Effective Date: September 10, 2008

Generally Smarter.com ("Site" or "we", "our" or "us") does not collect, store, use or disclose any data collected with an intention to identify and/or contact a person such as: name, address, telephone number or e-mail address (hereinafter "PII") except in very specific instances, for example, when you provide PII through registering on the Site or as set forth in this Privacy Policy. Whenever we collect such PII, it will be governed by this Privacy Policy. 

Smarter.com provides a comparison shopping service that enables consumers to compare prices, products and stores when they shop online. This service is provided by Smarter.com which is owned by MeziMedia, Inc. ("MeziMedia"). For Smarter.com, privacy is a top priority and we provide this Privacy Policy to outline our practices and procedures with respect to information collection and use to enable you to make an informed decision about sharing information with us. 

## What does this Privacy Policy cover?

This Privacy Policy applies to collection, use, storage and disclosure of information by us.

Please be aware that, as part of the service provided by this Site, we may provide links to websites operated by third parties. We are not responsible for the information collection or privacy practices or the content of those third party Web sites or applications. You should check the applicable privacy policies of such third-party Web sites or applications to determine how they handle any information they collect from you.

## What information does Smarter.com collect and how is it used? Does Smarter.com disclose information to third parties?

We may collect any or all of the following three types of information: (i) traffic or clickstream data, (ii) non-personally identifiable information (for example: IP address, browser types, operating systems, domain names, access dates and times, referring website addresses, online transactions and browsing and search activity) ("Non-PII"), and/or (iii) PII in the instances as set forth in this Privacy Policy. Our collection and use of each type of data is described below, as well as the ways (if any) in which the data may be shared with third parties or subsidiaries or affiliates of MeziMedia ("MeziMedia Entities"). 

(a) Traffic or Clickstream Data ("Clickstream Data"). Clickstream Data consists of traffic and usage data that is not personally identifiable. We do not supplement or combine Clickstream Data with any PII. We may share Clickstream Data we collect with certain selected third parties and MeziMedia Entities, but only in anonymous form. Notwithstanding the foregoing, such third parties and MeziMedia Entities may combine such Clickstream Data with any PII that you choose to give to such third parties or MeziMedia Entities when registering with their websites. We collect Clickstream Data regarding use of our services by observing browser functions and the files (pages) you access. For example, our servers collect information about the site to which you may redirect to in order to enable us to calculate and receive payments from our business partners. In addition, we may use Clickstream Data to better design our services.

(b) Non-Personally Identifiable Information. As part of our on-going efforts to ensure the best possible experience for all users of the Site, we may use log files, web beacons and cookies to collect Non-PII from the Site, browsers, advertisers and third-party sites. "Log files" track actions occurring on the Site and collect data including: your IP address, browser type, Internet service provider, referring/exit pages, platform type, date/time stamp, click data and types of advertisements viewed. "Web beacons" are electronic files used to track your navigation of a website or collection of sites, the completion of transactions, submittal of applications and browsing behavior. "Cookies" are files (e.g. flash browser objects) that are stored on your Internet enabled device (which includes your computer, BlackBerry or other PDA). Cookies are used to improve the experience web users have when they see web advertisements and ensure that when a web user clicks on an advertisement, they are sent to the correct click-through destination. We may use Cookies for purposes which may include, without limitation, to estimate the total reach of any of our advertisers, how frequently you return to the Site, as well as to streamline experiences of users of our Site. Cookies are also an anonymous way to survey how we are doing and to look for ways to improve our services. All information collected by Cookies, Web beacons and Log files are Non-PII.

There are two classes of Cookies based on how long they remain on your system: (i) "Session Cookies" may be used only during your visit to the Site and are erased once you close your browser, and (ii) "Persistent Cookies" (if applicable) remain on your browser for one (1) year from your last visit to the Site and enable us to remember you on subsequent visits to the Site and provide more relevant content to you on such Site.

There are many misconceptions about Cookies, some of which we will try to address in this policy. Cookies cannot erase your hard drive or otherwise damage your computer and do not tell us an e-mail address or any other PII. We do not and cannot use Cookies or web beacons to retrieve PII from your computer. 

A useful resource on understanding Cookies may be found at http://www.allaboutcookies.org.

(c) Third Party Advertising. We have relationships with third-party advertising companies to drive traffic to and to serve ads on our Site. We share Clickstream Data and Non-PII with such advertising companies. Such companies may also collect non-personally identifiable information through the use of Cookies and other technology and any personally identifiable information you may choose to give in registering and transacting with any website linked to such ads. Although we choose our business partners and clients carefully, we are not responsible for the privacy practices of such third parties. You should check the applicable privacy policies of these third-party advertisers to determine how they handle any information they collect from you.

(d) Contact Information or Personally Identifying Information. We have access to your PII after such PII has been submitted to us by: (i) becoming a registered user of our Site, (ii) subscribing to any of our newsletters, (iii) contacting us by submitting a comment, problem, or request for information, (iv) submitting PII in connection with special offers or contests, and/or by (v) signing up as one of our advertisers, merchants or business partners. 

PII provided in connection with problems, comments or requests is used only to respond to those problems, comments or requests. This information is not stored or used in connection with Clickstream Data and is provided to a third party only as necessary to respond to the comment, problem or request of as required by law or court order. 

Finally, from time to time, but only with your permission, we may provide your PII to selected third parties who wish to participate in special promotions offered in conjunction with us.

## Do I have choices?

Yes. You may opt-out of having your PII shared with third parties at any time by sending request that includes your full name, email address, and postal address with a request for opt-out with regard to your PII to: Smarter.com, Attn: Privacy Officer, 103 E. Lemon Ave., Suite 200, Monrovia, CA 91016 or you can email us including your full name, email address with a request for opt-out with regard to your PII to privacy@MeziMedia.com.

We also offer "opt-out Cookies" to block the placement of future MeziMedia Persistent Cookies on your system for one thousand (1,000) days from the time you opted out. If you have multiple internet browsers or users on the same computer, you will need to perform the opt-out operation for each browser and/or user. If you or your privacy software deletes the opt-out Cookies from your computer, you will need to repeat the process. Alternatively, most internet browsers and browser add-ons allow you to adjust their settings to allow you to automatically refuse Cookies either generally or from specific sites. To adjust these settings, we suggest that you contact the supplier of you browser and browser add-ons for more information.

Please note that the above link for opt-out Cookies is only applicable to MeziMedia owned websites using Persistent Cookies and not any other company website. Also, please note that use of the opt-out Cookies or implementation of browser settings and add-ons that refuse all cookies will affect our ability to provide you content and advertisements that will more effectively match your interests and may prevent us from controlling the frequency with which you may view any particular advertisement. "Session Cookies" are used only during your visit to the Site and are erased once you close your browser.

## Is data stored by Smarter.com secure?

We employ reasonable measures to ensure the security of all information and we routinely evaluate our practices to identify security threats or opportunities for the improvement of our services. No transmission of information is guaranteed to be completely secure. Unauthorized entry or use, hardware or software failure, and other factors may compromise data security. You acknowledge and agree to assume this risk when communicating with us. 

## Does Smarter.com collect personally identifying information from or about children?

We use reasonable efforts not to collect, use or disclose PII from children under the age of 13. The services are not targeted at children, and children age 13 and under may not register for any portions of the services that require registration. If you believe your child has provided us with any PII data by registering on our Site, please specify this issue and email us at privacy@MeziMedia.com.

## How can I access or correct any personally identifying information about me?

To request a copy of any PII you have sent to us, please send an email containing your request to privacy@MeziMedia.com.. You must provide your full name and the e-mail from which the request is received (and to which the response will be sent) must match the e-mail on file with us. You may then correct or delete such information using the procedures specified in the e-mail. 

## How can I learn about changes to this privacy policy?

We may find it necessary or be legally obligated to update this Privacy Policy from time to time. When we do, we will post the revised Privacy Policy and the date the Privacy Policy was last updated on this page so that you are always aware of the information we collect, how we use it, and under what circumstances we disclose it. We encourage you to review the Privacy Policy whenever you use this Site to make sure you understand how your information will be used. It is the express will of the parties that this agreement and all related documents have been drawn up in English.C'est la volont¨¦ expresse des parties que la pr¨¦sente convention ainsi que les documents qui s'y rattachent soient r¨¦dig¨¦s en anglais.

## How do I find out more about Smarter.com information practices?

If you have any questions about anything in this Privacy Policy or about collection of personally identifiable information, or information generally, please contact us as follows:

Business and Legal Affairs  
Smarter.com/MeziMedia  
103 E. Lemon Ave., Suite 200  
Monrovia, CA 91016

E-Mail: privacy@MeziMedia.com.
