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	Skyfire Privacy Policy Effective February 6, 2008 Skyfire Labs, Inc. (“Skyfire”) has developed a mobile web browser (the “Browser”) that enables you to surf the internet, interact with websites and send and receive content (collectively “Browser Usage”) on your mobile phone, PDA and other handheld electronic devices. When you use the Browser, Skyfire has access to, and in many cases will monitor, your Browser Usage. Skyfire recognizes that you trust us to act in a responsible manner with any Browser Usage information we learn about you when you use the Browser and we are committed to respecting your privacy by explaining, in this Privacy Policy, how we collect, use and disclose Browser Usage information we receive when you use the Browser, when you visit and use the www.skyfire.com website (the “Site”), and when you access, download or use any information, software, features or other content appearing on the Site or offered by Skyfire (the “Services”). This Privacy Policy may be updated from time to time. We will notify you of any material changes by posting the new Privacy Policy on the Site or through a message sent to your registered mobile phone number. Unless we provide you with separate notice and an opportunity to opt out, information will be treated in accordance with the policy that was in place when the information was collected. You are advised to consult this Privacy Policy regularly for any changes. As used in this Privacy Policy, the terms “using” and “processing” information include using cookies on a computer or a mobile device, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates within the United States or internationally. Information Collection & Use Our primary goals in collecting information are to provide and improve our Site, Services and Browser, to administer your subscription and to enable users to enjoy and easily navigate and use the Site, Services and Browser. Personally Identifiable Information When you subscribe to the Browser through the Site or via a mobile device, or if you choose to register and create your own profile webpage on our Site, we will ask you for certain information that can be used to contact or identify you and administer your account (“Personal Information”). Personal Information includes, but is not limited to, your name, any screen or user names, account passwords, phone number, credit card, payment account or other billing information, email address, home and business postal addresses, the model and phone number of your mobile device that will be used to subscribe to and access the Browser (your “Device”) and your privacy preferences. If you sign up to receive promotional offers or alerts via text messaging, any mobile number you provide us to receive such offers or alerts will be collected by Skyfire as Personal Information. Skyfire may also request that you provide Personal Information when you order additional services (for example, premium functionality), when you request promotional information, when you complete customer surveys, when you participate in contests, when you call our customer support line and if you contact or interact with us. Finally, when you apply for a job and provide us with Personal Information, we will collect such information. Skyfire uses your Personal Information (in some cases, in conjunction with your Site Usage Information and/or in conjunction with your Browser Usage Information) mainly to provide the Browser and any services you request, complete your transactions, resolve disputes and communicate with you. For example, Skyfire may use your Personal Information in order to enable us to process and validate your Browser subscription, to bill for any Services, to contact you regarding the Browser, to contact you about new or existing products and services or special offers that may be of interest to you, to process and charge any fees due, to verify your identity or customer qualifications as may be required, to detect and protect us against error, fraud or criminal activity, to enforce our terms of use, to respond to any communications you send us or to provide you with any relevant or requested information. If you decide at any time that you no longer wish to receive certain communications from us, please follow the instructions provided in any of the communications or update your “user preferences” information (see “Changing or Deleting Information” below). When you register through the Site and submit your Personal Information to create a profile webpage, other Skyfire users may be able to see your “Screen Name”. You can choose what other Personal Information you provide as part of your profile and in some cases you can choose whether to share that information publicly on the Site by making selections via the “user preferences” section of your profile webpage. Providing such information is voluntary and should correlate with the degree of interaction you want to have with other users. We recommend that you guard your anonymity and sensitive information and that you not use your real name as your “Screen Name,” since that would allow others to identify you. Site Usage Information Our Site is designed so that visitors may browse it without the collection of any personally identifiable information (except for such visitor’s internet protocol (IP) address). When you visit the Site, we may collect information indirectly and automatically (through the use of cookies, as described below) about your Site activity, including the geographic location of the IP address you are using to access the internet, the type of browser used, platform type, referring/exit pages and date/time information (“Site Usage Information”). Skyfire uses Site Usage Information for internal purposes such as to administer, improve and customize the Site, to help Skyfire understand and analyze how the Site is being used, to track aggregate Site usage, to provide technical administration, to increase the Site’s functionality and user-friendliness and to better tailor the Site to our visitors’ needs. For example, some information is collected so that when you visit the Site again, it will recognize you and serve advertisements and other information appropriate to your interests. Browser Usage Information Once you have subscribed to and begin to use the Browser, we will collect information about your use of the Browser on your Device (“Browser Usage Information”). Browser Usage Information includes such information as which websites and programs you access or download on your Device, how long you visit such websites and use such programs, your activities (such as products purchased or advertisements viewed) on such websites, which specific areas of a website or webpage you use and for how long, websites you bookmark, search terms you use, referring/exit pages, browser and platform types, the geographic location in which your Device is being used and information you provide on third party websites. All of your Browser Usage Information is stored together by Skyfire under an automatically generated, random identification number (“ID Number”) that will not be associated with or linked to your other Personal Information. By downloading our Browser and accepting our Terms of Use (which includes acceptance of this Privacy Policy), you have given us your express consent to collect and use Browser Usage Information and tie it to an ID Number. Skyfire uses Browser Usage Information to improve the Site, Browser and Services and offer you a personalized Browser experience. Browser Usage Information permits us to recommend products and services that we believe will be of interest to you, personalize your viewing and Browser usage, select targeted advertisements or other promotions for you and offer you local content and advertising information. Anonymous Usage Information From time to time, Skyfire may offer you the opportunity to use the Browser in “Anonymous Mode”. By choosing this feature, Skyfire will collect Browser Usage Information, but such collection will be on an anonymous basis only, meaning that it will not be tied to an ID Number or your Personal Information for the period of time that the Anonymous Mode option is made available to you and has been selected by you (“Anonymous Usage Information”). By downloading our Browser and accepting our Terms of Use, you have given us your express consent to collect Anonymous Usage Information and use it as described below. You cannot block the collection of Anonymous Usage Information and still use the Browser. Skyfire uses Anonymous Usage Information to understand what our customers want, for editorial, feedback, marketing and promotion purposes, for statistical analysis, product development and content improvement and to create aggregate reports of how users are using the Browser. Certain Anonymous Usage Information would be considered a part of your Personal Information if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be identified. But the same pieces of information are considered Anonymous Usage Information when they are taken alone or combined only with other non-identifying information (for example, your viewing activities). We may combine your Personal Information with Anonymous Usage Information and aggregate it with information collected from other Browser users to provide you with a better experience, to improve the quality and value of the Browser and to analyze and understand how our Site and Browser are used. We may also use the combined information without aggregating it to serve you specifically, for instance to deliver a product to you according to your preferences or restrictions. Cookies We use “cookies” on our Site and via our Browser to collect information. A cookie is a small data file that we transfer to your computer’s or Device’s hard disk for record-keeping purposes. We use cookies to save your registration ID and login password for future logins to the Site or use of the Browser. We also use cookies to enable certain features of the Site or Browser, to better understand how you interact with the Site and Browser, to track user trends and to monitor aggregate usage and web traffic routing on the Site and Browser. Third party advertisers on the Site and through the Browser may also place or read cookies on your computer’s or Device’s browser. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of the Site or all (or any) functionality of the Browser. Phishing Identity theft and the practice currently known as “phishing” are of great concern to Skyfire. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your account ID, login password or national identification numbers in a non-secure or unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website. Information Sharing and Disclosure We do not share Personal Information, Site Usage Information, Browser Usage Information and/or Anonymous Usage Information with third parties except as follows: Service Providers. We may employ third party companies and individuals to facilitate our Site, Services and Browser, to provide the Browser on our behalf, to perform Site-related services (e.g., without limitation, bill or credit card payment processing, maintenance services, database management, web analytics and improvement of the Site’s features) or to assist us in analyzing how our Site, Services and Browser are used. These third parties have access to your Personal Information, Site Usage Information, Browser Usage Information and/or Anonymous Usage Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. Aggregate Information and Non-Identifying Information. We may share aggregated Site Usage Information, aggregated Browser Usage Information and/or aggregated Anonymous Usage Information that does not include Personal Information and we may otherwise disclose aggregated Browser Usage Information and/or aggregated Anonymous Usage Information with third parties (including suppliers, advertisers, research companies and other organizations) for industry analysis, demographic profiling and other purposes. Any information shared in these contexts will not contain your Personal Information. Compliance with Laws and Law Enforcement. Skyfire cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Skyfire or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity. Business Transfers. Skyfire may sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy. Skyfire will notify you before transferring your information to a new entity as part of a merger, acquisition, reorganization or sale of some or all of its assets if the new entity's processing of your information will materially differ from that set forth in this Privacy Policy. Changing or Deleting Your Information All Browser and Site subscribers may review, update, correct or delete the Personal Information in their registration profile by contacting us. If you completely delete all such information, then your account may become deactivated. If you would like us to delete your record in our system, please contact us and we will attempt to accommodate your request if we do not have any legal obligation to retain the record. See below for privacy contact information. From time to time, we may contact you be mail, email, telephone or SMS to tell you about additional products or services that we or third parties may offer. If you do not wish to receive such calls or promotional materials, please contact us and we will attempt to accommodate your request. Security Skyfire is concerned with safeguarding your information. We employ a variety of industry-standard administrative, physical and electronic security measures designed to protect your information from unauthorized access. No data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk. Once we receive your transmission, we make reasonable efforts to ensure security on our systems. We use secure server software (SSL) and firewalls to protect your information from unauthorized access, disclosure, alteration, or destruction. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. If Skyfire learns of a security systems breach we may attempt to notify you electronically so that you can take appropriate protective steps. By using this web site or providing personal information to us you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of this site. Skyfire may post a notice on our web site if a security breach occurs. If this happens, you will need a web browser enabling you to view the Skyfire web site. Skyfire may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice) you should notify us at info@skyfire.com. International Transfers Your information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide information to us, Skyfire transfers Personal Information to the United States and processes it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. Browsing the Internet via the Browser When you use the Browser to engage in activities with a third party, Skyfire has access to the information you send and receive to such third parties. When you elect to engage in a transaction with a third party advertiser or content provider using the Browser, Skyfire will pass and transmit any transaction information you provide via the Skyfire server to such third party advertiser or content provider. If you choose to visit a website or an advertiser by entering a website address, clicking on a link or advertisement, you will be directed to that third party’s website. The fact that the Browser permits you to interact with or link to websites or advertisement is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. Skyfire does not exercise control over third party websites. These other websites may place their own cookies or other files on your computer and Device, collect data or solicit personal information from you. Other sites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit. Links to Other Sites Our Site contains links to other websites. If you choose to visit an advertiser by “clicking on” a banner ad or other type of advertisement, or click on another third party link, you will be directed to that third party’s website. The fact that the Site permits you to link to a website or present a banner ad or other type of advertisement is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer and Device, collect data or solicit personal information from you. Other sites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit. Our Policy Towards Children The Site and use of the Browser are not directed to children under 18. We do not knowingly collect personally identifiable information from children under 13. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at info@skyfire.com. If we become aware that a child under 13 has provided us with Personal Information, we will delete such information from our files. Contacting Us If you have any questions about this Privacy Policy, please contact us at privacy@skyfire.com or at: Skyfire Labs, Inc., 444 Castro Street, Suite 130, Mountain View, CA 94041, Attn: Privacy Officer.