4INFO Privacy Policy

Effective Date: August 12, 2011

4INFO is a mobile advertising company. We focus primarily upon three areas of business: 1) we provide an interactive media network (the "Network") to help our clients advertise via mobile websites, WAP sites, mobile apps, and other forms of media; 2) we offer a website (the "Website") that offers the largest selection of free text message alerts and information in the United States; 3) and we provide a mobile messaging technology platform (the "Platform") that enables our clients to deliver, track and report on text message alerts that our clients sent out via our platform.

This privacy policy explains how information is collected and used on the Website, the Platform and the Network by 4INFO and as applicable, the advertisers, WAP and website owners and other businesses that use our services (our "Clients"). If you have any questions about this privacy policy, please feel free to contact us at support@4info.com.

Policy for Information we Collect on this Website

This part of the privacy policy applies to the 4INFO web site www.4info.com and all subsidiary pages, including the SMS alerts you may sign up for on http://alerts.4info.com (the "Website").

Personally Identifiable Information

We collect Personally Identifiable Information ("PII") from the Website. PII is any information that can be used to identify or locate a particular person or entity. This includes, but is not limited to: name, address, telephone or cell phone number, or email address. We may collect PII under the following circumstances:

• When you choose to register with 4INFO on the Website, we will collect your email address and your cell phone number, and you will be required to provide a password as part of your registration. We may also ask for your wireless carrier, gender, zip code, occupation, industry, make and model of your mobile device, and your personal interests. You will also be offered the opportunity to receive 4INFO news via email and/or SMS. 4INFO may combine information about you that we have with information we obtain from our business partners.
• When you sign up to receive one of our SMS alert messages on the Website, or with our partners, we may ask you to register with us. (See above) If you register for an SMS alert via one of our partner websites, they will make it clear that you are registering with 4INFO, and provide you with a link to this privacy policy. Please note that you may also sign up to receive our SMS alerts without registering, by providing us with your cellular number via the Website.
• When you use 4INFO products and services, even if you do not register, 4INFO collects and stores information about your transactions with us. 4INFO automatically receives and records information on our server logs from your product or service usage including your cell phone number or IP address and all messages sent to 4INFO short codes.
• If you enter one of our partner's sweepstakes, we may ask for PII so that we may contact you in the event that you win the sweepstakes.
• When you choose to send us PII about yourself in an email or by completing an online form on this Website, we use this information only to contact you to respond to your inquiry or to fulfill your request to receive one of our business case studies or white papers. Once collected, we will store your PII for a reasonable time for record keeping purposes. The information that we store is usually deleted as space requires or in the normal course of business.

Non-Personally Identifiable Information

We collect Non-Personally Identifiable Information ("Non-PII") from visitors to this Website. Non-PII is information that cannot by itself be used to identify a particular person or entity, and may include your IP host address, pages viewed, browser type, Internet browsing and usage habits, Internet Service Provider, domain name, the time/date of your visit to this Website, the referring URL and your computer's operating system. When you register with us, we may ask you to provide information such as your wireless carrier, gender, zip code, occupation, industry, the make and model of your mobile device, and to select your personal interests. This information will be combined with your mobile phone number in order to serve targeted advertising to you.

Cookies

We use "cookies" on this Website in order to us to retain your login preferences if you sign up to receive our SMS alerts. Cookies are small text files that contain a string of alphanumeric characters. A persistent cookie remains on your hard drive for an extended period of time. You can remove cookies by following directions provided in your Internet browser's "help" file. Please note that removing or otherwise disabling cookies may reduce your ability to enjoy the full functionality of the Website. For more information about cookies please visit http://www.allaboutcookies.org/cookies/.

Third Party Advertisers

We use third-party advertising companies to serve ads when you visit our Website. These companies may collect information about your visits to our Website, such as number of times you have viewed an ad (but not your name, address, or other personal information). These companies may also use that information to serve ads about goods and services that may be of interest to you on this Website, and other websites. If you would like more information about this practice and to know your choices about not having this information used by these companies, click here.

Ways Information collected via the Website is used

4INFO uses information for the following general purposes:

• To help us deliver and customize the SMS messages that we send, we may use the information that you provide to us, and may merge that information with additional information we obtain from our partners. For example, we may use your cell number to run a lookup through your wireless carrier to determine the type of phone you have in order to provide you with more relevant advertising.
• We may use any of the information under our control in order to improve, or to better understand how our products or services are used.
• We may use your PII to contact you in order to answer a question or address a concern that you've raised, or to provide customer service on your account.
• We may use your PII to conduct research by sending you a survey. We don't combine the survey results with other information under our control.
• We reserve the right to send you certain communications relating to your 4INFO account, such as service announcements and administrative messages.
• We welcome your comments and suggestions regarding the web site. However, any comments, feedback, notes, messages, ideas, suggestions or other communications (collectively, "Comments") sent by you to 4INFO shall be and remain the exclusive property of 4INFO. We won't release your name in a way that contradicts this Privacy Policy, but we may share your Comments without identifying who you are.

Information we Collect via our Technology and Network

This section of the policy is designed to help you understand how our technology platform ("Platform") and our Network ("Network") processes info for 4INFO and as applicable, the advertisers, WAP and website owners and other businesses that use our services (our "Clients").

Overview of our Technology Platform

Our Platform is designed to help our Clients deliver advertising and content to your mobile device and your computer. For example, our Platform is used to perform the following:

• Send SMS messages and alerts to your mobile device,
• Place ads into those SMS messages and alerts,
• Place ads into mobile games, applications and WAP sites,
• Place ads onto websites that you visit while on the Internet,
• Understand which ads are placed, and which are clicked on by you and others.

Overview of our Network

Our Network facilitates the serving of advertisements on to interactive media, including mobile websites, WAP sites, mobile apps, mobile games and SMS messages ("Interactive Media"). Our Network uses technically available means including the placement of "cookies" to gather information about your use of Interactive Media (e.g., the mobile websites that you visit and the advertisements that you see while surfing the mobile Internet.) You may encounter our Network when 4INFO or one of our Clients purchases advertisements on Interactive Media. We use the information collected by our Network in order to help facilitate the advertisements that you see, to make the ads you see more relevant to you, and to help our Clients understand whether the advertisements they've purchased are effective.

Please note that not every client uses our Platform and/or Network the same way. For example, one Client may only use the Platform to deploy SMS messages, while another Client may deploy SMS messages on their own, but will use our Network to serve ads and report on how many clicks each ad receives.

Information collected by our Technology Platform and Network

The information we gather about you can vary according to the method through which the information is gathered. When you opt-in to receive an SMS message from one of our clients, we gather information associated with your mobile device. The information we gather, regardless of the channel through which it is gathered, may include your name, address, email, phone number, demographic data, connection data associated with your mobile device or computer, your zip+4 postal code, the wireless carrier to which you subscribe, and/or actions you have taken on advertising served by our Platform.

Our Platform does collect and use Non-PII, including: the IP address used to access the mobile Internet, the type of phone or other mobile device used, the date and time one of the mobile ads we facilitate was delivered and, if applicable, clicked.

Ways Information collected via our Technology and Network is used.

4INFO uses this information to analyze trends and to help our Platform and Network tailor advertisement placement on behalf of our Clients. We and/or our Clients may combine this data with data from our third-party partners. We also may aggregate this information and share it with our affiliates, employees and Clients.

Policies for the Website, the Technology Platform and the Network

Information Sharing and Disclosure

4INFO does not rent, sell, or share PII about you with other people or nonaffiliated companies, except when we have your permission, or under the following circumstances:

Agents

We employ other companies and people to perform tasks on our behalf and need to share your information with them to enable them to perform those tasks. Examples include sending email, sending text messages, analyzing data, and providing user services. Each of our agents are contractually required to handle information in a way that is consistent with this privacy policy.

Adherence to Law

We may release information when we believe in good faith that release is necessary to comply with applicable law; enforce or apply our Terms of Use and other agreements; or protect the rights, property, or safety of 4INFO, our employees, our users, or others. This includes, without limitation, exchanging information with other companies and organizations for fraud protection.

Business Transfers

If 4INFO, or substantially all of its assets were acquired, or in the unlikely event that 4INFO goes out of business or enters bankruptcy, the information we have would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of 4INFO may continue to use your information as set forth in this policy.

Client Lists

We facilitate the delivery of text messages on behalf of some of our Clients. Any of our Clients may choose to use a different service provider to facilitate that delivery. In such cases, if you are on our Client's list, we may transfer your information back to our Client so they may deliver messages to you via another technology provider.

Your Access to Your Information

4INFO generally allows you to access all or part of your information for the purpose of viewing, and in certain situations, updating that information. You may view and edit the information you've provided us when you registered with us, including your name, your phone number, your email address, and the text alerts to which you have subscribed. In order to access your information, we generally require you to authenticate who you are.

When you update information, however, we may maintain a copy of the unrevised information in our archives.

Also, please note that if our Clients are delivering SMS messages via the Platform, they may maintain control of all or portions of your information and 4INFO may not be able to provide you with the same access to your information for viewing and/or editing purposes.

Interest-Based Advertising and Opt Out

4INFO works with its Clients to provide ads that are likely to be more interesting and more relevant to mobile device users. We refer to this as interest-based advertising. For example, we use information collected via our Technology Platform, along with other non-personally identifiable information related to your mobile device to determine what advertising you receive. You may opt-out of 4INFO’s use of this data for interest-based advertising by following the instructions below. Please keep in mind that even after you opt-out, you will continue to receive ads, but 4INFO will no longer tailor those ads based on your interests.

To opt-out of 4INFO interest-based advertising, please use your mobile device to go to our mobile opt-out page. You can do so by typing in the following URL into your mobile browser: http://oo.adhaven.com. Please note that if you change your mobile device, you may need to renew your opt-out choice, and if you use more than one device, you must opt-out of each device by visiting this site from the browser on that device. 4INFO uses cookies as a method to support your interest-based advertising preference. Your device must support and maintain the 4INFO opt-out cookies to enable this feature. You can opt-in again at any time by typing http://oi.adhaven.com into the mobile browser for each device.

Security

The security of your information is important to us, including but not limited to the PII collected via the Website. We have implemented reasonable security measures to protect the information in our care, both during transmission and once we receive it. This includes, but is not limited to, the use of firewalls and encryption. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.

The PII you provide when you register with 4INFO is protected by a password for your privacy and security. You need ensure unauthorized access to your account and PII by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have finished accessing your account.

For additional information about the security measures 4INFO uses in connection with the Website, please contact us at support@4info.com.

Information Relating to Children

Our Website, products and services are designed for those 13 years of age and older. We do not knowingly collect PII from anyone under the age of 13 and we do not knowingly create Non-PII segments of those under 13. If we are made aware that we have received PII from someone under 13, we will use reasonable efforts to remove that information from our records.

Deleting your Information and Opt-out

You may stop participating and receiving SMS messages from any single 4INFO program by sending STOP to any of our short codes, in response to any message from that program. You may stop participating and receiving SMS messages from all 4INFO programs and services by sending the text message STOP ALL to 44636. This action cancels your previous opt-in for messaging. You will receive a message confirming the opt-out.

Some of the SMS programs that we deploy on behalf of our clients are run via other short codes. For a list of the Common Short Codes, please click here. The short codes that 4INFO deploys on behalf of our clients are labeled as "Powered by 4INFO" at the point of registration. Please note that some of our Clients deploy short codes on the Platform that are not labeled as "4INFO."

If you are having trouble unsubscribing from any program on our short codes (44636, 446361, 446362, 446363, 446364, 446365, 80676, 96362, 28007) or on any short code that is "Powered by 4INFO" please email us at support@4info.com. Please note that we cannot help you unsubscribe from any short codes other than 44636 and those marked as "Powered by 4INFO."

You may request deletion of your 4INFO account by sending an e-mail to support@4info.com. Please note that some information may remain in our records after deletion of your account.

Third Party Websites

The 4INFO Website, advertising placed by 4INFO and 4INFO text messages may contain links to other sites. 4INFO is not responsible for the privacy policies and/or practices on other sites. When linking to another site a user should read the privacy policy stated on that site.

Industry Efforts to Protect Consumer Privacy

4INFO is committed to protecting consumer mobile privacy. 4INFO abides by the Mobile Marketing Association Code of Conduct for Mobile Marketing and other generally accepted industry standards.

Unsolicited Message Policy

The 4INFO technology platform is sometimes used to help our clients deliver advertising and content to your mobile device and your computer. Clients of 4INFO have agreed to never send unsolicited SMS messages through 4INFO. Any client who violates this agreement is subject to privacy review, services termination and potential legal action. If you believe you have received an unsolicited commercial text message from 4INFO directly, or on behalf of any of our clients, please send an email (preferably with the reported violation included and the applicable short code) to: support@4info.com.

Changes to this Privacy Policy

4INFO may update this policy. We will notify you about significant changes in the way we treat PII by sending a notice to the primary email address specified in your 4INFO account or by placing a prominent notice on our web site. Each user is bound by any changes to the Privacy Policy when he or she uses the Website after such changes have been first posted.

Contact 4INFO with Questions or Concerns

If you have any questions or concerns regarding privacy at 4INFO, please send us a detailed message to support@4info.com. Alternatively, you may contact us via postal mail at:

Privacy Officer
4INFO, Inc.
177 Bovet Road, 4th Floor
San Mateo, CA 94402