This page sets forth the privacy policies and practices of: (i) Asiad, Inc.; (ii) any company which controls, is controlled by or is under common control with, Asiad, Inc. (all such companies and Asiad, Inc., each an "Asiad company" and, collectively, "Asiad", "we" or "us"); and (iii) each website (each a "Site") operated by us.

Please read this privacy policy carefully. By visiting any of the Sites and sharing information with us, you agree to be bound by the terms and conditions of this Privacy Policy.

Section 1. Consumer Privacy

(a) Information Collection. Asiad collects a variety of information about individual internet users ("Consumers"). Outlined below are the types of information the Sites collect with respect to Consumers.

(i) Personally Identifiable Information ("PII"). The Sites are designed to promote and facilitate business with our advertising and publishing clients ("Clients"). These Sites do not provide for-pay products or services to Consumers. However, Asiad may collect PII from Consumers under the following circumstances.

(A) Incentive Sites. Certain Sites offer product incentives to Consumers ("Incentive Sites"). Incentive Sites collect your name, email address, mobile phone number, and shipping address. We will initially use this information to: (i) set up your account; (ii) send you certain administrative emails related to your use and the operation of such Incentive Site(s), including, but not limited to, registration confirmation emails and notices of updates and revisions to the Site(s); (iii) send you a registration confirmation SMS; and (iv) log your shipping information so that we know where to send any incentive products you may earn.

(B) Information Collection Agent. When a Consumer responds to a Client advertisement or offer, Asiad may act as information collection agent ("Collection Agent") for such Client. As a Collection Agent for a Client, Asiad may collect PII from Consumers on behalf of such Client. We will collect only the information which the Client has requested us to collect.

Upon successful collection of the requested information, Asiad will transfer all such information to the appropriate Client. Prior to any such information transfer, each Consumer must consent to the transfer and acknowledge that such Consumer: (i) understands that the information is being transferred to the relevant Client; (ii) understands that once transferred the information will be subject to the privacy policy of such Client; and (iii) has read and understands the privacy policy of such Client. Each Consumer hereby releases Asiad from any and all responsibility and holds Asiad harmless with respect to any and all liability or damage resulting from or incurred in connection with the use of such Consumer's PII by any Client to whom Asiad transfers the PII in accordance with the terms of this paragraph.

Asiad may retain a backup copy of all PII provided to us in our capacity as Collection Agent. Any such PII will remain subject to this Privacy Policy.

It is important to note that when a Consumer responds to a Client advertisement or offer and Asiad is not acting as a Collection Agent for such Client, the Consumer will be redirected to the relevant Client's own website. Such website may have certain logos or other co-branding graphics from one or more Asiad companies; however, such website will be under the sole control of the particular Client to whose advertisement or offer the Consumer is responding. We do not have access to any PII that Consumers provide directly to any of our Clients. All such information is subject to the posted privacy policies of the relevant Client. We urge Consumers to review the relevant Client's privacy policy before providing any PII to such Client. Each Consumer hereby releases Asiad from any and all responsibility and holds Asiad harmless with respect to any and all liability or damage resulting from or incurred in connection with the use of such PII by Clients to whom such PII was directly transmitted as described in this paragraph.

(C) Correspondences. If you contact an Asiad company, we may keep a record of that correspondence.

Under no circumstances does Asiad request or collect certain sensitive PII including information regarding a Consumer's medical/health condition; racial or ethnic origin; political, religious or philosophical beliefs or affiliations; trade union membership; or sexual preferences.

(ii) Non-Personally Identifiable Information ("Non-PII"). When a Consumer responds to or views an internet advertisement or offer served by Asiad or visits a Site, we send a cookie and/or gif file (a "Cookie") to assign an anonymous, unique identifier to the Consumer's internet browser. Cookies are small data files commonly used on the Internet to help optimize and personalize the users' experiences and identify repeat visitors to websites.

Through Cookies, Asiad is able to track a limited range of Consumer activities on our Clients' websites. Such tracking is limited to providing Asiad with information for the purpose of: (a) paying third-parties commissions when a Consumer clicks on a link, creates a lead, or makes a purchase on a Client's website; (b) crediting Consumers with purchases and referrals toward the receipt of product incentives on our Incentive Sites; (c) calculating amounts owed to our Incentive Sites for referrals we send to Clients and (d) optimizing and personalizing the Consumers' experiences on the Sites. We reserve the right to retain all advertisement delivery and reporting data as long as may be reasonably necessary for accounting and audit purposes.

We use log files to collect information about Site users such as internet protocol ("IP") addresses, browser type, internet service provider, referring/exit pages, platform type, and date/time stamp. We use this information to administer the Site(s), understand aggregate usage and navigation trends, and determine the relevance of content. This information is not linked to any PII.

We also may use internet browsing and online purchase data ("Profile Data") associated with an anonymous identifier to develop a predictive statistical user profile of a Consumer's needs and interests. Asiad does not use Cookies or log files to collect end users' names, physical addresses, email addresses, phone numbers, credit card numbers, social security numbers, or any other information which can be used to identify a specific person. We may match the IP address and a Consumer's Profile Data with email address data obtained separately in order to better target campaigns to meet the Consumer's interests, but we will not share this information with third parties.

For improved audience targeting, some Sites may allow Clients to add non- personally-identifying demographic information, such as age, gender, area code, or ZIP code, to non-identifiable Profile Data we collect.

(b) Information Sharing. Asiad may share Consumer information under the following circumstances:

(i) Collection Agent. As more fully set forth in Section 1(a)(i)(B), Asiad may occasionally collect information from Consumers on behalf of our Clients. We will not share such information with the Client except pursuant to the terms and conditions set forth in Section 1(a)(i)(B).

(ii) Shipping Information. Our Incentive Sites encourage Consumers to participate in Client offers by providing product incentives. According to the terms of service of such Incentive Sites, we are obligated to deliver the promised incentive products to those Consumers who have fulfilled the requirements of a particular Incentive Site campaign. We typically engage trusted business partners to handle the supply and delivery of these incentive products ("Delivery Partners"). We share Consumer shipping information with Delivery Partners in order to allow them to ship incentive products to the correct Consumer. Our Delivery Partners are contractually: (a) obligated to use the same degree of care in protecting Consumer information as they use to protect all other confidential information and (b) prohibited from disclosing Consumer information to any third party or any staff member without the need to know such information.

(iii) Target Marketing. A Consumer may indicate a desire to receive marketing communications from Asiad and/or other third party marketing partners. In such circumstances Asiad will have additional rights with respect to such Consumer's PII as more fully set forth below.

(A) If a Consumer opts into the receipt of Asiad marketing communications, we will have the right to enhance and/or merge PII about such Consumer with commercially-available third party data collected from other sources in an effort to ensure that the messages being sent to the Consumer in online and/or offline marketing programs are relevant to their interests.

(B) If a Consumer opts into the receipt of third party marketing communications, Asiad will have the right to share such Consumer's PII (including information that has been enhanced with information from other sources) with advertisers and third party marketers for their online and/or offline marketing programs.

(iv) Business Combination. Asiad's Consumer information may constitute a substantial corporate asset. Asiad reserves the right to share any and all Consumer information for the purposes of valuing such asset in connection with any corporate transaction reasonably requiring such valuation; such transactions may include, among others, a sale, merger, consolidation, change in control, asset sale, reorganization, financing or liquidation of any Asiad company. Asiad will require each party, to whom such Consumer information is given pursuant to this paragraph, to be covered by a confidentiality agreement. Each such confidentiality agreement shall require the party receiving Consumer information to protect the confidentiality of such Consumer information employing a standard of care no less than that which it observes in protecting its own confidential information.

(v) Legal Compliance. Asiad may release account and any other personal information if we are legally compelled to do so. We may also release such information if we believe the release is necessary to: (a) enforce the Terms of Use of any Site, any User Agreement (as defined below), or any other agreement of any Asiad company or (b) protect Asiad, our users, our Clients, or others against fraud or otherwise protect the rights, property or safety of such persons or entities.

(c) Information Access. Most Sites do not maintain a process for an individual Consumer to review and/or request changes to any PII collected. The Incentive Sites do allow Consumers to make limited changes to their PII including changes to their email and shipping addresses. Note that changes to an email address will not be effected until the relevant Consumer has successfully completed the appropriate email verification process.

(d) Children's Privacy and Spam. Asiad is very sensitive to the issue of children's privacy and makes every effort to protect the privacy of children using the Internet. Our Sites, 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. If you believe your child has provided Asiad with any PII by registering at a Site, please send an email to to have the child's information removed and his registration cancelled.

Section 2. Client Privacy

(a) Information We Collect: Advertisers and Publishers

(i) Personally Identifiable Information. Asiad collects PII from all Clients. The collection of this information constitutes a part of our normal business practices. Examples of PII that may be collected include name, address, telephone number, email address, social security number and tax ID number. Under no circumstances does Asiad request or collect certain sensitive PII including information regarding a Client's (or any of its representative's) medical/health condition; racial or ethnic origin; political, religious or philosophical beliefs or affiliations; trade union membership; or sexual preferences.

(ii) Non-Personally Identifiable Information. Asiad may use Cookies and log files to optimize and personalize Clients' experiences and allow Asiad to monitor Site traffic patterns.

(b) Cookies. When a Client logs into any browser-based Asiad reporting system, a Cookie is placed on the Client's computer. The Cookie allows Asiad to validate the identity of the Client and maintain the security and privacy of the Client's account data. This Cookie is required to log into Asiad's reporting systems; there is no method to opt-out of this Cookie.

(c) Information Sharing. Except as may be separately agreed between an Asiad company and a Client, all PII data provided by individual Clients will be kept in strict confidence by such company and will be treated with the same level of respect and care that such company treats other proprietary information and trade secrets. Asiad will never sell, rent, exchange or barter any personally identifiable Client information to or with any third party for financial gain or marketing purposes.

Asiad does not use any PII about a Client for profiling purposes. PII that Asiad collects from Clients is principally intended to assist us operate and administer our business. Asiad may also share Client PII in the following situations.

(i) Advertiser/Publisher Relationships. Asiad may provide a Client's email address and basic account data to another Client to facilitate a working relationship between such Clients (e.g., between an advertiser and a publisher). Once a relationship is established, the Clients (and their agents and representatives) may share certain campaign information and PII. When Clients form such a relationship, each party thereto thereby agrees to allow Asiad to share with the other party any and all information whether PII or otherwise which Asiad deems necessary or appropriate in connection with our provision of products or services to either party. While Asiad strongly encourages Clients to adopt responsible approaches to online marketing, Asiad is not responsible for the information practices of Clients or their agents. The collection, use, and disclosure of information by Clients and their agents are subject to their respective privacy policies, which may differ from Asiad's policy.

(ii) Business Communications. Periodically Sites may use Clients' PII in order to deliver strategic marketing information and other communications to assist Clients in business related activities. Clients wishing not to receive such communications from an Asiad company may do so by "opting-out" during the registration and application procedure process. A Client may change their "opt" status at anytime by accessing their online account and changing the appropriate settings.

(iii) Third-party Vendors. Asiad may, from time to time, disclose Client PII to certain third-party vendors providing administrative or program management services such as billing, delivery, and payouts. Any third-party vendor so used will have agreed to protect the confidentiality of information provided by Asiad prior to any such disclosure.

(iv) Business Combinations. Asiad's Client information may constitute a substantial corporate asset. Asiad reserves the right to share any and all Client information for the purposes of valuing such asset in connection with any corporate transaction reasonably requiring such valuation; such transactions may include, among others, a sale, merger, consolidation, change in control, asset sale, reorganization, financing or liquidation of any Asiad company. Asiad will require each party, to whom such Client information is given pursuant to this paragraph, to be covered by a confidentiality agreement. Each such confidentiality agreement shall require the party receiving Client information to protect the confidentiality of such Client information employing a standard of care no less than that which it observes in protecting its own confidential information.

(v) Legal Compliance. Asiad may release account and any other personal information if we are legally compelled to do so. We may also release such information if we believe the release is necessary to: (a) enforce the Terms of Use of any Site, any User Agreement, or any other agreement of any Asiad company or (b) protect Asiad, our users, our Clients, or others against fraud or otherwise protect the rights, property or safety of such persons or entities.

Section 3. General Provisions

(a) Security. Asiad employs industry standard security measures to ensure the security of all data. Any data that is stored on Asiad's servers is treated as proprietary and confidential and is not available to the public. Asiad has an internal security policy with respect to the confidentiality of Consumer, Client, 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 Asiad products and services. Asiad routinely evaluates its data security practices to identify security threats or opportunities for improvement.

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

(b) Consent and Changes. Asiad 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 Asiad prior to the effective date of the policy change.

(c) Data Processing. By providing information to any Site, you acknowledge that it may operate across national boundaries and agree: (i) to permit Asiad to transmit and use your information anywhere necessary, including across international boundaries, to effect the services and transactions provided by such Site and (ii) that such use by Asiad shall be subject to the terms and conditions stated in this Privacy Policy and the relevant User Agreement.

(d) Limitation of Liability, Third Party Information and Language

YOU UNDERSTAND AND AGREE THAT ANY DISPUTE OVER PRIVACY IS SUBJECT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND (I) IN THE CASE OF CONSUMERS USING ONE OR MORE OF OUR SITES, ALL APPLICABLE TERMS OF USE OR (II) IN THE CASE OF CLIENTS, OUR ADVERTISER SERVICE AGREEMENT OR PUBLISHER SERVICE AGREEMENT, AS APPROPRIATE (EACH SUCH DOCUMENT, A "USER AGREEMENT"). ANY SUCH DISPUTE SHALL BE SPECIFICALLY SUBJECT TO ANY ARBITRATION PROVISIONS CONTAINED IN THE RELEVANT USER AGREEMENT.

YOU AGREE THAT, TO THE EXTENT SUCH CLAIM IS NOT OTHERWISE BARRED BY THE RELEVANT USER AGREEMENT, ANY ASIAD COMPANY'S LIABILITY FOR ANY BREACH OF THIS PRIVACY POLICY SHALL BE LIMITED TO THE LESSER OF THE VALUE OF THE TRANSACTIONS OR SERVICES PROVIDED TO YOU BY SUCH COMPANY OR US$250.

You also agree that you have provided notice to, and obtained consent from, any third parties whose personal data you supply to Asiad 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 disclosures are obligatory and which, if any, are voluntary; and (d) how the third party can access and, if necessary, correct the data.

(e) Contact Us. For more information or if you have questions or concerns regarding this Privacy Policy, please send an email to .

Posted October 12, 2005