Privacy Policy

CodeBaby respects your privacy and is committed to maintaining the privacy and confidentiality
of personal data we collect. The purpose of our Privacy Statement is to demonstrate our firm
commitment to the privacy and protection of all persons who provide personal data to CodeBaby
and its affiliates. This Privacy Statement describes the ways we collect information from and
about you, and what we do with the information, so that you may decide whether or not to
provide information to us.

By visiting CodeBaby websites or otherwise providing your personal information to CodeBaby
via any other means, you are accepting and consenting to the practices described in this Privacy
Statement.

For purposes of this Privacy Statement, the term “visitor” includes visitors to our websites who
are not yet customers, those who become customers, as well as those who do not become
customers; whether you upload information to our websites, download it, or are merely visiting
our websites. You can choose not to provide certain information when using our websites but
then you might not be able to take advantage of many of its features.

1. WHAT DO WE COLLECT AND WHERE?

The information we collect may include your personal information, such as your name, contact
information, IP addresses, Live Chat Messages, Telephone conversations, product and service
selections and orders or other things that identify you individually. Generally, we may collect
information about you in the following manners:

• you may provide your personal information to us via chat, email or other written
  correspondence, telephone calls, web based forms, or other means;
• we use automated technical means to collect information about all website visitors for example
  by use of cookies;
• via third party providers; and
• CodeBaby affiliates located in the European Union may provide CodeBaby with personal
  information about their prospective or current customers.

Web Visit

You may visit our Websites in any of the following ways:

• By using your browser to navigate to our Websites including (but not limited to)
  www.CodeBaby.com; partners.CodeBaby.com; apps.CodeBaby.com
• By viewing an advertisement displayed on a third party website that is served content by our
  web server;
• By viewing an email that is served content by our or a third party web server.

When you visit our Website, our server logs your IP address (unique network addresses), the
time and duration of your visit, and the time and duration of the pages on our website you view.
If you arrive at our website by clicking a paid advertisement (including a paid search engine
result) or a link in an email, then we will capture information that tracks your visit from that link.
If you arrive at our Website by clicking a non-paid source, such as link in a non-paid search
engine result or an unsponsored link on another website, we may capture information that tracks
your visit from that source, to the extent we are able to do so. We may also capture information
about your computer system, such as your browser type and operating system.

We will likely place a cookie on your hard drive during the web visit. A cookie is a unique
alphanumeric identifier that we use to help us identify the number of unique visitors to our
Website, whether or not those visitors are repeat visitors, and the source of the visits. Cookies
cannot be executed as code or used to deliver a virus. Other servers cannot read them and
personal information cannot be gathered from them. They are simply an identifier shared
between you and us to allow us to improve the services we offer to you through our Website. If
you do not wish cookies to be placed on your computer, then they can be disabled in your web
browser. The option to do so is normally found in your browser’s “security settings” section.
However, please note, permanently disabling cookies in your browser may hinder your use of
our Website as well as other websites and interactive services.

A web beacon, also known as a web bug, is a small graphic (usually 1 pixel x 1 pixel),that is
embedded in a web advertisement, email, or page on our web site, but is invisible to you. When
you view a page on our web site, an email or an advertisement your web browser will request the
web beacon from a web server, which in turn will set a cookie in your web browser containing a
unique identifier. This unique identifier will be linked to log information that is used to track
your movements on our web site in order to determine the effectiveness of content and
advertising campaigns.

We do not collect personal information about you as part of a web visit, but web visit
information may be tied to other information (including personal information) we collect from
you via chat, web forms, and the other means we describe in this Privacy Statement.
Our advertising agencies may also use web beacons and cookies to track your activity on our
website originating from the advertisement. However, we will not provide your personal
information to our advertising agencies. Our advertising agencies maintain their own privacy
policies, and you should also review those.

Links to non-CodeBaby Websites

We may provide links to third-party websites for your convenience and information. The privacy
practices of those sites may differ from CodeBaby practices and are not controlled by CodeBaby
and covered by this Privacy Statement. We do not make any representations about third-party
websites. We encourage you to review their privacy policies before submitting your personal
data.

Personal information received from the EU

• When CodeBaby is a data controller – Safe Harbor compliance

CodeBaby adheres to the Safe Harbor Principles (Notice, Choice, Onward Transfer, Security,
Data Integrity, Access and Enforcement) as described in this Privacy Statement, with respect to
the personal data we collect from EU data subjects or receive from our affiliates located in the
EU, such as information regarding service requests, service orders, handling orders, delivering
services and processing payments; and have certified our compliance with the Safe Harbor
Framework to the United States Department of Commerce. CodeBaby Safe Harbor certification
can be found at https://www.export.gov/safehrbr/list.aspx.

• When CodeBaby is a data processor

CodeBaby’s obligations with respect to personal data for which CodeBaby is solely a data processor, such as personal data that CodeBaby’s customers store or transfer using CodeBaby’s hosted technology services, are defined in its agreements with its customers and are not included in this Privacy Statement. In those circumstances CodeBaby receives personal data from the EU as an agent of the customer merely for processing and is not required to apply Safe Harbor principles to that information. The customer will remain responsible for the personal data that it collects and processes and for the compliance with applicable data protection laws.

Sensitive Information

We will not intentionally collect or maintain, and do not want you to provide, any information
regarding your medical or health condition, race or ethnic origin, political opinions, religious or
philosophical beliefs or other sensitive information.

Children’s Online Privacy Protection

Our services are not designed for or directed to children under the age of 18, and we will not
intentionally collect or maintain information about anyone under the age of 18.

2. WHAT DO WE USE THIS INFORMATION FOR?

Personal Information

We may use your information to process your service requests, handle orders, deliver products
and services, process payments, communicate with you about orders, provide access to secure
areas of the Website, recommend merchandise and services that might be of interest to you, to
personalize your visit to our Website, and to enable us to review develop and continually
improve the products services and offers we provide online. We also use this information to
prevent or detect fraud or abuses of our Website and to enable third parties to carry out technical,
logistical or other functions on our behalf.

Contact Information

We use visitor information to send information about our company to visitors and to get in touch
with them when necessary. We also use the information we collect to improve the content of our
websites and as training aides for our employees. Visitors are given the choice at the point when
we request their information.

Financial Information and payment card details

We may ask visitors to enter credit card or account information in order to process orders for
services placed with CodeBaby or its affiliates. Financial information provided via our website or
via the CodeBaby service is transferred over a secure connection. We will not authorize the
release of the information with anyone not directly involved in processing the transaction.
Credit card numbers are used only for processing payments and are not used for any other
purposes. When we use third party service providers for credit card processing services we will
enter into a written agreement with such third party ensuring appropriate security and
confidentiality measures are in place in safeguarding your personal data.

We use web visit information to measure interest in and develop our web pages and marketing
plans, customize the content you view on your web visits based on your activity on past visits,
and administer our Website.

• We use the visitors’ IP address to help diagnose problems with our servers, and to administer
  our Websites.
• We use cookies to help us recognize visitors as unique visitors (just a number) when they return to our websites For example, if there are 1,000 visits to our website on a certain day, we can use cookies to discover how many of those visits were made via the same browser (same visitor). We may also use the cookie to discover whether a certain visitor has visited our site more than once, and the source for each visit. We also use cookies to: allow us to tailor content or advertisements to match your preferred interest; avoid showing visitors the same advertisements repeatedly; compile anonymous, aggregated statistics that allow us to understand how users use our site and to help us improve the structure of our Website (we cannot identify visitors personally in this way); count the number of anonymous users of our sites.
• We use web beacons to count the number of times that our advertisements and web-based email content are viewed. We combine web beacon information with cookies to track activity on our website originating from advertisements and web-based email content.

We use information you provide to us via telephone calls, chat, email, web forms and other
communications to correspond with you about services you may be interested in purchasing. If
you elect to purchase a service online using a web form, we will use the information to establish
your account. Information you submit in writing, such as chat, email, and web form information
is archived and may be tied to information that we collect about your web visits. Your telephone
call may be recorded for training purposes and we may enter information you provide via
telephone into our systems to use for the purposes described in this paragraph.

3. DISCLOSURE OF PERSONAL INFORMATION

Personal information we gather is for internal use only and will not authorize the release of this
information to anyone outside CodeBaby (except to third party service providers to CodeBaby
who perform functions on our behalf but in such event personal information will only be shared
to the extent reasonably necessary to perform their functions and they will not be authorized to
use it for any other function), unless you have consented to such disclosure.

Should you breach our terms and conditions or website terms, or if we are under a duty to
disclose or share your personal data in order to comply with any legal obligation, we may
disclose your information to a relevant authority. This may include exchanging information with
other companies and organizations for the purposes of fraud protection and credit risk reduction.
In particular, we may release the information we collect to third parties when we believe it is
appropriate to comply with the law, to enforce our legal rights, to protect the rights and safety of
others, or to assist with industry efforts to control fraud, spam or other undesirable conduct.
We may release the information we collect to third parties, where the information is provided to
enable such third party to provide services to us, provided that the third party has agreed to use at
least the same level of privacy protections described in this Privacy Statement, and is permitted
to use the information only for the purpose of providing services to us.

4. OPTING OUT OF COMMUNICATIONS

CodeBaby gives you an opportunity to chose to opt-out of personal data being disclosed to third
parties for a purpose incompatible with the purpose for which it was originally collected (except
for meeting applicable legal requirements or permitting third party service providers who
perform functions on our behalf as described in section 3 of this Privacy Statement), including
your opting out of receiving future marketing mailings. We will not use your contact information
to correspond with you about our services if you ask us not to. Please send your request to
support@CodeBaby.com. Please note that it may take up to ten days to remove your contact
information from our marketing communications lists, so you may receive correspondence from
us for a short time after you make your request.

5. SECURITY OF YOUR INFORMATION

CodeBaby is committed to industry best practices approaches concerning security measures to
prevent the loss, misuse and alteration of the information in our possession. We use various
security measures to protect the information we collect, as appropriate to the type of information,
including encryption, firewalls, and access controls. We store information you provide to us on a
computer system located in a controlled facility with a limited access. Visitor textual information
is encrypted during transmission, our company databases are accessible only by CodeBaby
employees, contractors and agents on a need to know basis and who have entered into and are
bound by a confidentiality and nondisclosure agreement with CodeBaby.

6. DATA INTEGRITY

Personal data we collect is relevant for the purposes for which it is to be used. CodeBaby takes
reasonable steps to ensure that data is reliable for its intended use, accurate, complete, and
current.

7. RIGHT TO ACCESS YOUR PERSONAL INFORMATION

If you believe that any personal information we have about you is incorrect, or is, has been, or
might be used inappropriately, please contact us at support@CodeBaby.com, and we will take
steps to correct or delete the information, or restrict its use, as appropriate.

8. VERIFICATION

CodeBaby utilizes the self-assessment approach to assure its compliance with its Privacy
Statement. CodeBaby regularly verifies that the privacy statement is accurate, comprehensive,
prominently displayed, completely implemented and in conformity with the Safe Harbor
Principles and conducts its self-assessment on an annual basis to ensure that all relevant privacy
practices are being followed. Appropriate employee training is in place and internal procedures
for periodically conducting objective reviews of compliance are in place.

9. INQUIRIES OR COMPLAINTS

If you have a question or complaint about this Privacy Statement or our information collection
practices, please contact us at support@CodeBaby.com. We will investigate the matter and are
committed to resolve any privacy concerns that you may have. If your inquiry has not been
satisfactorily addressed and you are a visitor located in the EU, you may contact European Data
Protection Authorities, elected as a Dispute Resolution in our Safe Harbor self-certification.

10. CHANGES

Our business changes constantly and our Privacy Statement may also change from time to time.
You should check our website frequently to see recent changes, however, we will never
materially change our policies and practices to make them less protective of personal information
collected in the past without your prior consent.

This Privacy Policy was last updated on January 31, 2011.