This Privacy Policy describes the information we collect about you and what may happen to that information.

1. Introduction
   
   
   1. General Introduction. This privacy policy describes how protrade.com and PROTRADE, operated by Citizen Sports, Inc., (collectively, "PROTRADE," "we," "us" or "our") collect and use information collected through the PROTRADE website ("Site"). Your information will only be used as described in this Privacy Policy; however, PROTRADE may modify these policies from time to time. The collection of personally identifying information is required to provide you with industry leading features while reducing the risk of fraud.
      
      
   2. General Collection. As part of the normal operation of our services, we collect and, in some cases, may disclose information about you. Please read this policy carefully to enable you to make an informed decision, and retain a copy for your records if you open an account.
      
      
   3. Assent. PROTRADE collects information from you, other Site visitors and other customers at several different points on the Site. By creating an account or continuing to use this Site, you expressly consent to this Privacy Policy and the Terms of Use, including, without limitation, your consent to use and disclose your personally identifiable information in the manner described in this Privacy Policy. If you object to your information being used in this way, you should not register or otherwise use this Site. This Privacy Policy is incorporated into and subject to the Terms of Use. Any terms used but not defined herein shall have the same meaning as those contained in the Terms of Use.
      
      
   4. Other Sites. This Site may contain advertisements and links to certain other third party websites. These third party sites are governed by their own privacy practices and we are not responsible for such privacy practices. This Privacy Policy applies solely to the use and disclosure of personally identifiable information collected by PROTRADE and not any third party site.
      
      
   5. Contact Information. We welcome your comments regarding this Privacy Policy. If you believe we have not adhered to this Policy or if you have any other questions regarding this Policy, please contact PROTRADE at http://www.protrade.com, click on Help.
      
      
2. Types of Information Collected
   
   
   1. Establishing an Account. In order to participate in our online games, sweepstakes or contests, you must be registered with PROTRADE and open and maintain an account with PROTRADE. During registration you are required to provide us with the following contact information: your e-mail address, an unique username and an acknowledgement that you are thirteen years of age or older. For prize redemption, you are required to provide us with your full name and mailing address. The following personally identifiable information is optional: your phone number. If you are engaging in any transaction with a fee, you will be required to provide the following credit card or debit card details: your credit or debit card number, your name as it appears on your credit card, the expiration date of the card, the security code (CSC) on the card and your billing address. This required information is necessary to process transactions and to contact you should the need arise in administering your account. This required information is also used to send you information relating to our services or promotional offers.
      
      
   2. Non-personal Information. We also collect non-personal information that we use to customize your experience on PROTRADE, including: IP address, Internet service provider, geographic location, browser type, operating system, pages viewed on PROTRADE, cash and prize winnings and game statistics. Although this information is related to your preferences and activity, it is not associated with your personally identifiable information and cannot be linked to you personally.
      
      
   3. Cookies. In common with most web sites, PROTRADE uses standard technology called "cookies," which are small data files that are transferred to your computer when you allow your browser to accept cookies. Cookies automatically identify your Web browser to the Site whenever you visit the Site, and make using the Site easier for you by saving your user ID, preferences and other convenient Site usage information. By tracking how and when you use the Site, cookies help us determine which areas are most utilized. Many improvements and updates to the Site are based on data obtained from cookies. Accepting cookies also allows you to customize your experience on the Site. Some of our advertising is placed by agencies that may use cookies of their own. You may learn more about how they use this information by visiting their sites. If you do not want to allow information to be collected through the use of cookies, you can generally opt out of providing this information by turning the cookies off in your browser. However, some areas of the Site may not provide you with an acceptable user experience if you have disabled the use of cookies.
      
      
   4. Correspondence. We retain all correspondence, including facsimiles, mail and e-mails, sent to us in our files for future reference. We may also retain correspondence, such as customer service inquiries, from PROTRADE to you. We may delete any of the foregoing records over time as we best determine meets our business needs. We do not currently grant any third parties access to this information, but reserve the right to do so (i) as required by law; or (ii) as otherwise provided herein.
      
      
   5. Marketing Data. You may have the opportunity to participate in demographic surveys and other marketing inquiries in an effort to further improve the use of the Site. Participation in these efforts is voluntary and you will have the opportunity to decide whether or not to disclose information. The use of the information collected will be explained in detail in the documentation that accompanies the surveys and marketing inquiries that you receive from us.
      
      
3. Use of Information
   
   
   1. Generally. The information collected may be used to: (i) ensure that you are of sufficient legal age to participate; (ii) process your transactions, including, without limitation, entry fees or payments of any winnings; (iii) provide customer services and resolve any complaints; (iv) improve the Site and service and resolve any technical problems; (v) communicate with you concerning the services offered on the Site by PROTRADE or any of its affiliates or business partners; (vi) create aggregate data; (vii) ensure compliance with the Terms of Use; and (viii) comply with any applicable laws and regulations, including but not limited to anti-money laundering laws which, among other things, may oblige PROTRADE to obtain and verify evidence of your identity.
      
      
   2. Legal Compliance. We release account and other personal information when we are required to do so in order to comply with the law.
      
      
   3. Advertisers. We aggregate (gather up data across all user accounts) personal information and disclose such information in a non-personally identifiable manner to advertisers and other third parties for their marketing and promotional purposes. However, in these situations, we do not disclose to these entities any information that could be used to identify you personally.
      
      
   4. Contests or Sweepstakes. We may operate contests and sweepstakes through the Site which may require registration. The personally identifiable information described above may be used to contact you for winner notification, prize delivery confirmation or other related purposes. In the event you win a contest or sweepstakes, we will post publicly your name, the name of the contest or sweepstakes you won and the amount of your prize on the Site, such as on a winner's page. In some instances, a third party advertiser or sponsor may operate or host a contest or sweepstakes that is promoted on the Site and, as part of the contest or sweepstakes, may collect your information. In those cases (where we are not the operator or host of the contest or sweepstakes), we have no control over the information collected. Thus, before participating, we urge you to review the advertiser's or sponsor's privacy policy as applicable to the contest or sweepstakes.
      
      
   5. If a user elects to use our referral service for informing a friend about our site, we ask them for the friend's email address. PROTRADE will automatically send the friend a one-time email inviting them to visit the site. PROTRADE stores this information for the sole purpose of sending this one-time email and tracking the success of our referral program. The friend may contact PROTRADE at support@protrade.com to request not to receive further email communications from PROTRADE.
      
      
4. Disclosures. PROTRADE discloses the personally identifiable information described above: (i) to companies that help process the transactions you request, in order to protect your transactions from fraud and verify your identity; (ii) that PROTRADE in good faith believes is necessary or appropriate to cooperate in investigations of fraud, intellectual property infringements or other activity that is illegal or may expose us or you to legal liability, or to conduct investigations of violations of the Terms of Use; (iii) when required by law or to comply with a court order, subpoena, search warrant or other legal process; (iv) to comply with legal, regulatory or administrative requirements of governmental authorities (including, without limitation, requests from the governmental agency authorities to view your personally identifiable information); (v) to protect and defend PROTRADE, its subsidiaries and affiliates and any of their officers, directors, employees, attorneys, agents, contractors and partners, in connection with any legal action, claim or dispute; (vi) to prevent imminent physical harm; (vii) to share aggregated statistical or demographic data with our affiliates, business partners or for public relations (this aggregated information is not enough to reveal your identity); (viii) to share data, including personally identifiable information about you, with our affiliates, subsidiaries and business partners that are committed to serving your online needs and related services; and (ix) in the event that PROTRADE, or a unit thereof merges with or is acquired by another company. In the Event that PROTRADE or a unit thereof merges with or is acquired by another company, the successor company will have access to the information maintained by PROTRADE, including customer account information, in order to continue to provide services, but would continue to be bound by this Privacy Policy unless and until it is amended as described in "Changes to this Policy" below.
   
   
5. Informing You. We may communicate with our customers on a regular basis via e-mail and/or mail to provide requested services, newsletters to resolve any complaints and for general customer service, and by other means where applicable, such as to investigate any suspicious transactions. You may receive occasional service announcements and administrative messages, for example, advance notice of any maintenance that might affect the Site. You cannot opt out of these types of "informational" rather than "promotional" communications.
   
   
6. Your Profile. We store information that we collect through cookies, log files and graphic files to create a profile of our customers. We also purchase third party marketing data and add it to our existing customer database so we can better provide pertinent offers in which you would be interested. We use this information to enhance or overlay your profile. This aggregate marketing data is therefore tied to your personally identifiable information. A "profile" is stored information that we keep on individual customers that detail their preferences. Consequently, all of the collected information is tied to your personally identifiable information to provide better offers and improve the content of the Site for you. Your profile may be shared with our affiliates, subsidiaries and business partners.
   
   
7. Security
   
   
   1. Limits of Security Measures. By opening an account and using the Site, you acknowledge that you understand that "perfect security" does not exist on the Internet and that we cannot ensure that all of your private communications and other personally identifiable information will never be disclosed in ways not otherwise described in this Privacy Policy. You agree that you do not expect that your personally identifiable information or private communications will always remain private.
      
      
   2. Confidentiality Obligation. The security of your PROTRADE account also relies upon your protection of your PROTRADE unique username, password or other appropriate security code ("IDs"). You agree to never share your IDs with anyone. In the event that you are concerned that your IDs are no longer secure and confidential, you should immediately notify PROTRADE at http://www.protrade.com, click on Help.
      
      
8. Accessing, Reviewing and Changing Personal Information
   
   
   1. Changing Information. Following registration, you can review and change the personal information you provided to us, at any time, by selecting Edit Profile within your account information page. You hereby agree to keep your account information up to date at all times.
      
      
9. Changes to this Policy
   
   
   1. Updates. PROTRADE reserves the right to change this policy. While we will indicate material changes by posting a prominent notice on our site, users can also check here to see if a revised policy has been posted. You will be notified of a material change in our privacy policy through a notice posted on our Web site.
      
      

To contact Customer Support: http://www.protrade.com click on Help

If you have any questions about this privacy policy or the privacy practices of this Site, you can contact Customer Support using the link above or you can contact us by mail at:

PROTRADE c/o Citizen Sports, Inc.
Customer Support, Attn: Privacy Policy
525 Brannan Street, Ste. 100,
San Francisco, CA 94107-1632

Date Last Modified: January 30, 2008