Allwink, Inc. (“Allwink”
or “we”) operates Allwink.com. This Privacy Policy describes Allwink’s use and
sharing of personally identifiable information (“PII”-- your full name, email
address, mailing address, telephone number, or credit card number) that

Members voluntarily provide to Allwink when they register (also known as
“Registration PII”). The Term “User” refers to a

Visitor or a Member. This Privacy Policy
applies to the services offered by Allwink, including any Allwink-branded URL
(the “Allwink Website”), the Allwink instant messaging service, the Allwink
application developer service and other features (for example, music and video
embedded players), Allwink mobile services, and any other features, content, or
applications offered from time to time by Allwink in connection with the Allwink
Website (collectively, the “Allwink Services”). The Allwink Services are hosted
in the United States.

The Allwink
Website is a general audience site and does not knowingly collect PII from
children under 13 years of age.

From time to time
Allwink may modify this Privacy Policy to reflect industry initiatives or
changes in the law, our PII collection and use practices, the features of the
Allwink Services, or technology, and such modifications shall be effective upon
posting by Allwink on the Allwink Website. Your continued use of the Allwink
Services after Allwink posts a revised Privacy Policy signifies your acceptance
of the revised Privacy Policy. It is therefore important that you review this
Privacy Policy regularly to ensure you are updated as to any changes. If Allwink
materially changes its practices regarding collection or use of your PII, your
PII will continue to be governed by the Policy under which it was collected
unless you have been provided notice of, and have not objected to, the change.

COLLECTION AND SUBMISSION OF PII AND NON-PII ON Allwink

General. When
Allwink collects PII from you it is because you are voluntarily submitting
Registration PII to us in order to register as a Member of Allwink. Allwink may
also collect PII from you if you choose to participate in Allwink Services
activities like sweepstakes, contests, and surveys, because you want us to
furnish you with products, services, newsletters, or information, or in
connection with content or suggestions you submit to Allwink for review.

In addition,
Allwink collects other non-PII including IP address, aggregate user data, and
browser type. This data is used to manage and improve the Allwink Services,
track usage, and for security purposes. 

Allwink Members
may also choose to provide or store non-PII information in their profiles,
including but not limited to date of birth, interests, hobbies, lifestyle
choices, groups with whom they are affiliated (schools, companies), videos
and/or pictures, private messages, bulletins or personal statements
(collectively “Profile Information”). The Profile Information in a Member’s
profile is provided at his or her sole discretion.

Allwink Members
can change their Registration PII and Profile Information at any time and can
control how Visitors, other Members and Allwink communicate with them by
controlling their account settings, available within the “Edit Profile” portion
of their Allwink profile. Link to

Privacy Settings.

Cookies. Cookies
are small bits of information that Allwink places on your computer. Allwink uses
cookies to identify your Internet browser, store Users’ preferences, and
determine whether you have installed the enabling software needed to access
certain material on the Allwink Services. Data in cookies may be read to
authenticate user sessions or provide services.

Third party
advertisements displayed on Allwink Services may also contain cookies set by
Internet advertising companies or advertisers (known as “third party cookies”). Allwink
does not control these third party cookies and Users of the Allwink Services
should check the privacy policy of the Internet advertising company or
advertiser to see whether and how it uses cookies. See the “Notice” section
below for more information on customized advertising on Allwink. A pixel tag is
a tiny image inserted in a webpage and used to record the number and types of
views for that page. Allwink may allow third party pixel tags to be present on
Allwink Services for purposes of advertising, providing services or data and
statistics collection.

You can program
your computer to warn you each time a cookie is being sent, block third party
cookies or block all cookies. However, by blocking all cookies you may not have
access to certain features on the Allwink Services.

NOTICE: Allwink WILL PROVIDE YOU WITH NOTICE ABOUT ITS PII COLLECTION
PRACTICES

When you
voluntarily provide PII to Allwink, we will make sure you are informed about who
is collecting the information, how and why the information is being collected
and the types of uses Allwink will make of the information to the extent it is
being used in a manner that differs from what is allowed pursuant to this
Privacy Policy.

At the time you
provide your PII, Allwink will notify you of your options regarding our use of
your PII (See “Choice” below). Except as described in this Privacy Policy,
Allwink will not share your PII with third parties unless you have given Allwink
permission to do so (See “Use” below).

Allwink Services
may be linked to Internet sites operated by other companies. Allwink Services
may also carry advertisements from other companies. Allwink is not responsible
for the privacy practices of websites or other services operated by third
parties that are linked to or integrated with the Allwink Services or for the
privacy practices of third party Internet advertising companies. Once you leave
Allwink Services via such a link, access a third party application (such as
widgets) or click on an advertisement, you should check the applicable privacy
policy of the third party or advertiser site to determine, among other things,
how they will handle any PII they collect from you.

Allwink Services
may also be linked to sites operated by companies affiliated with Allwink (i.e.,
that are part of the News America Group: “Affiliated Companies”). Although all
Affiliated Companies adhere to the News America corporate

Privacy Principles, Users who visit those Affiliated Company sites should
still refer to their separate privacy policies and practices, which may differ
in some respects from this Privacy Policy.

Allwink may use
cookies and similar tools to customize the content and advertising you receive
based on the Profile Information you have provided. Profile Information you
provide in structured profile fields or questions (multiple choice questions
like “Marital Status,” “Education” and “Children”) (“Structured Profile
Information”), information you add to open-ended profile fields and questions
(essay questions like “About Me,” “Interests” and “Movies”) (“Non-Structured
Profile Information”) and other non-PII about you may also be used to customize
the online ads you encounter to those we believe are aligned with your
interests. For example, based on your music interests we might display an
advertisement to make sure you are advised when your favorite band is coming to
town. The information used for this feature does not provide your PII or
identify you as an individual to third parties. If you would like to disable
advertising customization for Non-Structured Profile Information, please log in
and

click here.

Some of the advertisements that appear on Allwink Services may also be delivered
to you by third party Internet advertising companies. These companies utilize
certain technologies to deliver advertisements and marketing messages and to
collect non-PII about your visit to or use of Allwink Services, including
information about the ads they display, via a cookie placed on your computer
that reads your IP address. To opt out of information collection by these
companies, or to obtain information about the technologies they use or their own
privacy policies, please

click here.





Third party applications (such as widgets) created by third party developers may
also be available on the Allwink Services. Third party applications are small
bits of software, often with interactivity, that can be installed into Members’
profiles or shared with other Users. However, Allwink does not control the third
party developers, and cannot dictate their actions. When a Member engages with a
third party application, that Member is interacting with the third party
developer, not with Allwink. Allwink encourages Members not to provide PII to
the third party’s application unless the Member knows the party with whom it is
interacting. 

CHOICE: Allwink WILL PROVIDE YOU WITH CHOICES ABOUT THE
USE OF YOUR PII

Except as
described in this Privacy Policy, Allwink will get your permission before we use
the PII you provide to us in a way that is inconsistent with the purpose for
which it was submitted or share your PII with third parties that are not
affiliated with Allwink.

USE: Allwink'S USE OF PII

Allwink will only
use the PII you provide under this Privacy Policy in a manner that is consistent
with this Privacy Policy. If Allwink obtains PII from a third party, such as a
business partner, our use of that information is also governed by this Privacy
Policy.

In order to
locate other Allwink Members that you may already know in the physical world,
Allwink allows Users to search for Members using Registration PII (i.e., full
name or email address). Allwink also allows Users to browse for certain Profile
Information in order to help connect with Members (i.e., schools and/or
companies where Users may have attended or worked). Allwink may also enable
Members to publicly display some Registration PII as an element of their Profile
Information if they choose to do so via a profile setting under “Edit Profile.”
Search engines may index the portion of a Member’s profile (including the
Profile Information it contains) that is publicly displayed. 

If you have
consented to receive promotional materials (e.g., newsletters) or notifications
from Allwink, Allwink may periodically use your email address to send you such
materials related to the Allwink Services, as applicable. If you want to stop
receiving such materials from Allwink, you can change your profile settings
under “Account Settings,” or follow the unsubscribe instructions at the bottom
of each email. 

Allwink
employees, agents and contractors must have a business reason to obtain access
to your PII. Allwink may share your PII with those who help us manage or provide
Allwink Services’ information activities (for example, message board
administration, order fulfillment, statistical analyses, data processing), or
with outside contractors, agents or sponsors who help us with the
administration, judging and prize fulfillment aspects of contests, promotions
and sweepstakes.

These outside
contractors, agents or sponsors may temporarily store some information on their
servers, but they may only use your PII to provide Allwink with a specific
service and not for any other purpose. Allwink may also provide your PII to a
third party in those instances where you have chosen to receive certain
information and have been notified that the fulfillment of such a request
requires the sharing of your PII. Allwink also may share your PII with
Affiliated Companies if it has a business reason to do so.

As described in
“Notice” above, Allwink may customize the advertising and marketing messages you
receive on the Allwink Website, or may work with outside companies to do
so. Your non-PII and/or Profile Information may be shared with these companies
so this customization can be accomplished. Allwink prohibits these companies
from sharing your non-PII and/or Profile Information with any third party or
from using it for any other purpose. Anonymous click stream, number of page
views calculated by pixel tags, and aggregated demographic information may also
be shared with Allwink’s advertisers and business partners.

There may be
instances when Allwink may access or disclose PII, Profile Information or non-PII
without providing you a choice in order to: (i) protect or defend the legal
rights or property of Allwink, our Affiliated Companies or their employees,
agents and contractors (including enforcement of our agreements); (ii) protect
the safety and security of Users of the Allwink Services or members of the
public including acting in urgent circumstances; (iii) protect against fraud or
for risk management purposes; or (iv) comply with the law or legal process. In
addition, if Allwink sells all or part of its business or makes a sale or
transfer of all or a material part of its assets or is otherwise involved in a
merger or transfer of all or a material part of its business, Allwink may
transfer your PII to the party or parties involved in the transaction as part of
that transaction.

When a Member who
is located in the European Union chooses to post Profile Information that will
be publicly disclosed, that Member is responsible for ensuring that such
information conforms to all local data protection laws. Allwink is not
responsible under the EU local data protection laws for Member-posted
information.

SECURITY: Allwink PROTECTS THE SECURITY OF PII

Allwink uses commercially reasonable administrative,
technical, personnel and physical measures to safeguard PII and credit card
information in its possession against loss, theft and unauthorized use,
disclosure or modification. In addition, Allwink uses reasonable methods to make
sure that PII is accurate, up-to-date and appropriately complete.

ACCESS, REMEDIES AND COMPLIANCE: HOW TO ACCESS,
CORRECT OR CHANGE YOUR PREFERENCES REGARDING YOUR PII AND HOW TO CONTACT Allwink
ABOUT PRIVACY CONCERNS

Whenever possible, Allwink Members may review the
Registration PII we maintain about them in our records. We will take reasonable
steps to correct any PII a Member informs us is incorrect. If you are a Member,
you can view and change your Registration PII, Member preferences and Profile
Information by logging into your account and accessing features such as “Edit
Profile” and “Account Settings.” 

If you ask Allwink to stop using your PII, Allwink will
honor that request while retaining any record of your PII that is necessary to
comply with applicable federal, state or local law.

If you would like to communicate with us about this
Privacy Policy or Allwink’s collection and use of your PII, please use the
Contact Allwink form on our


Help site.