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Privacy Policy
  Your privacy is important, so Cafe.com, SA ("Cafe.com") has created the following policy ("Privacy Policy" or "Policy") to inform you about the type of information we gather about you when you visit our website located at http://www.Cafe.com/ (the "Site") and use our services, and how we may use that information and if and when we disclose it to third parties.

This Privacy Policy explains Cafe.com's data collection and use practices generally and in connection with advertising and content and any related services offered on the Site (collectively, the "Services"). The Policy applies to the Site and to any other online or offline Cafe.com websites, including websites owned and controlled by Cafe.com.

The terms "you," "your," and "yours" refer to the visitor, customer and/or purchaser utilizing our Site. The terms “Cafe.com”, "Cafe", "we," "us," and "our" refer to Cafe.com and its subsidiaries and affiliates. This Privacy Policy is governed by our Terms of Use located at http://www.Cafe.com/BottomLinks/TOU.aspx. Please read these documents prior to using our Site and/or any of the Services we offer. By using this Site and/or our Services, you consent to the data practices prescribed in this Policy. We may make changes to this Privacy Policy by posting an updated version on this page. It is your responsibility to review this Privacy Policy frequently and remain informed about any changes to it, so we encourage you to visit this page often.

WHAT INFORMATION IS COLLECTED?

Personal Information
"Personally Identifiable Information" is any information that may be used to identify an individual, including, but not limited to, a first and last name, home or other physical address, an e-mail address, phone number or other contact information, whether at work or at home. Cafe.com may request Personally Identifiable Information from you when you register to use our Site and Services and at various other locations on our Site, such as in online stores, message boards, personal pages, blogs and surveys. If you do not want your Personally Identifiable Information collected, please do not submit it to us. In certain areas, you may choose to allow other Cafe.com users to see the registration information you provide. In such cases, we will notify you during the registration process and allow you to determine the information you wish to be displayed. When you do provide us with Personally Identifiable Information, we may use that information to better understand your needs and how we can improve our products and Services (as described in more detail below).If we ever send you information by e-mail concerning new products or Services that you did not expressly request, we will provide you with the opportunity to opt-out of receiving future notices.

Non-Personal Information
Non-personally identifiable information ("Non-Personal Information") is information that, by itself, cannot be used to identify or contact you. Examples of this type of information include the type of Internet browser or computer operating system you use, demographic information (your age, gender, income, education, profession, zip code, etc.), the date and time you visited our Site, the pages you accessed, the name of the website from which you linked to our Site and other anonymous data involving your use of our Site. We use this information to analyze trends and gather broad demographic information for aggregate use. For example, we collect information regarding your hardware configuration, including but not limited to OS version, type of coding for video, processor, memory size, explorer version, video card type and sound card type, so that we can confirm that the videogames are being installed in accordance with our End User License Agreement accessible at http://www.Cafe.com/BottomLinks/EULA.aspx and to communicate you about updates or changes in policies and changes to our Services. This information is not linked to any Personally Identifiable Information.

HOW IS SUCH INFORMATION USED?

We gather the information discussed above for purposes of providing and improving our Services. Personally Identifiable Information is used in order to register you as a user of the Site and Services, to set up your payment for the Services and to give us a sense of who our customers are and what are customers are looking for from our Site, Services and products. In addition, we may use your Personally Identifiable Information to keep you up to date on the latest product announcements, news, special offers, to notify the winners of contests and sweepstakes we may offer, to keep track of scores on game leaderboards and for communicating other information we think you would like to hear about. We may also use that information to contact you, for example, as part of an optional questionnaire in order to help us better understand the needs and preferences of our customers (e.g., videogame use, videogame preferences and videogame purchasing practices). In the event we receive a copyright and/or trademark infringement notice or other notice of any legal claim relating to content provided by you, we may share your contact information with the parties involved in the applicable dispute. We may also share your e-mail address with third party e-mail carriers who assist us with sending e-mails to our customers. Subsidiaries and controlled affiliates are not viewed as third parties for the purpose of data transfers, and hence personal information may be shared within those subsidiaries and affiliates without obtaining additional consent.We keep track of Non-Personal Information such as the type and number of videogames you download and play to help us track sales, downloads, etc. and may use such information, as well as aggregate data regarding your age, gender, occupation, education level, geographic location, computer equipment data and online and videogame interests, activities and practices, to provide general audience preference information to game publishers as part of our effort to provide you with the best possible products and Services. Cafe.com also automatically receives and records information on our server logs from your browser, including your IP address, cookie information and the page you request. You can choose not to provide us with certain information, but then you might not be able to take advantage of many of our features.

Online Store
If you make a purchase on our Site, we may collect information related to your purchase, such as payment type and billing address. This information may be shared with third parties, such as third party financial institutions and their vendors, who provide payment services. We may also use the information you provide to send you important announcements and updates regarding our Site, products, Services and any other information that we think may be of interest to you. However, you may opt-out from receiving future mailings by contacting us at opt_out@Cafe.com [Please note that this e-mail address is not intended for and will not respond to customer inquiries; rather, customer inquiries should made on our contact page located at http://www.Cafe.com/BottomLinks/Help/HelpContact.aspx or:
Cafe.com, SA
75 rue des plantes
75014 Paris
France
Attn: Thibault Viort


IS THE INFORMATION SHARED OR DISCLOSED?

Safeguarding your information is important to us, and we are not in the business of selling that information to others. Cafe.com shares your Personally Identifiable Information and Non-Personal Information only as described in this Policy. Cafe.com reserves the right to share some of the information you provide with third parties. For example, from time to time, Cafe.com may disclose the information it collects to third parties it hires to assist it in serving you (e.g., fulfilling orders, sending postal mail and e-mail, removing repetitive information from customer lists, analyzing data, providing marketing assistance, providing search results and links (including paid listings and links), processing credit card payments, providing customer service).Though we make every effort to preserve your privacy, Cafe.com may disclose Personally Identifiable Information if required to do so by law or in the good faith belief that such action is necessary to:
(1) conform to the edicts of the law or comply with a current judicial proceeding, court order or legal process;
(2) protect and defend the rights or property of Cafe.com; or
(3) protect the personal safety of users of Cafe.com, its websites or the public.
In the event Cafe.com should ever file for bankruptcy, merge with another company or have all or substantially all of its assets acquired by a third party, we may sell or otherwise transfer the information you provide to us on this Site to a successor in interest or other third party or share your Personally Identifiable Information with any company with whom we merge as part of the transaction. If we sell our business, we will attempt to ensure that requests made of us regarding e-mail communications will be honored.


ACCESS AND CHOICE.

You may update, correct, or amend your personal information by sending a registered letter to the web-publishing company at the address listed below or by sending an e-mail to rq_info @Cafe.com. Please note that this e-mail address is not intended for and will not respond to customer inquiries; rather, customer inquiries should made on our contact page located at http://www.Cafe.com/Help/HelpContact.php. Please be aware that this Privacy Policy and the choices you make on this Site will not necessarily apply to Personally Identifiable Information you may have provided to Cafe.com in the context of other, separately operated, Cafe.com products or Services. When contacting Cafe.com to change your information, please make sure to specify whether you would like to change your information for all Cafe.com products and Services, or only the information that you supplied when registering to use this Site.

THE SECURITY OF YOUR INFORMATION.

Cafe.com protects the security of your payment and financial information during transmission by using Secure Sockets Layer (SSL) software which encrypts the information you enter. In addition, access to customer data is restricted to Cafe.com employees with permission to access customer data for business and customer support purposes. Your e-mail address may be shared with third party e-mail carriers who assist us in sending e-mails from Cafe.com to our customers. To protect against credit card fraud, Cafe.com does not maintain credit card numbers on its system. Despite these practices, no security measures are completely fail-safe or impervious to circumvention. Your communications with us will travel through third party networks and we assume no responsibility for the security of such networks. Further, we are not responsible for events beyond our control, including without limitation, failure of security measures, the malicious acts or willful misconduct of hackers or any other person.

INTERNATIONAL TRANSFERS.

Cafe.com abides by the safe harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of data from the European Union.

COPPA COMPLIANCE.

Cafe.com complies with the Children's Online Privacy Protection Act of 1998 ("COPPA"). COPPA protects the personal information of children under the age of 13. This applies to individually identifiable information about a child that is collected online, such as full name, home address, e-mail address, telephone number or any other information that would allow someone to identify or contact the child. COPPA also covers other types of information—for example, hobbies, interests and information collected through cookies or other types of tracking mechanisms—when they are tied to individually identifiable information. It is important for you to understand this law; we encourage you to read more about COPPA.

Note to Parents:
Cafe.com is committed to providing a safe, secure, and fun online experience for children who visit our Site. We are dedicated to safeguarding any personal information collected online and ensuring that COPPA rules are being followed in conjunction with all other activities conducted on our Site, helping parents and children have a positive experience on the Internet. Children can use the Site and view content without any Personally Identifiable Information being collected. However, in some areas of the Site, it is necessary to collect Personally Identifiable Information from children so that they can participate in an activity or download a videogame. Consistent with COPPA, we do not knowingly request or accept Personally Identifiable Information from children under the age of 13 without prior verifiable parental consent. In addition, Cafe.com will not condition a child's participation in an activity on the child providing more information than is reasonably necessary for the activity. A printable consent form is built into the registration process to help us secure parental consent and can also be obtained here. Parents will always have access to all personal information we have about their children. If your child has registered using a false age, please notify us and we will immediately close the account and nullify all Personally Identifiable Information collected from the child. Parents can revoke their consent and ask that information about their children be deleted from the Site by contacting us at parents@Cafe.com explaining that you want to deactivate your child's account. Parents may obtain any Personally Identifiable Information collected from their child by sending an e-mail to parents@Cafe.com requesting the Personally Identifiable Information. Cafe.com will obtain verifiable parental consent for the collection, use or disclosure of Personally Identifiable Information from a child.

COOKIES.

Cookies are small text files stored by your browser in your computer when you visit our Site. Cookies do not store personal information about you, unless you knowingly provide it. Cookies can store Non-Personal Information, such as what websites, pages, or advertisements your browser has accessed. We use cookies to improve our Site and make it easier to use. Cookies permit us to recognize you when you return to our Site and avoid repetitive requests for the same information—saving you time and enhancing your experience. We mostly use "session cookies" that are automatically deleted several months after a visit to our Site. Cookies from our Site cannot be read by other websites as they tie automatically to Cafe.com's domain name. You have control over cookies. Most Internet browsers can be set to refuse to accept cookies, although this may affect your Internet experience. You can also erase cookies that are already on your computer, block all cookies or receive a warning before a cookie is stored. Please refer to your browser instructions or "help" screen to learn more about these functions.Please note that other companies that place advertising on our Site may collect information about you through the use of cookies when you view or click on their advertising or content. Due to the way the Internet technically operates, we cannot control, and make no representations about, the collection or use of this information by such third parties.

CONTACTING Cafe.com.

If you have any questions or suggestions regarding our Privacy Policy or if you have submitted information through our Site and would like access to such information or to have that information corrected, please contact us by e-mail at privacy@Cafe.com or by postal mail at:

Cafe.com, SA
75 Rue des Plantes
75014 Paris
France

and we will respond to you promptly.

Amended as of January 1st, 2008. V1.0


 
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