SIMPLI SHOPPING PRIVACY POLICY

EFFECTIVE DATE: October 20, 2008

At Simpli Shopping.com ("Simpli Shopping.com”,"we", "us", “our” "Site"), we respect your privacy and want to ensure that each and every user and member feels comfortable in sharing their data. We take your privacy and our responsibility under the privacy laws very seriously.

Please read this privacy policy carefully since by visiting the Site and sharing information with us you agree to be bound by the terms and conditions of this Privacy Policy. Simpli Shopping.com is owned by ValueClick, Inc. For more information about ValueClick, Inc. or any of its subsidiaries or affiliates, please visit www.valueclick.com

CALIFORNIA RESIDENTS: YOUR PRIVACY RIGHTS

Effective January 1, 2005, companies that collect personally identifiable information (data collected with an intention to identify and contact a person such as name, address, telephone number or e-mail address) ("PII") from California residents and disclose such information to third parties (including affiliated entities) for marketing purposes must, in response to a request by a consumer, either (1) provide a list detailing the categories of information shared and the entities to which such information was provided or (2) provide a mechanism by which a consumer may opt-out of having their information shared with third parties. We have elected the second option and you may request that your PII not be shared with third parties by sending your request, including your full name, email address and postal address to Simpli Shopping, Attn: SB 27 Officer, 30699 Russell Ranch Road, Suite 250,, Westlake Village, CA 91362 or email us with such request with your full name and email address at privacy@search123.com.

I. INFORMATION WE COLLECT

A. Personally Identifiable Information (PII).

Simpli Shopping does not automatically collect any PII about you. We do collect PII through membership registration, newsletter sign-up requests or promotional contests (if applicable). Please note that it is not necessary for you to become a member in order to use many of the features on Simpli Shopping. A non-member can easily see products and prices, perform searches, read reviews and take advantage of many other useful features on the Site.

The reason that we ask for this PII are for reasons that include, as an example, providing you with information that you may request, customizing your experience on the Site, and contacting you when necessary in connection with any promotions you participate in.

We also may use this information for internal business purposes, which may include aggregating the data to help us to create a profile of Simpli Shopping visitors - as a whole - so that we can for purposes which include: a) build a better understanding of our users and enhance the services we offer, and b) attract advertisers to spend money on Simpli Shopping, thus enabling our free price comparison service to operate.

Unless you tell us not to, we may use your PII to contact you about offers or promotions from Simpli Shopping and selected third parties we think you would be interested in.

B. Non-Personally Identifiable Information (PII).

Simpli Shopping uses Cookies, log files and web beacons to collect non-personally identifiable information, such as IP address, browser types, operating systems, domain names, access dates and times, referring website addresses, online transactions and browsing and search activity (“Non-PII”).

“Log files” track actions occurring on our Site and collect data including your IP address, browser type, Internet service provider, referring/exit pages, platform type, date/time stamp, click data and types of advertisements viewed.

"Web beacons" are electronic files used to track your navigation of a website or collection of sites, the completion of transactions, submittal of applications and browsing behavior.

"Cookies" are files (e.g. flash browser objects) that are stored on your Internet enabled device (which includes your computer, BlackBerry or other PDA). Cookies are used to improve the experience web users have when they see web advertisements and ensure that when a web user clicks on an advertisement, they are sent to the correct click-through destination. We may use Cookies to help us serve ads, take polls and better manage the services we offer. Cookies collect Non-PII and do not collect any PII about you. Cookies, Log files and Web beacons cannot be used to obtain PII from your hard drive.

There are two classes of Cookies based on how long they remain on your system: (i) “Session Cookies” are used only during your visit to the Site and are erased once you close your browser, and (ii) “Persistent Cookies” remain on your browser for 1 year from your last visit to the Site and enable us to remember you on subsequent visits to the Site and provide more relevant content to you on such Site.

There are many misconceptions about Cookies, some of which we will try to address in this policy. Cookies cannot erase your hard drive or otherwise damage your computer and do not tell us an e-mail address or any other PII. Simpli Shopping.com does not and cannot use Cookies or web beacons to retrieve PII from your computer.

A useful resource on understanding Cookies may be found at http://www.allaboutcookies.org.

II. INFORMATION SHARING

Simpli Shopping may use third party vendors to help us operate our business and this Site or administer activities on our behalf. We may share your information, PII and/or Non-PII, with these third parties for those limited purposes. Any third-party vendor so used has agreed to protect the confidentiality of information provided by Simpli Shopping.

Simpli Shopping and/or our marketing partners may enhance and/or merge PII with commercially-available third party data collected from other sources in an effort to ensure that the messages being sent to the consumer in online and/or offline marketing programs are relevant to their interests.

Simpli Shopping may share Non-PII and PII (including information that has been enhanced with information from other sources) with co-branded partners, advertisers, third party marketers, our affiliated entities for their online and/or offline marketing programs or in connection with the sale, merger, consolidation, change in control, transfer of substantial asset, reorganization or liquidation of any Simpli Shopping division. Such entities may merge the Non-PII that we share with such entities with any PII you may choose to give in registering and transacting with such entities’ websites.

Please note that while Simpli Shopping encourages merchants and marketing partners to adopt responsible approaches to online marketing, we are not responsible for the information practices of our merchants or marketing partners. The collection, use, and disclosure of information by such third parties is subject to their respective privacy policies, which may differ from this policy. Please be sure to review their policy prior to providing any information.

Simpli Shopping may release account and any other PII when we believe release is appropriate to respond to a subpoena or otherwise comply with the law; enforce or apply our Terms and Conditions and other agreements; or protect the rights, property, or safety of Simpli Shopping or others. This includes exchanging information with other companies and organizations for fraud protection.

III. CONSUMER CHOICE AND ACCESS

If at anytime you no longer wish to receive e-mail offers from a Simpli Shopping, you may "unsubscribe" by sending an email with your full name and email address to privacy@search123.com or by using the unsubscribe option within any promotional offer. In compliance with the CAN-SPAM Act, you will be removed from our email list and will no longer receive offers from us. If you have registered or submitted PII under more than one email account, you must submit separate unsubscribe requests in the manner set forth in this paragraph from each account.

The Cookies we use do not have an "opt-out" option, yet you still have the option of blocking the use of cookies by changing a setting in your Internet browser. To adjust these settings, we suggest that you contact the supplier of you browser and browser add-ons for more information.

IV. SECURITY

Simpli Shopping employs reasonable security measures to ensure the security of all data it collects.

No transmission of data over the Internet is guaranteed to be completely secure. It may be possible for third parties not under the control of Simpli Shopping to intercept or access transmissions or private communications unlawfully. While we strive to protect your PII, Simpli Shopping cannot ensure or warrant the security of any information, including PII, you transmit to us. You acknowledge and assume this risk when communicating with us.

V. CONSENT AND CHANGES

Simpli Shopping may find it necessary or be legally obligated to update this Privacy Policy from time to time. When we do, we will post those changes on this page and update the effective date so that you are always aware of the information we collect, how we use it, and under what circumstances we disclose it.

VI. CHILDREN'S PRIVACY AND SPAM

Simpli Shopping is very sensitive to the issue of children's privacy and makes an effort to protect the privacy of children using the Internet. Our Site and membership services are not developed for or directed at children under the age of 13. If you believe your child has provided Simpli Shopping with any PII by registering at a Simpli Shopping web site, please contact us with such details at privacy@search123.com to have them removed.

Simpli Shopping is committed to proper Internet practices and full compliance with the CAN-SPAM Act of 2003 (15 U.S.C. § 7701). It is our policy to prohibit the sending of unsolicited or "Spam" email by Simpli Shopping or any of its marketing partners.

Please note that under the CAN-SPAM Act, an advertiser is required to provide an opt-out mechanism for consumers to unsubscribe from future emails about the advertiser. Although not required to by law, many email marketers also include an opt-out mechanism to enable consumers to be removed from their mailing list. This has caused some confusion for consumers in opting out. The table below clarifies which opt-out mechanism you should use.

To receive no further emails . . .	Opt-Out Mechanism to Use
about the advertiser	Advertiser's
from the email marketing company	Marketer's
from the advertiser or email marketing company	Both

VII. DATA PROCESSING

You acknowledge that Simpli Shopping operates in the United State and the European Union and agree to (i) permit Simpli Shopping to transmit and use your information anywhere necessary, including across international boundaries, to affect the services and transactions provided by this Site; and (ii) that such use by Simpli Shopping shall be subject to the terms and conditions stated in this Privacy Policy and our Terms and Conditions.

VIII. LIMITATION OF LIABILITY, THIRD PARTY INFORMATION & LANGUAGE

YOU UNDERSTAND AND AGREE THAT ANY DISPUTE OVER PRIVACY IS SUBJECT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND OUR TERMS AND CONDITIONS (INCLUDING LIMITATIONS ON DAMAGES, AND ARBITRATION OF DISPUTES). YOU AGREE THAT SIMPLI SHOPPING'S LIABILITY FOR ANY BREACH OF THIS PRIVACY POLICY SHALL BE LIMITED TO THE VALUE OF THE TRANSACTIONS OR SERVICES PROVIDED TO YOU BY SIMPLI SHOPPING TO THE EXTENT SUCH CLAIM IS NOT OTHERWISE BARRED BY OUR TERMS AND CONDITIONS.

You also agree that you have provided notice to, and obtained consent from, any third party individuals whose personal data you supply to SIMPLI SHOPPING with regard to: (a) the purposes for which such third party's data has been collected; (b) the intended recipients or categories of recipients of the third party's personal data; (c) which of the third party's data are obligatory and which data, if any, are voluntary; and (d) how the third party can access and, if necessary, rectify the data held about them. It is the express will of the parties that this agreement and all related documents have been drawn up in English. C'est la volonté expresse des parties que la présente convention ainsi que les documents qui s'y rattachent soient rédigés en anglais.

CONTACT US

For more information or if you have questions or concerns regarding the Simpli Shopping Privacy Policy, please send an email to privacy@search123.com, or you can send correspondence to the following address: Simpli Shopping, Attn: Privacy Officer, 30699 Russell Ranch Road, Suite 250, Westlake Village, CA 91362.