NeoCW.com is committed to providing a fun, entertaining, and safe Web site for people of all ages. We are dedicated to safeguarding any personal information collected on-line and to helping parents and children learn how to exercise control over personal information while exploring the Internet. To this end, we ensure that our privacy policy and our information practices adhere to the U.S. Department of Commerce's Safe Harbor Principles. Because many of the visitors to this site are children, we take care that our content is suitable for children. In addition, we take special measures to help children protect their privacy while on-line. For example, we do not ask children to disclose more personal information than is necessary for them to participate in a particular activity, and we take efforts to prevent children from posting contact information.

To help ensure a rewarding on-line experience for our visitors - and for the parents of our visitors who are children - we provide you with this summary of our information practices.

As we continue to offer our visitors new and different types of content and services, we may modify our practices from time to time. However, we will treat all personal information we collect in accordance with the privacy notice in effect at the time the information is collected.

I. The Information We Collect

At NeoCW.com, the only personally identifiable information we collect from users 12 years old and younger is a valid e-mail address. And, we ONLY use this information to send these users one message to activate their NeoCW.com account, and then the e-mail address is completely removed from our system. We also ask users 12 years old and under for certain non-personally identifiable information, such as birth date, gender, state/province, zip/postal code, and country.

Users can also change their user information supplied upon registration (except for user name, original e-mail address and date of birth) on this page: http://www.NeoCW.com/account.php and following the direction on such page. When a child under 13 enters a contest, we will ask for a parent's e-mail address so that we can notify the parent that we have received personal information from the child. We do not knowingly collect names and e-mail addresses from children under 13 without notifying the parent via e-mail and giving them the opportunity to remove their child's name from the list of entries. Winners of our contests or sweepstakes are notified by e-mail, and are required to send us by fax or regular mail a form containing their street address. Winners who are minors must have the form signed by a parent in order to receive their prizes.

Additionally, when visitors come to our site, we automatically collect some non-personally identifiable "computer" information, such as the type of computer operating system (e.g., Windows 95 or Mac OS), the user's "IP Address", the web browser (e.g., Netscape, Internet Explorer) being used, and information regarding the Internet service provider.

II. How We Use the Information

We use visitors' personal information for our internal purposes of enabling visitors to enter one of our on-line contests or sweepstakes, to subscribe to our online newsletter, or to inform users of upcoming events and special announcements. We use the e-mail addresses of parents to notify them when we have received information from their children and to give them the opportunity to have their child's name removed from our lists. We do not keep any personal information we obtain through a contest or sweepstakes after the particular event is completed. We use the names and e-mail addresses of subscribers to our e-mail newsletter only to send them the newsletter. Each newsletter contains instructions on how to be removed from the subscription list by sending us a return e-mail. We also use visitor's personal information to track usage and to ensure user are following the site's Terms and Conditions. Sometimes we will use agents or contractors to help us provide services to our visitors, such as helping us conduct a sweepstakes and sending prizes to the winners. In these cases, we require the agent or contractor to keep the information confidential and to use it only for the specific services they are performing. In addition, please review the section on Collection of Information by Third-Party Sites and Sponsors for a description of the limited instance whereby personal information collected on the site may be supplied to third parties with the consent of the user.

We sometimes use the non-personally identifiable information that we collect to improve the design and content of our site, to personalize our visitors' experience on NeoCW.com, and to offer products, programs, and services. We also may use this information in the aggregate to analyze site usage, as well as to offer products, programs, or services.

We will disclose information we maintain when required to do so by law, for example, in response to a court order or a subpoena. We also may disclose such information in response to a law enforcement agency's or other public agency's (including schools or children services) request or if we feel that such disclosure may prevent the instigation of a crime.

We will not use or transfer personally identifiable information in ways that are materially different from the ones described above without also providing parental notification of such practices and obtaining consent for any materially different uses.

III. Collection of Information by Third-Party Sites and Sponsors

Our site contains links to other sites, including those of sponsors, advertisers and survey companies, whose information practices may be different from ours. Sometimes the other sites might conduct contests or sweepstakes that are promoted on NeoCW.com. Visitors should consult the other sites' privacy notices, since those sites are not covered by our privacy policy and may follow procedures that are different from ours. NeoCW.com never gives a user's e-mail address or other registration information to such third parties without permission, however, if you choose to "opt-in" (click on a box to receive a third party's information), to register with one of our sponsors, or not to "opt-out" (uncheck a checked box that will provide a sponsor with your information), that means you have allowed NeoCW.com to give your registration information and other collecting information, including e-mail address, to that third party.

IV. Cookies

NeoCW.com uses a software technology called "cookies." Cookies are small text files that we and certain third parties place in visitors' computer browsers to store their preferences. Cookies themselves do not contain any personally identifiable information. Although cookies could enable us to relate a visitor's use of this Web site to personal information that a visitor has provided, such as an e-mail address, we do not use them for this purpose. We do use "cookies" to determine how many visitors we have and how often they visit various sections of our site.

We employ P3P codes and so-called P3P privacy policies only as technical switches to enable our web site to function properly. Some Web browsers require those codes in order to trigger the function of certain cookies. However, our use of P3P is completely unrelated to any privacy or data policies that we may be bound to and the DSA token in our compact P3P privacy policy means that the P3P codes and so-called P3P privacy policies we publish have no meaning and carry no obligations or liability. We disavow any significance to those codes and policies and reject all aspects of the P3P protocol.

We have put in place appropriate physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect on-line.

VI. Parental Review of Information

• access the personally identifiable information that the NeoCW.com site has collected on-line from your child,
• correct factual errors in such information,
• request to have this information deleted, or
• request that we no longer collect or maintain such information.

Please be sure to include your e-mail address and a telephone number where we can reach you. To protect your child's privacy and security, we will take reasonable steps to help verify your identity before granting you access to the personal information that we collect and maintain about your child.

VII. Contact Us

If you have any questions, comments, or concerns regarding our privacy policy and/or practices, please contact us at the following e-mail address:

admin@NeoCW.com

If you are unable to resolve your concerns with our Privacy Manager, we encourage you to contact The Direct Marketing Association at www.the-dma.org.

VIII. A Final Note to Parents

The Internet offers a world of opportunity for children. Your guidance and involvement are essential to help ensure that children have a safe and rewarding on-line experience. We encourage you to visit The Direct Marketing Association's Web site(www.the-dma.org) and explore the Get CyberSavvy! program. Get CyberSavvy! helps families learn how information flows on-line so they can use the Internet in ways that protect their privacy and well-being. It also contains a number of valuable resources to help parents and children be aware of and express their preferences about information that is collected on-line and how it is used. Your efforts to instill responsible information practices will help steer your children to age-appropriate sites and will go a long way toward ensuring that your children have enriching experiences on-line.

IX. Effective Date

The privacy policy set out above is effective as of January 1, 2005, and applies to all information previously obtained by NeoCW.com. NeoCW.com reserves the right to change its privacy policy at its sole discretion. NeoCW.com' users will be informed of any such change by NeoCW.com posting a new privacy policy on the NeoCW.com website. The effective date of any change of privacy policy will be clearly marked.