WHOSAY INC. VIEWER PRIVACY POLICY

This Privacy Policy applies to the information we may collect from or about you when you visit the WhoSay website www.whosay.com (the "Site") which is provided by WhoSay Inc. ("us," "we" or "our") and when you use related services and applications, including applications for mobile devices, content, widgets and other materials set out in more detail in our Terms of Use, (referred to collectively with the Site as the "Service").

Your privacy is important to us. To help you understand our privacy practices, we provide this notice explaining how we collect, use, and disclose information from or about you when you are on the Site or otherwise using the Service. By using the Service, you agree to the terms and conditions of this Privacy Policy and to the collection, disclosure and other uses of your information described below.

WHAT INFORMATION WE MAY COLLECT

In connection with your use of the Service, we collect and store any information you enter on our Site, via the Service or provide to us when you register or in any other way. This information includes different types of personally identifiable information including but not limited to your name, address, gender, e-mail address, SMS number, telephone number, fax number, birthday, and credit or debit card information. We may also collect information about your personal or professional interests and use of or opinions about various products, programs and services.

We may also collect certain information automatically when you visit the Site or use the Service, such as the type of browser or mobile platform and operating system you are using, your IP address, Internet service provider, platform type, referring and exit websites, cookies information (see "Cookies and Other Technologies" below), your use of the Service, and other clickstream data. When you use a WhoSay application on your mobile device, we may also collect information about your mobile's unique device identifier as well as other technical information about your device in order to serve content to it. We will also link your device to your geographical location if you have enabled location services on your mobile device. This enables us to provide you with location-based services that you request, but you can switch off location-enabled features at any time through your mobile device. Each time we request your location, your mobile device operation system manufacturer may also collect information about your location to provide and improve its location services. However, the location information we collect is not used by us to identify or contact you.

If you choose to connect a Facebook, Twitter, Google + or other third party social networking account with WhoSay, we may combine the information we collect directly from and about you with information that Facebook, Twitter, Google + or your other social networking provider lawfully shares with us. The information they provide to us may include your social networking user ID, any information you have shared publicly through that social networking service, and any other information which they are lawfully permitted to share with us. We use this information only for the purpose of enhancing the service we provide to you (for example, by allowing you to log into WhoSay using your social networking account credentials) and enabling you to share your WhoSay experiences through your connected social networking account(s).

If you provide information about another individual, you confirm that you have informed them of our identity and the purposes for which their personal data will be processed as set out in this Privacy Policy and that you have obtained their consent to such processing.

HOW WE USE THE INFORMATION

We use the information you provide to process your registration/subscription to the Service, to respond to your inquiries and fulfill your requests including without limitation any request to purchase goods or services via the Service and to send you messages or administrative information, such as updates to our Site or Service policies. We may also use the information we collect to personalize your experience and to offer you products, programs or services that may be of interest. We may combine information we receive with outside records and share such information with third parties to enhance our ability to market to you those products or services that may be of interest to you. In addition, we may use the information we collect from and about you for our business purposes, such as data analysis, audits, and improving our marketing and our services.

In particular, we may use information collected about your use of the Service through cookies and other technologies, to assist us in delivering to you relevant advertising when you visit the Site and when you visit other third party sites and use the Service. To do this, we may work with third party advertising networks and advertisers to deliver these ads to you. As noted in the section "Cookies and Other Technologies" below, these third party advertising networks and advertisers may also use cookies and similar technologies to collect and track your online behavioural information (such as demographic information, aggregated information, and Internet browsing activity) to assist them in delivering advertising that is more relevant to your interests. This information does not enable us or them to identify your actual identity however.

If you choose to submit content, including a comment, to the Site or using the Service, we may publish your name, screen name and other information you have provided to us. Please note that any information you post or disclose through any of the Service's interactive features may be available to Site visitors and to the general public. Furthermore, we may make such content and information available to other websites and networks. We are not responsible for the use by any third party of information that you publicly disclose through the our Service.

We use the information that we collect automatically when you use the Service for research and analytics purposes, including to improve the design, content, and user experience of the Service, as well as for other purposes specified in this Privacy Policy. For more information, please see the section "Cookies and Other Technologies" below.

MARKETING CONSENT

You can register with WhoSay to receive marketing and other communications on an ongoing basis. The communications we send you may include news and information about the artists, programs and other talent pages you follow, as well as information and offers about products, services and promotions we or our third party partners think may interest you. In addition, if you follow an artist, program or other Talent Account on our Web Site, we may pass your contact details to the relevant Talent Account so that they can contact you directly.

All of our communications will provide you with a method to unsubscribe, and you can also change your communications preferences by visiting your account settings. You may also exercise your right to opt out of the use of your information for marketing purposes at any time by contacting us using the method explained under the section below "Privacy Complaints or Queries".

COOKIES AND OTHER TECHNOLOGIES

To enhance your online experience, we use cookies. Cookies are text files we or our service providers place in your computer's browser to store your preferences. Cookies, by themselves, do not tell us your e-mail address or other personally identifiable information unless you choose to provide this information to us by, for example, registering in connection with the Service. However, once you choose to furnish the Service with personally identifiable information, this information may be linked to the data stored in the cookie.

Cookies allow us to collect information such as browser time, time spent on the Service, and pages visited. We use the information to understand Internet usage and to improve our content, offerings and advertisements. We may also use cookies to personalize your experience with the Service (e.g., to recognize you by name when you return to the Service), save your password in password-protected areas, enable you to use shopping carts, as well as to offer you products, programs or services.

Cookies set by the website owner (in this case, WhoSay Inc.) are called "first party cookies." Cookies set by parties other than the website owner are called "third party cookies". Third party cookies enable third party features or functionality to be provided on or through the website (e.g. like advertising, videos and analytics). The parties that set these third party cookies can recognize your computer both when it visits the Site and also when it visits certain other websites.

Cookies can remain on your computer for different periods of time. Some cookies are "session cookies," meaning that they exist only while your website browser is open and are deleted automatically once you close your browser. Other cookies are "permanent cookies," meaning that they survive after your browser is closed and can be used by websites to recognize your computer when you later re-open your browser and browse the internet again.

The specific types of cookies served through the Site are described below:

TYPES OF COOKIEWHO SERVES THEMWHAT THEY DO

Essential website cookiesWhoSayThese cookies are necessary to provide you with services available through this website and to use some of its features, such as access to secure areas. Without these cookies, services you have asked for, like shopping baskets and secure customer account pages, would not be possible.

Performance and functionality cookiesAdobe (click here for more information)These cookies are used to monitor and enhance the performance and functionality of our website but are non-essential to its use. However, without these cookies, certain functionality (like videos) may become unavailable.

Analytics and customization cookiesGoogle Analytics (click here to opt out)
comScore (click hereto opt out)These cookies collect information that is used either in aggregate form to help us understand how the website is being used or how effective marketing campaigns are, or to help us customize the website for you.

Advertising cookiesDoubleclick (click hereto opt out)
Krux Digital (click hereto opt out)These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers on sites that you visit, and in some cases selecting advertisements that are based on your interests.

Social networking cookiesTwitter (click here for more information)
Facebook (click herefor more information)
Google (click here for more information)
reddit (click here for more information)These cookies are used to enable you to share pages and content that you find interesting on our website through third party social networking websites.

You may set your Web browser to accept all cookies, block certain cookies, require your consent before a cookie is placed in your browser, or block cookies altogether. In order to adjust your browser settings or preferences, review the "Help" or "Internet Options" menu in your browser's tool bar.

We may also use small pieces of code such as "web beacons," "pixel tags," or "clear GIFS" in connection with some Site pages and email messages to, among other things, track the actions of Site users and email recipients, measure the success of our marketing campaigns, and compile statistics about Site usage and response rates. Web beacons are electronic files that count users who access a website or page and can also be used to see if a cookie has been activated. You can't decline web beacons; however, by preventing cookies being used on your computer you can prevent web beacons from tracking your activity.

The use of the technologies described in this section allows our third-party vendors to deliver advertisements when you visit the Site or other websites or web properties across the Internet. These vendors may place pixel tags, web beacons, clear GIFs or similar technologies on the Site and third-party websites and also place or recognize third-party cookies when you visit the Site or other websites. These vendors may use information about your visits to the Site and other websites to serve advertisements about our products and services, and other companies' products and services, that may be of interest to you (and to measure the effectiveness of those campaigns). If you would like more information about this practice and to know your choices about not having this information used by these companies, visit the Network Advertising Initiative at www.networkadvertising.org, the Digital Advertising Alliance at www.aboutads.info or YourOnlineChoices at www.youronlinechoices.eu.

By continuing to use the Service through your computer or mobile device, you consent to our use of cookies, pixels and local storage in accordance with this Privacy Policy.

HOW WE DISCLOSE THE INFORMATION

We may share your personally identifiable information with the celebrity, influencer, artist, group or other WhoSay talent (each, a "Talent Account") to whose WhoSay Site you subscribe. Information provided by or collected from you that may be shared with a Talent Account includes your name, location, contact details (e-mail and SMS details), Facebook, Twitter or Google + login credentials (to enable account connection between your Facebook, Twitter or Google + accounts and the Site and its related services), correspondence, user-generated content, and website cookies and aggregated analytical reporting data generated by your use of the Site.

RECIPIENTS

We do not otherwise share your personally identifiable information with third parties for their direct marketing purposes unless you give us your consent.

We engage certain trusted third parties to perform functions and provide services to us, including, without limitation, hosting and maintenance, customer relationship, database storage, management and analysis, and direct marketing campaigns. We will share your personally identifiable information with these third parties, but only to the extent necessary to perform these functions and provide such services, and only pursuant to binding contractual obligations requiring such third parties to maintain the privacy and security of your data.

We may use and share with third parties certain technical information (including IP addresses) or aggregated information to show general demographic and preference information and viewer patterns among Site viewers.

We may use and disclose the information we collect from and about you as we believe to be necessary or appropriate: (1) under applicable law, including laws outside your country of residence; (2) to comply with legal process; (3) to respond to requests from public and government authorities, including those outside your country of residence; (4) to enforce our Terms of Use; (5) to protect our operations or those of any of our affiliates; (6) to protect our rights, privacy, safety, or property and/or that of our affiliates, you, or others; (7) to allow us to pursue available remedies or limit the damages that we may sustain; and (8) to investigate, prevent or take action regarding illegal or suspected illegal activities.

Please note that if WhoSay Inc. or any of its affiliates, subsidiaries or lines of business is sold or otherwise disposed of, including through merger of, consolidation or sale of assets, or in the unlikely event that WhoSay Inc. goes out of business or enters bankruptcy, the relevant customer database, including personally identifiable information we may possess about you, may, in whole or in part, be sold, disposed of, transferred or otherwise disclosed as part of that transaction and you acknowledge that the acquirer of WhoSay Inc. or any of its affiliates, subsidiaries or lines of business may continue to use your information as set forth in this Privacy Policy (as amended from time to time).

THIRD PARTY SITES

The Site may contain links to other websites whose information practices may be different than ours and for which we are not responsible. You should consult the other sites' privacy policies, as we have no control over information that is submitted to, or collected by, these third parties.

SECURITY

We use appropriate technical and organizational measures to safeguard the personally identifiable information under our control. Unfortunately, no data transmission over the Internet or any wireless network or method of electronic storage can be guaranteed to be 100% secure.

Your account is protected by a password provided to you in connection with your third party socials networking account such as Facebook, Twitter or Google +. You are responsible for preventing unauthorized acces to your account.

INTERNATIONAL USERS, CROSS-BORDER TRANSFER

The Site is hosted in the United States, and therefore your information may be processed and stored in the United States. As a result, United States federal and state governments, courts, or law enforcement or regulatory agencies may be able to obtain disclosure of your information through laws applicable in the United States. In addition, your information may be transferred to and maintained in whole or in part on computer networks which may be located outside of the state, province, country or other governmental jurisdiction in which you reside, including the United States. You understand that the countries to which we may transfer information many not have as comprehensive data protection rules as in your country, and your use of the Service or your submission of any personal information to us will constitute your consent to the transfer of your personal information outside of the United States. However, please be assured that we take steps to ensure that your personal data is protected in accordance with this Privacy Policy.

OUR POLICY TOWARD CHILDREN

We do not knowingly collect personally identifiable information from children under the age of thirteen (13). If we become aware that a child under thirteen (13) has provided us with personally identifiable information, we will delete such information and the child's account from our system. If a parent or guardian becomes aware that his or her child has provided us with any personally identifiable information, which may include photos, videos and audio recordings of children, without their consent, he or she should contact us at privacy@whosay.com.

RIGHT TO ACCESS

You have the right to access the personally identifiable information we hold about you (for which we reserve the right to charge you a small fee, as permitted by applicable law) and to instruct us to correct or update it. Please submit any requests for access to your personal data in writing to privacy@whosay.com.

RETENTION PERIOD

We will retain your personally identifiable information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law.

PRIVACY COMPLAINTS OR QUERIES

In the event you have a privacy complaint or a query with respect to information collected by WhoSay Inc., you may contact us at privacy@whosay.com.

UPDATES TO THIS PRIVACY POLICY

This Privacy Policy may be changed periodically. We will notify you about material changes by sending a notice to the email address you registered with us and/or by placing a prominent notice on our Website. Your continued use of the Service constitutes your agreement to this Privacy Policy and any future revisions of it.

DATE LAST MODIFIED

January 8, 2014