Privacy Statement for Piczo

Updated December 2008

About Piczo.

Piczo (interchangeably, "Piczo", "the Site", "we", "our", "us") is a website creation and self-expression tool that allows you to register and create your own Piczo website. We allow our members to create, upload and store pictures, text and other information on their personal web pages. Piczo also contains social networking features that allow you to build lists of friends and interact with those friends as well as other Piczo members.

We are committed to maintaining the privacy of your personal information (Personal Information) and have developed this privacy statement (Privacy Statement) to let you know how we collect, maintain and use the information we receive.

This Privacy Statement applies to all Personal Information collected or submitted through the Site. Whenever you create, upload or store personal information in public areas of the Site, like your publicly viewable personal web pages, guestbooks, comment boards, shoutboxes, and profile pages, that information becomes available to the public. The publicly available information can be used by others to send you unsolicited communications or for other uses or communications. You should therefore exercise discretion in deciding what information you create, upload or store on public parts of the Site. Ultimately, your personal information and your privacy remain under your control. Piczo provides you with privacy features to enable you to permission who can see your site and block members if you so choose.

What's Covered?

1. Children
2. The Personal Information we collect
3. How we use your Personal Information
4. Email Communications
5. How we share your Personal Information
6. Cookies
7. Third Party Advertising and Cookies
8. Third Party Links
9. Acquisition
10. Security
11. Limiting access to your website
12. Approving New Posts
13. Non-US residents
14. Privacy Compliance
15. Contacting Piczo
16. Changes
17. Canceling the Service
18. Internet Safety

1. Children. During the registration process Piczo collects limited Personal Information, such as the child's (Child's) age and the parent or guardian's (Parent's) email address in order to process the Child's registration request. Piczo does not collect any other Personal Information of children registering for Piczo under the age of 13 without prior consent of the Child's Parent's. If you are under the age of 13 you must get permission from your Parent to use Piczo by providing Piczo with a valid email address for your Parent. Piczo will email your Parent and request that they activate your membership before you can begin using Piczo. Once we have your parent's approval, it is up to you the Child and your Parent to control the Personal information you post and this information is shared.

If you are a Parent and you would like to review your Child's Personal Information, have your Child's site cancelled and for Piczo to discontinue any further collection of the Child's information, you may click here to alert us. Please include the following information with your request so that we may verify that you are the Child's Parent. We will keep this information on file as a record of your request. We will not use this information for any other purpose than identity verification.

• Child's Full Name
• Child's Piczo Username and/or Site name
• The Child's Birthday
• Your Full Name
• Your Relationship to the Child
• Your contact information including address, day and evening phone number, and email address
• A statement indicating you are the Child's Parent or Guardian.

If you are between the age of 13 and 17, you are encouraged to obtain permission from your Parent to use Piczo. Depending on the nature of any customer service inquiries, the Piczo Staff may advise teenagers to get Parents' permission in order to continue the service.

2. The Personal Information we collect. In addition to the information that you post on your personal web pages, we collect and store Personal Information as part of your account or profile, such as contact information (for example name and e-mail address), as well as zip code/postal code, gender, and age. Our systems also collect and store non-personal information such as your IP address, specific type of browser, the pages you visit at the Site, and information from cookies. We may use and share non-personal information to provide better and more relevant services and advertisements to our members.

Once a parent provides consent to activate a Child's account, Piczo may request Personal information from the Child. The Children's Online Privacy and Protection Act ("COPPA") requires us to inform Parents about how we collect, use, and disclose Personal information from children under the age of 13. Under COPPA Piczo does not require Personal information from children under the age of 13 to participate in our service other than what is reasonably necessary for the child to participate in the service.

3. How we use your Personal Information. We collect your Personal Information only for the purpose of providing you specific services or as we believe necessary for our legitimate business interests; including, but not limited to, market research, demographic analysis, and site performance and usage. For example, we use usage patterns to determine what features of the service are particularly useful to members, which features are not, and identify potential areas which need to be developed to meet our member's needs.

4. Email Communications. We use your email address to send you information about the Site, announce new features and to update you about our services. We may occasionally use your user name and password to inspect your website or to evaluate or correct problems with your account. We also use your email address to alert you of any new friend invitations and when you receive new messages on your website. These emails will give you the option to choose if you do not want to receive future emails ("opt-out"). Opt-out options are also included under Account Settings when logged into your Piczo site.

5. How we share your Personal Information. We will not sell, rent, or otherwise make your Personal Information available to third parties, except if we reasonably believe we are required to do so by law, regulation or other government authority or to protect the rights and property of Piczo, its affiliates or the public. We may also cooperate with law enforcement agencies in any official investigation and we may disclose your personally identifiable information to the relevant agency in doing so, for example, in order to enforce or apply our Terms of Service or Acceptable Use Policy, or to protect our rights, property, or safety of Piczo, our members, users or others.

6. Cookies. We use technology such as "cookies" to help us analyze the use of the Site. Cookies are small files placed on your hard drive that assist us in providing our services. Certain features on the Site may only be available through the use of cookies. Our cookies only store certain information, which enhances your experience of using the Site. It also enables us to track the traffic on the Site and may for example store your IP address and the time when you visited the Site. Through the use of cookies, we collect and transmit user name, cluster ID, demographic and geographic data, last login time, IP address, whether the member viewed an image on Piczo prior to visiting Piczo.

7. Third Party Advertising and Cookies. In connection with advertisements on the Site, our third-party advertising sales company, third party ad servers, and our advertisers may place or recognize a unique "cookie" on your browser. This Privacy Statement does not cover such third-party cookies. We may aggregate usage information that we collect in a non-personally identifiable manner to advertisers and other third parties in order to present to members more targeted advertising, products and services.

Piczo does not currently advertise to our members under the age of 13.

8. Third Party Links. Our Site may contain links to other websites. When you click on one of those links, you are accessing a website that is not owned, operated, or controlled by us or any of our affiliates. The operator of such a site may have its own privacy policy (which we encourage you to read carefully). That policy will govern the collection and use of your data on that site.

9. Acquisition. We reserve the right to transfer your Personal Information to an acquirer in connection with a transfer of ownership of Piczo, such as a sale to or merger with another company.

10. Security. We will take reasonable precautions to protect Personal Information from loss and unauthorized access. However, these measures, standing alone, are not sufficient to ensure the security of your Personal Information. It is also important for you to guard against unauthorized access to your passwords and the unauthorized use of your computer.

11. Limiting access to your website. Piczo gives you the option to protect your personal web pages by requiring that visitors use a password to access those pages. We recommend that you give your viewers a different password than the one you use to author your site. Note that visitors with a password could forward their password to others, who would then be able to access your personal web pages as well. These controls are located under Account Settings to password protect your entire website, and under Organizer, to protect certain pages of your website.

12. Approving New Posts. Piczo gives you the option to approve posts made to your site before they are made publicly visible. You can turn this feature on by clicking the Pencil icon next to a guestbook, shoutbox, or comment board and un-checking "Approve new messages automatically."

13. Non-US residents. If you are not a US resident, your use of our Site constitutes your agreement and consent to the collection, transfer, storage, use and disclosure of your Personal Information to and within the United States in accordance with this Privacy Statement.

14. Privacy Compliance. By using the Site, you consent to the collection and use of your information as set forth in this Privacy Statement and any dispute over privacy is subject to this Privacy Statement and our Terms of Service, as applicable. If you have any concerns about the privacy or security of your Personal Information, please click here to contact us. We will attempt to resolve your inquiry in a timely manner.

15. Contacting Piczo. If you have any questions or concerns about the Piczo Privacy Policy, you can contact us at:

Piczo, Inc.

150 California St.

Suite 1000

San Francisco, CA 94111

415.358.4887

Email click here

16. Changes. Piczo reserves the right to change these Terms at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we make, as they are legally binding on you. Some of the provisions contained in Terms of Service may also be superseded by provisions or notices published elsewhere on our site. Any changes made to these Terms will automatically be effective 30 days after they are posted on this page. If you continue to access Piczo after a notice of a change has been published, that means you are agreeing to the new Terms. If you do not agree to a change, you must terminate your membership with Piczo.

17. Canceling the Service. You can cancel your service at any time. Please click here for information on how to cancel your membership.

When you cancel your Piczo services, or, if your Piczo service is terminated, your information will no longer be available online. Piczo may retain a copy of your information, including browser information, for archival purposes.

18. Internet Safety. For more information on keeping yourself safe online, please visit our Safety page.