Date of Last Revision: March 11, 2008

PENZU PRIVACY POLICY

Capitalized terms not herein defined shall have the meaning ascribed to them in the Penzu Terms and Conditions of Use (a copy of which may be found here).

1. COLLECTION OF PERSONAL INFORMATION

If you register and create an Account at www.penzu.com or penzu.com (the “Site”) you will provide Penzu Inc. (hereafter "Penzu", "we", "our", "us") with certain Registration Data including your first name, last name, date of birth, and e-mail address. Additionally, when creating a private personal profile, you may provide Penzu with such information as gender, geographic location, interests, biography, time zone and language preferences (Registration Data and information provided by users upon creation of a private profile hereafter collectively referred to as “Personal Information”).

When you send email or other communications to Penzu, we may retain those communications and any information contained therein to process your inquiries, respond to requests and improve our services.

Penzu will only ask for information about you when such information is required and you will be informed as to why it is so required and how it will be used.

2. SITE INFORMATION

When you enter the Site, we collect information with respect to your browser type and IP address. Additionally, Penzu also stores certain information from your browser using cookies (all information collected automatically through interaction with the Site is hereafter referred to as “Site Information”). Cookies are pieces of data stored on the User’s computer and contain information about that User. Many major browsers are initially set up to accept cookies. You can reset your browser to either refuse to accept all cookies or to notify you when you have received a cookie. However, if you refuse to accept cookies, you may not be able to use some of the features available on the Site.

3. USE OF PERSONAL INFORMATION

Penzu collects your Personal Information primarily for the purpose of providing you with the Service. Your Personal Information is also used to communicate with you about your Account and to provide you with information related to other products and services. To unsubscribe from any email communications from Penzu, users must deactivate their Account, which can be done from the Account page.

Penzu may also contact you from time to time to conduct market research and surveys in an effort to continually improve our product and service offerings. Penzu may also share certain voluntarily-provided information with partners and advertisers. However, Penzu will not share with partners and advertisers any personally identifiable Registration Data, such as a User’s last name and e-mail address.

We retain the right to aggregate all Personal Information on the Site on a general, non-personally identifiable level, in order to generate statistics which we may provide to advertisers and third parties for their marketing and promotional purposes. This information is in no way identifiable to you and is completely anonymous.

We do not sell or rent any personally identifiable Registration Data to third parties without your explicit consent. Unless you specifically authorize us to release such information, or release is required or permitted by law, we will not exchange, sell, lease, trade or otherwise give away such information to other third parties.

If we propose to use your Personal Information for any other purpose than those described in this Privacy Policy, we will obtain your consent first and offer you the option of opting out of such use of your Personal Information.

4. USE OF SITE INFORMATION

Site Information is collected for statistical purposes and to better serve our users. Our cookies are used to store session data and to help with the usability of our Site. We monitor the Site and analyze traffic patterns to help us with our research and development and create a better experience for you on the Site. Penzu may also keep track of whether external links presented on the Site are followed. We do not link IP addresses to personally identifiable information nor do we distribute or share IP information with any third party.

Non-personally identifiable information may also be used to display customized content and targeted advertising. Such customized content and targeted advertising will be automatically generated based on Site Information and/or keywords in User Content. Any information that is used to generate such customized content and targeted advertising is in no way disclosed to any third parties nor personally identifiable.

Penzu permits third parties that present advertisements on the Site to set and access their cookies on your computer. The use by such third parties of their cookies is governed by these parties’ own privacy policies.

5. DISCLOSURE OF PERSONAL INFORMATION

We will seek your prior consent to the collection, use and disclosure of the Personal Information as required by applicable privacy legislation. Subject to legal and contractual requirements, you can refuse to consent to our collection, use or disclosure of Personal Information about you. You may also withdraw your consent to any further collection, use or disclosure of Personal Information about you at any time by giving us reasonable notice. Such withdrawal of consent may limit your ability to use all or parts of the Service.

Penzu shall disclose Personal Information if we have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce the Penzu Terms and Conditions of Use, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against imminent harm to the rights, property or safety of Penzu, its users or the public as required or permitted by law.

To enable us to more efficiently provide the Service, Penzu may share your Personal Information with selected third parties who are acting on our behalf as our agents, suppliers or service providers. Such third party service providers are provided only with such information as is necessary in the circumstances. Information provided to third parties may be used only for the purpose stipulated and commercially reasonable efforts will be made to condition such provision of information to execution of confidentiality agreements.

Any User Content that you make available to other users, including, but not limited to, information in your User profile, granting access to other users to all or part of your online journal or sending messages to other users, is done so at your own risk. Any Personal Information that is Posted or sent by any User is the sole responsibility of such User and Penzu shall not be held responsible for any information that you make public.

6. ACCURACY

Penzu will try to ensure that information about you is accurate, complete and up-to-date. Please inform Penzu of any change of name, address or other Personal Information. In the event that you have questions about the accuracy of factual information we have collected about you, you will be provided with access to that information in order to verify and update it. If we have disclosed inaccurate information about you to a third party, we will be pleased to contact the third party in order to correct the information.

7. PRIVACY AND SECURITY OF USER CONTENT

Penzu is committed to protecting your privacy and the privacy and security of your User Content. In addition to your Account password, Penzu also provides users with the option of password protecting specific journal entries through the use of a second password for such entries.

Although we take measures to ensure the privacy and security of your User Content, we cannot guarantee its absolute privacy and security, as no privacy or security measures are perfect or impenetrable. We cannot control the actions of other users whom you have shared any Personal Information or Account information with, and therefore we do not guarantee that unauthorized individuals will not obtain access to your private User Content. We are also not responsible for any circumvention of our privacy or security systems. By using the Service, you acknowledge that Penzu does not encode or encrypt the contents of your User Content. Users are encouraged to password protect any journal entries which they do not want to share with others.

8. USER MESSAGES

Penzu users have the ability to send anonymous messages to other users of the Service. Any identifying information with respect to the sender of the anonymous message is kept strictly confidential by Penzu, except in circumstances where such disclosure is required in accordance with Section 5 above.

9. NO CHILDREN UNDER AGE 13

Penzu does not knowingly collect or solicit Personal Information from anyone under the age of 13 or knowingly allow such persons to register with the Site. If you are under 13, please do not attempt to register for an Account or send any information to us. In the event that we are aware of any users on the Site under the age of 13 we will delete all information related to such User and deactivate their Account from the Site. If you believe that we might have any information from or about a child under 13, please contact us at info@penzu.com.

10. MINORS BETWEEN THE AGES OF 13 AND 18 YEARS

We require that minors over the age of 13 ask their parents or legal guardians for permission before sending any information about themselves to anyone over the Internet.

11. EXTERNAL WEBSITES

The Site contains links to other external websites, including those of any advertisers on the Site. Penzu is not responsible for the privacy practices or the content of third party websites and users are strongly advised to read the privacy policy of all such websites. This Privacy Policy applies only to the information collected by Penzu.

12. THIRD PARTY SERVICE PROVIDERS

Penzu may use third parties to provide us with information regarding our users’ activities on the Site. Such third parties may set cookies on our behalf and receive Site Information. However, no such third parties will have access to any Personal Information which would reveal the identify of any of our users.

13. CHANGE OF OWNERSHIP

If all or substantially all of the ownership of Penzu changes, your Personal Information and Site Information may be transferred to the new owner(s) in order for the Service to continue to operate. In any such transfer of information, your information would remain subject to any pre-existing Privacy Policy.

14. ACCESS TO INFORMATION

If you have any questions about the collection, use or disclosure of your Personal Information by Penzu, or if you want to know whether we have any of your Personal Information on file, you may contact us. Except in limited circumstances, as specifically provided by applicable privacy legislation, Penzu can inform you whether we hold Personal Information about you. We can also disclose the source of the information, allow you access to your Personal Information and provide a brief description of use that has been made, or is being made, of the information and the third parties to which it has been disclosed.

Penzu will only refuse your access to your Personal Information in those limited exceptions permitted or required by applicable privacy legislation. Such exceptions may include information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, and information that is subject to solicitor-client or litigation privilege. Penzu will respond to your requests for access in accordance with applicable privacy legislation.

Should you no longer desire to use the Service, you may deactivate your Account with Penzu. In the event of any deactivation of your Account, your User Content and/or Personal Information may not be deleted by Penzu.

Users may also email Penzu at support@penzu.com and request that their Account be terminated. Penzu may also terminate your Account, in its sole discretion and without any notice, for any reason including, without limitation, violation of this Privacy Policy or the Penzu Terms and Conditions of Use. In the event of a termination of your Account, all User Content and Personal Information will be lost.

If you have any concerns in respect of the Site, this Privacy Policy, practices followed by the Site or your dealings with the Site, please email us your concerns at info@penzu.com.

15. NOTICE

We may amend this Privacy Policy at any time by posting the amended terms on the Site. All amended terms shall automatically be effective immediately and we are not required to notify you of the changes.