TRANSGAMING INC. PRIVACY POLICY

Committed to Protecting your Privacy

TransGaming Inc. and its affiliates ("TransGaming") recognize the sensitive nature of personal information. TransGaming adheres to rules governing the protection of confidential information and complies with the principles of The Personal Information Protection and Electronic Documents Act ("PIPEDA") and the National Standard for the Protection of Personal Information (CAN/CSA-Q830-96). This Privacy Policy governs TransGaming's collection, use and disclosure of "Personal Information" (as defined below) in the course of our commercial activities.

WHAT DOES PROTECTION OF YOUR PRIVACY MEAN?

• The collection, use, and disclosure of your personal information will be done in a manner that recognizes your privacy rights
• You have the right to access the information we have about you
• We keep your information and the business you do with us in strict confidence
• Our staff is familiar with this Privacy Policy and they understand the importance of abiding by the policies and procedures set out in this Privacy Policy

We have developed this Privacy Policy to outline our commitment to maintain your privacy when we collect, use and disclose Personal Information.

Scope and Purpose: This Policy applies to the collection, use and disclosure of Personal Information acquired by TransGaming, for example when you are on the TransGaming site or when you use TransGaming services and software. This policy does not apply to Personal Information collected by users of Cider-enabled games. For the Policy applicable to Cider-enabled games, please see http://www.transgaming.com/privacy.

Definition of "Personal Information": "Personal Information" is information about an identifiable individual.

Identification of the Purpose of Collection and Consent: TransGaming will identify the reason for the collection, use and/or any disclosure of Personal Information before or at the time of collection. We will only collect Personal Information with your consent. The collection of Personal Information will be limited to that which is necessary for the purposes identified by TransGaming when it seeks consent for the collection of information. Any change of purpose will be communicated to you and a new consent obtained. We will document all purposes for the collection of Personal Information.

Receiving consent will not be a condition of supplying a product or a service, unless the information requested is required to fulfill an explicitly specified and legitimate purpose. Individuals may withdraw their consent at anytime and TransGaming will explain to individuals the implications of withdrawing their consent. Personal Information will be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.

When We Collect: We collect information at various times, including when:

• You register for an account or sign up at one of our websites
• When you use certain TransGaming products or services, and when you enter promotions or sweepstakes
• When you access online features and/or services
• When you download and/or upload content
• When you activate updates
• TransGaming may also receive Personal Information from our business partners.

Type of Information Collected: By using TransGaming products or services you are deemed to have expressly consented to the collection of the information set out below:

• When you register with TransGaming, we may ask for your name, email address, address including country, phone and fax number (once you register with TransGaming and sign in to our services, you are not anonymous to us)
• Additional surveys may request more information but this information is not required and the purposes for which such information will be collected and used will be identified
• We may collect your user-name, user-profile and Game ID
• We will collect technical and related information that identifies your computer, such as an internet protocol address and serial key
• We will collect hardware information, information concerning your operating system, application software and peripheral hardware such as MAC model, CPU model and speed, RAM size, VRAM size and graphics card model and vendor ID
• TransGaming also automatically receives and records information on our server logs from your browser including your IP address, TransGaming cookie information, download tracking and the page you requested¹; TransGaming uses this traffic data to help diagnose problems with its servers, analyse trends and administer the website.

Personal Information may be used:

• To customize the advertising and content you see on our pages
• To fulfill your requests for certain products and services
• To improve products and services, to conduct research and to provide software updates and any dynamically served content, product support and other services to customers, including marketing and online play
• For service announcements or administrative messages relating to TransGaming's products and services
• To facilitate technical protection measures
• To assess our clients ongoing needs and offer products and services to meet those needs
• For billing, collection and accounting services relating to our products and services
• To meet communication, service and administration needs
• For internal, external and regulatory audit purposes
• To identify customer preferences
• In relation to contests, promotions, and surveys
• To protect you, our other customers and TransGaming
• To comply with legal requirements.

For statistical purposes we may collect, summarize and use customer information in a format that does not identify the individual. This anonymous aggregate data may be shared with our third party providers and business partners.

Disclosure: TransGaming will not sell or rent your Personal Information to anyone.

TransGaming will only share Personal Information about you to a third party(s) if we have first obtained your consent to share this information. This information will be shared if required to provide the product or service that you have requested.

In certain situations disclosure and use of Personal Information may be made without your knowledge and consent:

• For the purpose of collecting a debt owed by you to TransGaming
• When a government institution has requested the information and the information relates to the enforcement of any law, carrying out an investigation relating to the enforcement of a law or relates to national security and/or defence
• If we have reasonable grounds to believe that the information relates to a breach of an agreement or a contravention of any law that has been, or is about to be, committed, we will disclose the Personal Information to an investigative body or government institution
• When we are required to comply with subpoenas, warrants issued or court orders made by a court, person or body with jurisdiction to compel the production of information or when we are required to comply with rules of court regarding the production of records.

Implied Consent: In some cases, consent is implied. For example, if we ask to be provided with Personal Information for a stated purpose and the Personal Information is provided without objection, implied consent has been given.

Limiting the Use, Retention, and Disclosure of Personal Information: TransGaming will only use or disclose Personal Information for the purpose for which it was collected, unless the individual consents, or if the use or disclosure is authorized by PIPEDA or another legal authority. We will only keep your Personal Information for as long as it remains necessary or relevant for the purposes stated above or as otherwise required by law.

Security of Personal Information: We will maintain the strict confidentiality of all Personal Information collected, and will only disclose such information to our employees, or to third parties, when you have consented to such a disclosure.

We limit access to your Personal Information to employees who, as part of their job, need to come into contact with that information to provide products or services to you.

We have physical, electronic, and procedural safeguards to protect personal information about you. We will maintain your personal information in secure data storage to safeguard it from unauthorized access, use or disclosure. Our soft copy data storage will be protected by the appropriate technological measures (e.g. passwords and encryption) and any hard copies of Personal Information will be kept in locked filing cabinets or kept in offices with restricted access.

In the event that you believe you may be the victim of identity theft or other illegal conduct, please contact the appropriate federal, provincial or local law enforcement agencies directly.

Individual Access to Information: You have the right to access, verify and update your Account Information and preferences at any time, including whether you want TransGaming to contact you about specials and new products. You may request deletion of your TransGaming account by contacting the Privacy Officer and verifying your identity.

Upon request and following appropriate identification of the requestor that is satisfactory both to TransGaming and under PIPEDA, an individual will be informed of the existence, use and any disclosure of his/her Personal Information. The individual will be given access to that information if requested. A reasonable administration fee may be charged to supply the information. The approximate cost of the administration fee will be communicated to the individual prior to the release of the information.

If the Personal Information held by TransGaming is inaccurate TransGaming shall amend the information as required. In limited circumstances, TransGaming may refuse an individual access to their Personal Information; however, access will only be refused in accordance with PIPEDA or other applicable laws. For instance, if the Personal Information is protected by solicitor-client privilege, or would reveal confidential commercial information, TransGaming may refuse access to such information.

Products Offered in Partnership with Third Parties and Third Party Links: This policy does not apply to the practices of companies that TransGaming does not own or control, or to people that TransGaming does not employ or manage, including without limitation, any of TransGaming's affiliates or business partners.

Our website may include links to third party websites. We have no control over such sites and are therefore not responsible for, nor can any liability accrue to TransGaming as a result of, the manner in which the third parties that operate such linked sites collect, use, disclose and otherwise treat your Personal Information.

Children: We assume that if you are legally providing us with credit card information that you are an adult or are otherwise authorized to do so. We encourage parents and guardians to participate in their children's activities and to supervise them when they access on-line resources. We do not knowingly collect Personal Information from children under the age of 13. No information should be submitted to or posted on TransGaming sites by users under 13 years of age. If a child under the age of 13 submits Personal Information to TransGaming sites, we will delete the information as soon as we discover it was provided by a child undy Officer by email at: privacy@transgaming.com, by fax at (416) 979-9908, marked 'Attention: Privacy Officer', and by mail at:

Attention: Privacy Officer
TransGaming Technologies Inc.
431 King Street West, Suite 600
Toronto, Ontario
M5V 1K4 Canada

¹TransGaming may set and access cookies on your computer. TransGaming uses web beacons to access our cookies inside and outside our network of web sites and in connection with TransGaming products and services.