Effective Date: January 1, 2007

V-Vestor Privacy Policy

Thank you for visiting the Vvestor™ website located at www.Vvestor.com (the "Site"). The Site is an Internet property of Browsetopia, LLC ("Vvestor™," "we," "us"). Vvestor™ has created this privacy policy (the "Privacy Policy") in order to disclose our information gathering and dissemination practices. We understand the importance that Internet users place on privacy and have designed our Site with this in mind. While the Site remains available to end-user visitors without any registration requirements ("Non-Registered Users"), in order to utilize some of the Site's enhanced features, interested parties must either: (1) register as a member ("Member") on the Site, in order to access the various Member-based services detailed below ("Member Services"); (2) register as a preferred Member ("Preferred Member") of the Site, in order to utilize a host of services made available to Preferred Members through the Site ("Preferred Services"); and/or (3) register in order to enter one of our sweepstakes, promotional offers or contests (collectively, "Promotions") including, but not limited to, the Guess the Index Promotion and Best Investor Promotion (collectively, the "Vvestor™ Services", with the applicable registrants referred to herein as "Registered Users"). In order to become a Registered User, applicants must supply certain personally identifiable information. We are an optional service. We collect credit card, address, bank and/or other personal information only from those individuals/entities that choose to participate. Because we offer a variety of services to distinct users, our Privacy Policy contains two (2) separate sets of terms and conditions: one for our Non-Registered Users and one for our Registered Users.

If you are a resident of the State of California and would like to opt-out from the disclosure of your personal information to any third-party for marketing purposes, please Click Here. Please be advised that where California State residents opt-out from permitting their personal information to be shared, such individuals may still receive selected offers directly from us, in accordance with the law.

I. Non-Registered Users

Information Collected/Tracked by Vvestor™

As a general rule, Vvestor™ does not request or collect any personally identifiable information directly from Non-Registered Users.

We gather Non-Registered Users' server, IP address and browser-type related information as part of the general administration of the Site ("Site Data"). This Site Data is comprised of the demographic, usage and/or other characteristics of Site visitors as a group, without any associated personally identifiable information.

When a Non-Registered User visits the Site, we send a cookie and/or gif file ("Cookie") to assign an anonymous, unique identifier to the applicable Non-Registered User's Internet browser. A Cookie is a piece of data stored on your hard drive containing non-personally identifiable information about you. Cookies have many benefits to enhance your experience at the Site. To find out more about Cookies, please visit www.cookiecentral.com. To disable and reject certain Cookies, click on the link for your browser: Internet Explorer, Mozilla Firefox, Opera. Even in the case where a user rejects a Cookie, he or she may still use the Site. Vvestor™ reserves the right to retain Cookie data indefinitely.

Use of Information Obtained by Vvestor™

As a general rule, Vvestor™ does not collect or share any personally identifiable information that it obtains from Non-Registered Users. Vvestor™ reserves the right to release current or past Site Data: (a) in the event that we believe that the Site is being or has been used in violation of this Privacy Policy, the Vvestor™ Website Terms and Conditions ("Terms and Conditions"), the Guess the Index Promotion rules ("Guess the Index Rules"), Best Investor Promotion rules ("Best Investor Rules") or to commit unlawful acts; (b) if the information is subpoenaed; or (c) if Vvestor™ is sold or acquired. While Vvestor™ strongly encourages clients, affiliates and partners to adopt responsible approaches to online marketing, Vvestor™ is not responsible for the information practices of its clients, affiliates and/or partners. The collection, use and disclosure of information by clients, affiliates and/or partners is subject to their respective privacy policies, which may differ from the Privacy Policy. Vvestor™ reserves the right to use all Site Data associated with Non-Registered Users to investigate fraudulent or other claims made against Vvestor™.

Changes in our Privacy Policy

If we change our Privacy Policy, we will prominently post a link to those changes on our Site's Homepage so that our Non-Registered Users are always aware of what information we collect, how we use it and under what circumstances, if any, we disclose it. The Non-Registered User's continued use of the Site after posting of the Privacy Policy change on the Site constitutes an affirmative acknowledgement and acceptance by the Non-Registered User of the modified Privacy Policy.

Security

Vvestor™ takes every precaution to protect our Non-Registered Users' information. Vvestor™ regularly reviews, at least once per year, its Non-Registered User information security practices to identify security threats or opportunities for improvement. When Non-Registered Users submit sensitive information via the Site, we endeavor to keep the information protected both online and off-line. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot ensure or warrant the security of any information that you transmit to us, and you do so at your own risk.

All Site Data and other information is restricted in our offices. Only employees who need the Site Data and other information to perform a specific job function are granted access to it. All such employees are contractually bound to adhere to our security protocols, which they must verify that they have read and understand. The practices for handling sensitive information are disseminated to all of our employees. In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your personal information. You will be notified via e-mail in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage and to engage in remedial measures.

If you have any questions about the security related to the Site, please Contact Us.

II. Registered Users

Information Collected/Tracked by Vvestor™

Vvestor™ gathers two types of information: information that Registered Users submit to us, and information that is not directly submitted by Registered Users.

Information Submitted to Vvestor™

To accomplish our goal of bringing Vvestor™ Services to our Members and Preferred Members, and to administer the Promotions, we must gather personal information from all Registered Users through the applicable Vvestor™ sign-up and registration process, which may require, but may not be limited to, submission of some or all of following information: e-mail address, first name, last name, date of birth, credit card number, a user-specified password, mailing address, zip code, mobile telephone number and home telephone number.

Information not Directly Submitted by Registered Users to Vvestor™

We gather Registered Users' server, IP address, browser-type, clicks, impressions and other traffic and/or consumer action related information in connection with the general administration of the Site ("Site Data"). Vvestor™ reserves the right to transfer and/or sell Site Data about Registered Users for lawful purposes. The Site Data is comprised of the demographic, usage and/or other characteristics of Registered Users as a group. By submitting your personal information to, and/or using, the Site, you agree to allow Vvestor™ to transfer and/or sell such aggregate data to third-parties.

When a Registered User visits the Site, we send a cookie and/or gif file ("Cookie") to assign an anonymous, unique identifier to the applicable Registered User's Internet browser. A Cookie is a piece of data stored on your hard drive containing non-personally identifiable information about you. Cookies have many benefits to enhance your experience at the Site. To find out more about Cookies, please visit www.cookiecentral.com. To disable and reject certain Cookies, click on the link for your browser: Internet Explorer, Mozilla Firefox, Opera. Even in the case where a user rejects a Cookie, he or she may still use the Site. Vvestor™ reserves the right to retain Cookie data indefinitely.

Use of Information Obtained by Vvestor™

Sharing of the Information Gathered/Tracked by the Site

The personal information that you submit to Vvestor™ remains your property, but by submitting that personal information to Vvestor™ you grant Vvestor™ the right, subject to applicable state and federal law, to use that personal information for marketing purposes. Without limiting the generality of the foregoing, we reserve the right to share, sell, rent, lease and/or otherwise distribute any and all personal information with/to any third-party for any and all uses permitted by this Privacy Policy and applicable law. These third-parties may include, but shall not be limited to, providers of direct marketing services and applications, including lookup and reference, appending, data enhancement, suppression and validation, and e-mail marketing. We may also use your personal information for any Promotion-related purpose, and/or marketing and survey purpose, on our own behalf and on behalf of our affiliates and subsidiaries. We may disclose personal information to third-party agents and independent contractors that help us operate the Promotion(s). You agree that we may contact you at any time with updates and/or any other information that we may deem appropriate for you to receive in connection with your continued use of the Site.

Vvestor™ is able to offer its Vvestor™ Services to you, in part, based on your willingness to be reached by our third-party advertisers. Your personal information will be shared with advertisers on an aggregate and non-aggregate basis. We also use contact information from your personal information to send you information about Vvestor™ and to keep you informed of our other products and services that may be of interest to you. Please keep in mind, though, that Vvestor™ does not control, and is not responsible for, the practices of our third-party advertisers. Your contact information is also used to reach you, when necessary, regarding issues concerning your use of the Site and Vvestor™ Services. If you wish to stop receiving future communications from us and/or third-party advertisers, or if you wish to prevent the transfer and/or sale of your personal information to third-parties (subject to restrictions contained in applicable state and federal law), please see the Opt-Out/Unsubscribe section below.

By submitting your e-mail address at the Site and/or registering for the Vvestor™ Services, you agree to receive e-mail marketing from Vvestor™ (including other Vvestor™ properties) and our third-party advertisers. In addition, you agree that such act constitutes a purchase, an inquiry and/or an application for purposes of the Amended Telemarketing Sales Rule, 16 CFR �310 et seq. (the "ATSR"). With respect to the ATSR, and notwithstanding that your telephone number may be listed on the Federal Trade Commission's Do-Not-Call List, Vvestor™ retains the right to contact you via telemarketing in accordance with the terms of the ATSR.

In addition, you agree that by submitting your personal information at the Site, you agree to receive mobile marketing including, but not limited to, text-message based marketing, from us and our third-party advertisers and marketers. Notwithstanding that your mobile telephone number may be listed on state and/or federal Do-Not-Call registries, we retain the right to contact you via text-message based marketing in accordance with applicable state and federal law. Further, you agree that we reserve the right to share, sell, rent, lease and/or otherwise distribute your mobile telephone number and other mobile data with/to any third-party for any and all non-marketing uses permitted by this Privacy Policy and applicable law.

Without limiting the generality of the foregoing, you agree that upon registering for the Best Investor Promotion, your performance will be tracked and made publicly available on the Site; provided, however, that your individual transactions and other Investment Activity (as that term is defined in the Terms and Conditions) will only be made available to Preferred Members as set forth below. Vvestor™ reserves the right to contact Preferred Members, via e-mail, with updates associated with the Investment Activity of participants in the Best Investor Promotion; provided, however, that Vvestor™ will not share any personally identifiable information of the participants in the Best Investor Promotion with such Preferred Members.

To the extent that Vvestor™ collects your credit card-specific information, if ever, we will use the information to process and complete any transaction that you request. By submitting your credit card information to us, you authorize Vvestor™ to periodically verify that your credit card account continues to be a valid and active one by charging, and thereafter immediately crediting, a small sum to the card. Such verification may be conducted through a third-party and, in that case, Vvestor™ would share your specific credit card information with this third-party for verification purposes. Notwithstanding the foregoing, Vvestor™ reserves the right to share with third-parties the fact that we have credit card information on file for specific users, but we will not share your specific credit card information with third-parties without your prior informed consent.

Vvestor™ reserves the right to release current or past user information and personal information: (A) in the event that we believe that the Site and/or the Vvestor™ Services is/are being or has/have been used in violation of this Privacy Policy, the Terms and Conditions, the Guess the Index Rules, Best Investor Rules or to commit unlawful acts; (B) if the information is subpoenaed; or (C) if Vvestor™ is sold or acquired. Moreover, you hereby consent to disclosure of any record or communication to any third-party when Vvestor™, in its sole discretion, determines the disclosure to be appropriate including, without limitation, sharing your e-mail address with other third-parties for suppression purposes in compliance with the CAN-SPAM Act of 2003, as amended from time to time.

Correcting/Updating or Removing Information

Vvestor™ provides Registered Users with several options for modifying or removing their information from our database. Please visit the Manage Account page for an explanation.

Changes in Our Privacy Policy

If we change our Privacy Policy, we will prominently post a link to those changes on our Site's homepage so that our Registered Users are always aware of what information we collect, how we use it and under what circumstances, if any, we disclose it. The Registered User's continued use of the applicable Vvestor™ Services, Site and/or continued receipt of Vvestor™ e-mails after posting of the Privacy Policy change on the Site constitutes an affirmative acknowledgement and acceptance by the Registered User of the modified Privacy Policy.

Security

Vvestor™ takes every precaution to protect our Registered Users' information. Vvestor™ regularly reviews, at least once per year, its Registered User information security practices to identify security threats or opportunities for improvement. When Registered Users submit sensitive information via the Site, we endeavor to keep this information protected both online and off-line. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot ensure or warrant the security of any information that you transmit to us, and you do so at your own risk.

When we ask Registered Users to enter sensitive information (such as a credit card number), and when such information is stored and/or transmitted, that information is encrypted and is protected with SSL encryption software. While we use SSL encryption to protect sensitive information online, we also do everything in our power to protect Registered User information off-line. All of our Registered Users' information, not just the sensitive information mentioned above, is restricted in our offices. Only employees who need the information to perform a specific job (for example a billing clerk or a customer service representative) are granted access to personally identifiable information. All such employees are contractually bound to adhere to our security protocols, which they must verify that they have read and understand. The practices for handling sensitive information are disseminated to all of our employees. In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your personal information. You will be notified via e-mail in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage and to engage in remedial measures.

If you have any questions about the security related to the Site, please Contact Us.

Opt-Out/Unsubscribe

To stop receiving future communications from Vvestor™, please Click Here. To opt-out of having your information shared with third-parties, please Click Here. Vvestor™ uses personal information to provide promotional offers by e-mail to individuals. Vvestor™ may maintain separate e-mail lists for different purposes. If e-mail recipients wish to end their e-mail subscription from a particular list, they need to follow the instructions at the end of each e-mail message to unsubscribe from the particular list. To unsubscribe from all Vvestor™ e-mail lists, please Click Here.

III. General Provisions

Links

The Site contains links to other websites. Please be aware that Vvestor™ is not responsible for the privacy practices of other websites. We encourage our Registered and Non-Registered Users to be aware when they leave the Site and to read the privacy policies of each and every website that collects personally identifiable information. This Privacy Policy applies solely to information collected by the Site.

Children's Privacy

Vvestor™ is very sensitive to the issue of children's privacy and, therefore, we endeavor to protect the privacy of children using the Internet. The Site, Vvestor™ Services and other products and services available herein are not developed for or directed at children. Visitors under eighteen (18) years of age are not eligible to do business with us and we do not knowingly solicit or collect personal information from any person that we actually know is under the age of eighteen (18). Vvestor™ encourages parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children. If you believe that your child has provided Vvestor™ with any personally identifiable information, please e-mail contactus@Vvestor.com to have this information removed.

Contacting the Site

Our "Contact Us" page contains information that allows you to contact us directly with any questions or comments that you may have. We listen to or read, as applicable, every message sent in and endeavor to reply promptly to each one. This information is used to respond directly to your questions or comments. If you have any questions about this Privacy Policy or the practices of Vvestor™, please feel free to contact us at contactus@Vvestor.com.

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