NETSEER, INC.

PRIVACY POLICY EFFECTIVE MAY 15, 2012

1. GENERAL

NetSeer, Inc. (“NetSeer”) is a provider of contextual targeting advertising service. This service allows advertisers and publishers to deliver contextually relevant advertising based on the intent of the user at the time the ad is being served.

NetSeer is a licensee of the TRUSTed Ads Program. TRUSTe is an independent organization whose mission is to build a user’s trust and confidence in the Internet by promoting the use of fair information practices.

This Privacy Policy (“Policy”) covers not only activity on this website (www.NetSeer.com) but also on any ad networks, exchanges or other ad delivery channels on which NetSeer places advertisements.

If you have any questions or concerns regarding this statement, you should first contact privacy @ netseer.com. If you do not receive acknowledgment of your inquiry or your inquiry has not been addressed to your satisfaction, please contact TRUSTe at http://truste.org/consumers/watchdog_complaint.php. TRUSTe will function as a liaison with NetSeer to help resolve your concerns.

2. INFORMATION COLLECTED

Personally identifiable information ("PII") is data that identifies a specific individual, such as name, address, telephone number, email address, and birth date. NetSeer does not collect PII.

NetSeer's web servers and ad servers automatically collect non-personally identifiable information ("NPII") which only includes "click stream data." Click stream data includes information such as a Site visitor's IP address, web pages viewed as well as date and time, and browser and platform type. These automated server functions do not collect this information in a manner intended to identify a Site visitor.

NetSeer uses a common Internet technology called "cookies" to collect NPII about Site visitors. A cookie is a small text file written to an Internet user's browser that contains unique information about the Internet user. Cookies do not collect or transmit PII.

3. HOW INFORMATION IS USED

We use NPII primarily for two purposes. The first is to do frequency capping for ad campaigns being administered by NetSeer. This controls the number of ad exposures to a user and results in a better ad experience for both user and advertiser.

The second way NPII is used is to serve appropriate promotions from advertisers to users who have expressed an implied interest through their visit to the advertiser’s site ("retargeting.") We keep this usre level data for 60 days, after which time, data is aggregated and maintained for six month solely for reporting purposes. We also use NPII in a limited fashion, for the administration and operation of the Site, designing and developing new products and services, and generally improving the overall quality of your experience with the Site and NetSeer services.

We do not share user level data with 3rd parties and only aggregate data is shared for reporting purposes.

If you’d like to opt-out of NPII based retargeting, please click the appropriate button below. Upon clicking “opt-out,” NetSeer will place an opt-out cookie on your browser. The opt-out cookie means you will not be re-targeted by ads served through NetSeer’s media platform. If you or a software agent acting on your behalf delete, block or otherwise restrict cookies, or if you use a different computer or internet browser, you may need to renew your opt-out choice. If you choose to opt-in, NetSeer will delete the opt-out cookie and you may be retargeted with relevant advertisement based on your visits to websites of our advertising customers.

NetSeer does not have a cookie based behavioral targeting solution and sometimes uses 3rd party data providers to complement its product offerings. These data providers are compliant with the recommendations set forth by the Network Advertising Initiative (“NAI”). Consumers can go to the following link to opt out of the behavioral advertising delivered by the NAI’s member companies:

http://www.networkadvertising.org/managing/opt_out.asp

NetSeer does not build and supply customers with any sort of “custom segments.” Nor does NetSeer engage in retargeting campaigns that market prescription drugs. NetSeer may offer retargeting services for consumer products that do not require a prescription. Examples of where retargeting might be offered include certain health categories like fitness equipment, calorie counters, etc.

4. THIRD PARTY WEBSITES

The Site may include links to other sites that are controlled by parties other than NetSeer. NetSeer does not control the data collection policies of any website linked to the Site and no third-party sites are covered by this Policy. Site visitors choosing to access such third-party websites should carefully review the individual privacy policies governing any such websites.

5. DATA SECURITY

We take all reasonable security measures to protect our data. Our data repository and databases are within a local intranet network which is not visible and accessible from outside of NetSeer’s internal network. No third party service and data storage provider is used to keep the data and any entry route to our database or data repositories must go through our VPN and firewall.