Trilegiant Corporation ("Trilegiant") has created this privacy policy statement in order to demonstrate our firm commitment to our visitors' and customers' privacy. The following statement discloses our information gathering, use and dissemination practices for the www.cleverclubhouse.com ("Clever Clubhouse" or "CCH") web site on behalf of Trilegiant and its third –party content provider, ALFY, Inc. You should read and accept the Trilegiant privacy policy before you use the CCH website.

Who We Are

Trilegiant Corporation
Address: 100 Connecticut Avenue
Norwalk, CT 06850-3561

Telephone: 1-888-617-2582. Customer service e-mail: service@cleverclubhouse.com

Personal and Non-Personal Information

When you (the parent) visits the Clever Clubhouse web site in order to become a Member, register your child(ren) to use the web site and other services, participate in parent-only activities, make a purchase, enter a contest for yourself or on behalf of your child(ren), respond to a survey or update your or your child(ren)'s information, or participate in activities as a CCH Member, you may be asked to provide certain personally identifiable information ("Personal Information") about yourself, such as your name, e-mail address, physical address, telephone number, date of birth, mother's maiden name or social security number. For purchases, we require a name, physical address, telephone number, and credit card number. You may review and revise any Personal Information we have about you by sending a request to service@cleverclubhouse.com or calling 1-888-617-2582.

Our authorized third-party content provider, ALFY, Inc., is responsible for the collection and use of your Personal Information on our behalf. The information you provide is protected by a confidentiality agreement between Trilegiant and ALFY, Inc., and is to be used solely for the purposes described in this privacy policy.

When you, the parent (“Member”) create a Clever Clubhouse Account (“Primary Account”), we collect information only from and about the parents. This information may include a User Name (a nickname) and password, and the full name, address, phone number, e-mail address and credit card information of the parent responsible for the Clever Clubhouse Primary Account.

When you (the parent) create a child sub-account ("Sub-Account”), either during the registration process or at a later time, we collect a User Name and a Password for this child as well as his or her first name, sex and date of birth. We use this information to make the child's experience on the web site friendlier and to select the appropriate activities based on the child's age. The parent responsible for the Clever Clubhouse Primary Account is the only person who can add children to his or her Account and enter this information. Whenever a child is added to a Primary Account, we require that the parent acknowledge and agree to the terms of this Privacy Policy.

We may also request from you (the holder of the Primary Account), non-personally identifiable information ("Aggregate Information") about you or your family, such as annual income, buying preferences, or your age. Providing this demographic and profile type of information is optional. This information is collected anonymously and will not be linked to individuals, so we will have information about everyone who answered the questions only as a group, rather than as individuals.

Children’s Online Privacy

We do not sell, share or intentionally make any personally identifiable information about any children publicly available, except as provided herein or in compliance with the Children's Online Privacy Protection Act of 1998 ("COPPA") (for a complete description of COPPA, go to the US Government’s special web site at: http://www.ftc.gov/bcp/conline/edcams/kidzprivacy/index.html).

We keep the collection of Personal Information about any child to a minimum. We do not currently collect any Personal Information in our child activities. Children can use all of the features of our web site without giving us any additional Personal Information at all. If, in the future, we ever choose to collect any personally identifiable information from children, we will first obtain parental consent.

Parents have the right to review any personally identifiable information we have collected from or about their child(ren) and maintained in a retrievable form. At any time, they may later review or update the Personal Information we have collected online from them or their child(ren) by contacting us at service@cleverclubhouse.com. They have the right to have this information deleted and to refuse to permit further collection of that information, but the creation of a Child Sub-Account requires the parent to enter the child’s name, birthday, gender, and a parent-created username and password in order to access the web site. This can be done from Clever Clubhouse's Parent Control Center, or by sending us an e-mail with your child's User Name and Password to service@cleverclubhouse.com.

Please note that pursuant to the Clever Clubhouse Membership Agreement and the Clever Clubhouse Terms and Conditions, by subscribing to Clever Clubhouse, the person responsible for the Primary Clever Clubhouse Account represents that he/she is the parent or legal guardian of each child under the age of 18 who uses any Child Sub-Accounts linked to the Primary Account.

Some areas, applications or options in applications are available only to adults. Access to these is controlled by the User Name and Password of the Primary Account. Holders of Child Sub-Accounts can not access these areas, applications or options. For example, the Parent Control Center is an area intended only for adults and can only be accessed by the holder of a Primary Account. In this area, parents can review and edit their own account information, add and remove Child Sub-Accounts, set access restrictions, passwords and other options for their children and review and edit Personal Information regarding their children. Children are not permitted to log into the Parent Control Center and a Child Sub-Account's User Name and Password will not give a child access to a Primary Account.

Sweepstakes and Contests - From time to time, Clever Clubhouse offers sweepstakes and contests in which children may participate. In all cases, parents need to make each entry on their child’s behalf. If they do not, then their child is not entered in the contest. If the parents submit the entry (through their Primary Account), then the child is entered in the sweepstakes or contest, and Clever Clubhouse will contact the parent via e-mail if the entry is selected as a winner. We may also offer sweepstakes and contests for parents.

Reporting System - Clever Clubhouse features a unique reporting system which gives parents the ability to see where their child has been on the Clever Clubhouse site and suggests new applications which may interest their child. Only the child's parent has access to view this information, by logging into the Parent Control Center through the Primary Account. We may also use this information to suggest new applications or activities to you and your child. In addition, we may analyze this information from time to time on an aggregate basis in order to improve our web site. We do not share information from the reporting system with any third parties.

Although we comply with COPPA, we are not responsible for any misuse of Primary Accounts, passwords, or user names. It is very important that parents understand the features, uses and potential risks of using the Clever Clubhouse site. That's why we advise all users to practice safe computing and urge parents to monitor their child(ren)'s Internet usage and tell their child(ren) not to give out any personally identifiable information on a website without their parent's consent.

CLEVER CLUBHOUSE MAKES NO GUARANTEES, WARRANTIES OR REPRESENTATIONS THAT YOU OR YOUR CHILD WILL BE ABSOLUTELY SAFE OR INSULATED FROM INAPPROPRIATE CONTENT OR BEHAVIOR AND WE DO NOT GUARANTEE, WARRANT OR REPRESENT THAT A CHILD WILL NOT TRY TO CIRCUMVENT, OR BE SUCCESSFUL IN CIRCUMVENTING, THE FEATURES ON OUR SITE. FURTHERMORE, CLEVER CLUBHOUSE DOES NOT ASSUME ANY OBLIGATIONS, LIABILITY, OR RESPONSIBILITIES ASSOCIATED WITH SUCH BEHAVIOR OR ASSOCIATED WITH THE OBLIGATIONS OF PARENTAL SUPERVISION.

Information Usage

As explained above, we do not share Personal Information about children with unaffiliated third parties. We use your (the Parent’s) Personal Information to fulfill orders and to contact you when necessary, such as when your transactions or requests cannot be processed. We may also use this information to notify Members about new products or services and special promotions offered by Clever Clubhouse, Trilegiant or any of its affiliates. From time to time, we may also share your Personal Information with trustworthy unaffiliated third parties, who offer products or services that we feel may be of interest to you. See the "Opt-Out Process" section below if you would prefer that we do not share your Personal Information with unaffiliated third parties or with Trilegiant-affiliates.

Technical Problems Report Form - As part of our customer care, we have an online form for reporting technical problems. The form asks for but does not require information such as the Member's e-mail address, hardware and software being used, and details of the problem. We do not disclose this information to any other parties except on an aggregated basis in order to improve the web site.

Newsletters and Other Materials - We may offer Members the opportunity to subscribe to one or more newsletters and/or other e-mails which contain Clever Clubhouse activities. We may also send information and other materials to the home address of the Member who is responsible for the Primary Account from time to time.

Surveys - From time to time we may have Member surveys on Clever Clubhouse. For example, we may have a satisfaction survey where Members can provide us feedback on the registration process, the web site and other issues. Generally we do not collect any Personal Information in these surveys and results are analyzed on an aggregate basis only.

We may use Aggregate Information to improve and enhance your experience on the Clever Clubhouse web site. For example, we may use certain preferences you provide to tailor your experience at our site, such as showing you content and sending you notices concerning merchandise and services that may interest you. We may also share this Aggregate Information with other unaffiliated third parties, such as advertisers interested in advertising on the Clever Clubhouse web site, in an aggregate, anonymous form, which means that the shared information will not contain nor be linked to any personally identifiable information about you or any other person.

We may release account and other personal information when we believe release is appropriate to comply with law; enforce or apply our Membership Terms and Conditions; or protect the rights, property, or safety of Trilegiant, our users, or others. This includes exchanging information with law enforcement or other government officials and other companies and organizations as we, in our sole discretion, believe necessary or appropriate, in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose us or you to legal liability.

We will never share your credit card information with an unaffiliated third party without your consent.

Opt-Out Process

If you do not want us to share your Personal Information with unaffiliated third parties, you can send us an email at service@cleverclubhouse.com with the subject line "Privacy Policy." Please include your User Name and the words "block from third parties" in the email message. If you do not want us to share your Personal Information with our Trilegiant-related companies, you can send us an email at service@cleverclubhouse.com with the subject line "Privacy Policy." Please include your User Name and the words "block from Trilegiant-related companies" in the email message.

Cookies

"Cookies" are pieces of information that may be placed on your computer by a web site for the purpose of facilitating and enhancing your communication and interaction with that web site. Almost all web sites use cookies for these purposes.

We may use three different types of cookies: persistent cookies, session cookies, and third-party cookies. (Please refer to your browser's Help section for further information on controlling and setting cookies)

A persistent cookie remains on the your hard drive for authentication purposes. We use a persistent cookie to save your Username (only if you ask to remember my user name on this computer) so you don't have to re-enter it each time you visit our site. You may choose to reject persistent cookies and use your login password each time you visit, and the site will still function correctly.

A session cookie is temporary, only used during a single session on our web site, and is automatically deleted at the end of your visit. We use session cookies (a) to customize you and/or your child’s visit to the Clever Clubhouse web site and your membership experience, (b) to deliver content consistent with your stated interests and the manner in which you browse and/or use our site, and (c) for other purposes to make your visit more convenient. If you stop placement of session cookies, you will be unable to access any area of the web site including all children's content areas, and the Parent Control Center.

At times, some of our third party advertisers or their ad serving and tracking providers may place cookies on your computer system when you select their ad banner and some of our content providers or partners may also place cookies on your computer system when you visit those portions of our Clever Clubhouse site over which they have control. (These areas are located only in areas intended for adult use.) We have no control over these third party cookies and we do not receive the data collected by those cookies. In addition, we reserve the right to supplement the cookie data which we collect from you with information collected by cookies set by third parties on our behalf in order to understand how you use the Internet and what products are of interest to you. The information that we receive from these unaffiliated third parties is only Aggregate Information (i.e., anonymous, non-personally identifiable information).

You may stop or restrict the placement of cookies on your computer or flush them from your browser by adjusting your web browser preferences, but as noted above, you must accept session cookies in order for the site to function. If your browser does not differentiate between persistent and session cookies, then you must enable all cookies in order for the site to function. . We do not use cookies to retrieve information from your computer for purposes that are unrelated to the Clever Clubhouse web site or your interaction with the Clever Clubhouse web site.

Internet Protocol (IP) Address

We may use your IP address to help diagnose problems with our server and to administer our Web site. For our internal purposes, we gather date, time, browser type and IP address of all visitors to our site. We keep this information for system administration, for web server load balancing, to report aggregate information to our advertisers and for our internal security audit log. We do not link IP addresses to information that is personally identifiable. Your IP address may also be used to help identify you and/or your child for the duration of a session and to gather broad, aggregate demographic information. Your IP address will never be linked to any of your Personal Information unless you are in the process of making a purchase, in which case the link between this information will terminate upon your final purchase.

Clickstream

As you use the Internet, a trail of electronic information is left at each web site you visit. This information, which is sometimes referred to as "clickstream data," can be collected and stored by a web site server. Clickstream data can tell us the type of computer and browsing software you use, the address of the web site from which you linked to the Clever Clubhouse web site, and, in some instances, your e-mail address. We may use clickstream data as a form of Aggregate Information (see Information Usage section above) to anonymously determine how much time visitors spend on each page of our site, how visitors navigate throughout the site and how we may tailor our web pages to better meet the needs of visitors. This information will only be used to improve our web sites. Any collection or use of clickstream data will be anonymous and aggregate, and will not contain any Personal Information.

Consent to Processing

By providing any Personal Information to this site, you fully understand and unambiguously consent to the collection, usage and processing of such information in the United States.

Other Sites

Our sites or newsletters may contain links to other sites. Other sites may also reference or link to our sites. We are not responsible for the privacy practices, terms or the content of such other sites and we advise you to check their privacy policies and terms as well.

Security

The security of your Personal Information is very important to us. We attempt to provide for the secure transmission of your information from your PC to our servers by utilizing encryption software. However, due to the inherent open nature of the Internet, we can not guarantee that communications between you and Trilegiant, and Trilegiant and you, will be free from unauthorized access by third parties, such as hackers and your use of the Clever Clubhouse site demonstrates your assumption of this risk. Only those Trilegiant employees or Customer Service contractors who need access to your information in order to perform their duties are allowed access to your Personal Information. Any employee who violates our privacy and/or security policies may be subject to disciplinary action, including possible termination and civil and/or criminal prosecution.

Your Acceptance of this Policy

By using this site, you signify your assent to our Privacy Policy. If you do not agree with the terms of this policy, please do not use our Clever Clubhouse site. We reserve the right, at our discretion, to change, modify, add, or remove portions from this policy at any time. Your continued use of our site following the posting of changes to these terms means you accept these changes, and any consent provided under COPPA will be deemed to apply to the revised policies and new or modified features. However, in the event there is a material change in our data collection, use or disclosure practices, we will obtain a new consent.

4-24-2002