as otherwise described in this Privacy Policy. NetWinner has made substantial investments in our security, server, database, backup and firewall technologies to protect our information assets, including the confidentiality of information collected about our Participants. These technologies are deployed as part of an advanced security architecture and protocol. You should also do your part in protecting your PII. Your password is confidential and we recommend that you not divulge it to anyone. Once we receive PII, NetWinner undertakes substantial efforts to protect the confidentiality of this information consistent with this Privacy Policy. Your information may be stored, processed and transferred to or from the United States or any other country where NetWinner, its Partners, affiliates or agents are located. When you enter sensitive information we encrypt that information using secure socket layer technology (SSL). We follow generally accepted industry standards to protect the PII submitted to us, both during transmission and once we receive it. However, no method of transmission over the internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your PII, we cannot guarantee its absolute security. Thus, any information a Player transmits to us is done so at the Player's own risk. If you have any questions about security on our Website, you can send email to us at support@netwinner.com.
18. Sale of Assets
    In the event NetWinner enters into a business transaction such as a merger, acquisition by another company, or sale of all or a portion of its assets, our Participants' PII will likely be among the assets transferred. You will be notified via email of any such change in ownership or control of your personal information.
19. Contact Us
    If you have any questions about this Privacy Policy, NetWinner's practices, or feel that your privacy has been compromised, please email Customer Service at support@netwinner.com. Alternatively, you may contact us at the address listed at the beginning of this Privacy Policy.
20. Changes in this Privacy Policy
    NetWinner reserves the right to modify this Privacy Policy at any time, in our sole discretion, so please review it frequently. If we make material changes to this policy, we may notify you by email, by means of a notice on our home page or by actually posting the changes on the Website. Your continued use of the NetWinner Service following the posting of changes to this Privacy Policy will mean you accept those changes.

NetWinner Privacy Policy Version 1.0
This Privacy Policy was last updated on: July 10, 2006