STORMGLASS PRIVACY POLICY

Effective Date: November 1, 2012

Stormglass Ventures, LLC ("Stormglass") is committed to providing children of all ages with a fun, entertaining, and safe online experience. We are dedicated to safeguarding any personal information we collect, providing parents with peace of mind that any such personal information, especially for those children under the age of 13, is respected and safeguarded and helping parents and children exercise control over the collection and use of such personal information. Our information collection practices are designed to comply with the requirements of the United States Children's Online Privacy Protection Act ("COPPA"). The Stormglass website is designed for and targeted to U.S. audiences and is governed by and operated in accordance with the laws of the U.S. We encourage parents and legal guardians to become involved in the online activities of their children and discuss the child's use of the Internet and disclosure of personal information to anyone.

Personal Information Collection and Use Policies

It is our policy to require only the minimal collection of information from our users ("Stormglass Agents"). We do not condition a child's participation in any of our online activities on the disclosure of more information than is reasonably necessary to participate in the activity. As the safety of Stormglass Agents is our highest priority, we do require parental consent when a child wants to register to participate in our online activities and have devised a registration system that is intended to be completed by the parent on behalf of their child.

During the registration process, we will collect the child's first name (for one-time use in personalizing the introductory videos), parent's email address, child's username (not a personally identifiable name) and child's password. We ask for username and password so that each time a player logs on they have their saved, personalized information. We ask for a parent email so that we can send an email to the parent asking for their consent to activate the child's account. Children are unable to reveal personal information online or communicate directly with other players online. We may also use the parent's email address to send information on emergency Stormglass Agent mission assignments available to their child.

We may also collect additional types of personal information from parents or guardians (such as credit card billing information and mailing address) when acquiring a paid membership to the Stormglass online activities, or purchasing items from Stormglass. A billing address collected during the purchase of a subscription may be used to send welcome information, Agent verification documents, badge and other accessories and other marketing materials. We use a third party vendor to process the payment data and they are contractually required to protect the privacy and security of the data. We do not store any of the credit card information in our systems.

For some of our online activities - such as for particular missions - we may ask users to provide information that is not personally identifiable, such as country of residence or a Stormglass Agent's favorite color.

While the parent email addresses we collect are primarily used for our account activation and password retrieval systems and to verify parental consent of children to use the Stormglass website, we also retain the right to communicate safety and privacy messages, general updates, and usability features via email. We may also send marketing materials such as special offers, coupons, and promotions for Stormglass members. Parents can unsubscribe from these messages at any time by following the "unsubscribe" instructions found in the emails.

If an account has been inactive for 12 months or longer, we reserve the right to purge all of the user information associated with the account from our systems.

Non-Personal Information Collection and Use Policies

Additionally, when visitors come to our website, we may passively collect certain non-personally identifiable information through technology we use to make our website more interesting and useful to you. We routinely collect our users' visit information, including the pages visited, the date, time and frequency of visits, IP address, and the version of browser or operating system used. We use this information for improving Stormglass's content and services and for investigating cases of suspected abuse.

Stormglass may use cookies, web beacons, or similar tracking technologies to collect certain non-personally identifiable information. Cookies (which may be html files, Flash files or other technologies) are small text files that we place in visitors' computer browsers to store their preferences. Cookies themselves do not contain any personally identifiable information. Although cookies could enable us to relate a visitor's use of this website to personal information that a visitor has provided, such as an email address, we do not use them for this purpose. We do use "cookies" to determine how many visitors we have and how often they visit various sections of our website. You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn on/off all cookies. You do this through your browser settings. Please note that most browsers are automatically set to accept cookies. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookies. If you turn cookies off, some of our services may not function properly. We may use other standard Internet technologies, such as web beacons (also known as image tags, gif or web bugs which are small pieces of code used to collect advertising data, such as counting page views, promotion views or advertising responses) to, for collect other non-personally identifiable information for similar purposes.

Third Parties

Other than to process payment data, we do not share any personally identifiable information of our users with any third parties, commercial or otherwise, except that we may provide such information to parties involved in a merger, consolidation or other reorganization of Stormglass or to a party that purchases substantially all of our assets related to the website. We may, however, also comply with requests for personally identifiable information from law enforcement or other governmental agencies, or requested pursuant to subpoena. We may share aggregated statistical data with our sponsors, partners, or the general public.

This privacy policy applies only to information collected on this website. The website may contain links to other websites that are not owned or controlled by Stormglass. Please be aware that we are not responsible for the privacy policies of such other websites. We encourage you to be aware when you leave the website and to read the privacy policies of each and every website that collects personally identifiable information.

Data Security

The security, integrity and confidentiality of your information are extremely important to us. We have implemented technical, administrative and physical security measures that are designed to protect user information from unauthorized access, disclosure, use and modification. From time to time, we review our security procedures to consider appropriate new technology and methods. When you enter sensitive information, such as your credit card number, we encrypt that information using secure socket layer technology (SSL). Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable.

We may transfer your personal information to third parties in locations around the world for the purposes described in this privacy policy. Wherever your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information.

Parental Review of Information

Parents who wish to access personal information that we have collected online from their child, correct factual errors in such information, request to have this information deleted, or request that we no longer collect or maintain such information may do so by sending an email to privacy@stormglass.com. Please be sure to include your email address and a telephone number where we can reach you. To protect your child's privacy and security, we will take reasonable steps to verify your identity before granting you access to any information pertaining to your child.

Your California Privacy Rights

California Civil Code Section 1798.83 permits our users who are California residents to request certain information regarding our disclosure of our users' personal information to third parties for their direct marketing purposes. To make such a request, please send an email or write us:

Stormglass Ventures, LLC
ATTN: Privacy Coordinator
#31103147, PO Box 311
Mendham, NJ 07945
privacy@stormglass.com

Contact Information

Stormglass.com is owned, produced, operated and maintained by Stormglass Ventures, LLC. For questions regarding Stormglass, please email privacy@Stormglass.com. Please note that this email address is used only to respond to inquiries related to user privacy.

Stormglass Ventures, LLC
ATTN: Privacy Coordinator
#31103147, PO Box 311
Mendham, NJ 07945
privacy@stormglass.com

A Final Note to Parents

Parents are strongly encouraged to participate in their children's online activities and monitor their children's use of e-mails, instant message programs, and engagement in other electronic communication. For more information about COPPA or children's privacy, please visit www.ftc.gov/bcp/menus/consumer/data/child.shtm.

The Internet offers a world of opportunity for children. Your guidance and involvement are essential to help ensure that children have a safe and rewarding online experience. We encourage you to visit GetNetWise.org or SafeKids.com and review their online safety tools and information. Your efforts to instill responsible information practices will help steer your children to age-appropriate websites and will go a long way toward ensuring that your children have enriching experiences online.

Effective Date

This Privacy Policy was last updated on November 1, 2012, and applies to all information previously obtained by Stormglass. Stormglass reserves the right to change its privacy policy at its sole discretion. Stormglass users will be informed of any such material change by Stormglass posting a new privacy policy on the Stormglass website. The effective date of any change of the privacy policy will be clearly marked. Please review this Privacy Policy regularly so that you will be aware of any changes to it. Your continued use of the Stormglass website and/or provision of personally identifiable information by you to us following any such revision means you accept and will be subject to this privacy policy.

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