Updated as of 21st December, 2009

Search 123 : Display Web User Policy

Welcome to Search123.com, a division of ValueClick Europe Ltd. (hereinafter "Search123, ?we? or ?us?).

At Search123, privacy is a top priority and we provide this Privacy Policy to outline our practices and procedures with respect to information collection and use to enable you to make an informed decision about sharing information with us. Search123 is a Publisher and Advertiser network which means we may deliver advertisements to the websites you visit.

Please note that this Privacy Policy applies solely to Search123. All other ValueClick Inc. entities are governed by separate privacy policies found on such entities? websites.

INTRODUCTION

Acceptance of Terms

Please read this policy carefully since by visiting this website (?Website?) and/or sharing information with us, you agree to be bound by this Privacy Policy. The Privacy Policy may be revised or updated at any time by us. This page was last updated as of the date at the top of this Privacy Policy.

Summary

We have included a table summarizing our practices solely for your convenience and reference purposes. This table, however, is not an exhaustive description of our privacy practices and should not be construed to define, limit, or describe the scope or extent of our Privacy Policy. As a result, we urge you to read the entire document.

Information Not Collected - PII

We do not 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) (hereinafter ?PII?).

Information Collected ? non PII

The non-personally identifiable information we collect may include as an example, IP address, browser types, operating systems, domain names, access dates and times, referring website addresses, online transactions and browsing and search activity.

How Used

We may use your Non-PII (?Information?) for the following general purposes: enhancement of our services, marketing, and to more effectively match advertisements and website content to your interests.

Sharing your Information

We may share your Information with third party service providers we have contracted with, ValueClick Inc. and its subsidiaries and affiliates, including third party marketing partners, business partners and our clients.

Your choices

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. Please see your browser supplier's website for details on how to do this.

Security

We use reasonable and appropriate security measures to protect your data.

Changes

We may change the Privacy Policy at any time by posting the revised Privacy Policy on the Website and if such changes are material, a notice of the changes will also be posted along with the revised Privacy Policy.

Contact Us

If you have any questions about this Privacy Policy, the practices of or your dealings with us relating to this Privacy Policy, please email us at or you can send correspondence to us at the following address: Jayne Taberner, Country Manager, Search 123, 182 Upper Richmond Road, Putney, London, SW15 2 SH, United Kingdom.

INFORMATION WE COLLECT

Non-Personally Identifiable Information

As part of our on-going efforts to ensure the best possible experience for all recipients we may use log files, web beacons and cookies to collect data from browsers, advertiser and third party sites (?Sites?) to aggregate Information. The Information collected is used for marketing purposes, enables us to determine which advertisements perform well, allows us to more effectively match advertisements and website content to your interests, assists us in improving the operation of our services, helps us to maintain the quality of our services, enhances our services to our business partners and clients and enables us to provide general statistics to our business partners and clients regarding use of Search 123services.

?Log files? track actions occurring on Sites 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.

?Image requests? or ?web beacons? can transmit information used to track your data, which may include the navigation of a website or collection of sites, the completion of transactions, submittal of applications and browsing behaviour. This information is written to cookies.

"Cookies" are files (e.g. HTTP cookies) 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 estimate the total reach of an advertising campaign, as well as frequency of display. This allows advertisers to determine with greater accuracy the composition of the audience they reach. Cookies are also used to control the delivery of a series of advertisements to a web browser, and to limit the number of times a web browser receives any one advertisement.

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 Sites and are erased once you close your browser, and (ii) ?Persistent Cookies? remain on your browser for 2 years from your last visit to the Sites and enable us to remember you on subsequent visits to the Sites and provide more relevant content to you on such Sites.

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. Search 123 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.

SHARING YOUR INFORMATION

Information Shared by Search123

Search123 will only share your Information for the limited purposes provided for in this Privacy Policy. This includes sharing Information (1) to enable third party service providers to assist or facilitate in the services we provide to our clients; (2) to comply with applicable laws and regulations or to respond to a subpoena, search warrant or other lawful request for information received by Us, whether or not a response is required by applicable law; (3) to enforce our terms of use or to protect our rights ; (4) to protect the safety of members of the public and users of the service; (5) with other ValueClick Entities and third party marketing partners (including advertisers and publishers) for marketing purposes; (6) with vendors, administrative service providers, technology providers, and carefully selected partners for data validation, enhancement, information verification and suppression services or (7) for any other purpose for which you provide consent. While Search123 strongly encourages clients and partners to adopt responsible approaches to online marketing, Search123 is not responsible for the information practices of such clients and partners. The collection, use, and disclosure of information by clients and partners are subject to their respective privacy policies, which may differ from this Privacy Policy.

In the event that Search123 is acquired by or merged with a third party entity, we reserve the right, in any of these circumstances, to transfer or assign the information we have collected from you as part of such merger, acquisition, sale, or other change of control. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, we may not be able to control how your Information is treated, transferred, or used.

Information Collected by Third Party Sites.

Please be aware that the websites of our advertiser clients as well as the websites on which we place advertisements or any third party websites linked to one of our sites also may collect information from you. Such information may include non-personally identifiable information through the use of Cookies and other technology and any personally identifiable information you may choose to give in registering and transacting with such website. Although we choose our business partners and clients carefully, Search123 is not responsible for the privacy practices of websites operated by such third parties. You should check the applicable privacy policies of such websites you visit to determine how they handle any information they collect from you.

YOUR CHOICES

PROCESSING AND STORING YOUR DATA

Data Processing

The European Union ("EU") maintains strict privacy laws. These rules differ significantly from the laws of the United States of America (?US?). To reconcile these differences, the US and the EU have created a safe harbor (?Safe Harbor?) that defines mutually acceptable privacy operations. For more information see www.export.gov/safeharbor.

By providing information to us, you acknowledge that we operate in the US and you agree to (i) permit us to transmit and use your user Information anywhere necessary, including across international boundaries, to better improve the services and transactions provided by Search123; and (ii) that such use by us shall be subject to the terms and conditions stated in this Privacy Policy and the Terms of Use.

Security.

Search123 employs appropriate measures to ensure the security of all Information and we routinely evaluate our practices to identify security threats or opportunities for the improvement of our services. No transmission of information is guaranteed to be completely secure. Unauthorised entry or use, hardware or software failure, and other factors may compromise data security. You acknowledge and agree to assume this risk when communicating with us.

CHANGES

As the standards governing Internet privacy continue to evolve, Search123 may find it appropriate or necessary to update this Privacy Policy from time to time. As a result, we reserve the right to change this privacy policy at any time and shall post such changes on the Website. Our Website will state the date the Privacy Policy was last updated. We encourage you to review the Privacy Policy whenever you use this Website to make sure you understand how your information will be used. If we materially change how we use your Information, we will notify via a prominent notice on the Website prior to implementing the change.

MISCELLANEOUS

Children?s Privacy.

Search123 is very sensitive to the issue of the privacy rights or children. Search123 Websites and services generally are neither developed for, nor directed at, children. We never collect or maintain information on our website from those we actually know are under 13, and no part of our website is structured to attract anyone under 13 years of age.

Your Representations.

YOU UNDERSTAND AND AGREE THAT ANY DISPUTE OVER PRIVACY IS SUBJECT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND APPLICABLE SITE TERMS AND CONDITIONS. You also agree that you have provided notice to, and obtained consent from, any third party individuals whose Information you supply to us with regard to: (a) the purposes for which such third party's Information has been collected; (b) the intended recipients or categories of recipients of the third party's Information; (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 wish of the parties that the Privacy Policy and all related documents have been drawn up in the English language and that the English version of this Privacy Policy shall be the sole version used in interpreting and enforcing this Privacy Policy.

Search123 : Display Member Privacy Policy

This privacy statement discloses the privacy practices for Search123.

Our mission is to build users' trust and confidence in the Internet by promoting the use of fair information practices. Because this website wants to demonstrate its commitment to your privacy, it has agreed to disclose its information practices.

This website has agreed to notify you of:

What personally identifiable information of yours is collected from you through the website
The organization collecting the information
How the information is used
With whom the information may be shared
What choices are available to you regarding collection, use and distribution of the information
The kind of security procedures that are in place to protect the loss, misuse or alteration of information under Search 123?s control
How you can correct any inaccuracies in the information.

If you have questions or concerns regarding this statement, you should contact Search123 by email to . If you do not receive acknowledgment of your inquiry or your inquiry has not been satisfactorily addressed, you should then contact Search123by email to . If you are not a member of Search123 (an advertiser or web publisher who has registered with Search123to do business with Search123 please see our display web user privacy policy.

Information Collection and Use

As a ValueClick Company, Search123 is the sole owner of the information collected on this site. Information collected is in two distinct categories: Member information and aggregated Web User information. This portion of Search123?s privacy statement applies only to Members of Search123. For web user privacy issues regarding the serving of advertisements and the use of cookies, please see the Web User Privacy Statement.

Members of the Search123Network include publishers and advertisers involved in advertising campaign transactions. Member information collected includes personally identifiable information that is necessary to conduct business, such as name, phone number, and email address. Payments made to and from Search123 require the collection of personally identifiable information that may include credit card numbers and bank account information. Phone numbers may be used to contact Members for sales or inventory acquisition purposes. All Member information is collected, modified and stored in a password protected environment. This information is used for service, contact, billing and accounts payable purposes. We will not sell, share, or rent this information to non-ValueClick entities. All Member information collection is explicit, voluntary, manually entered by the Member, and can be opted-out.

Cookies are used to simplify Member login and to facilitate secure navigation through the password protected areas of the website. Members who choose to reject all cookies may have difficulty navigating the password protected areas of the website depending on the nature of their connection (dynamic IP, proxy server, etc.).

Information Sharing.

Member information is not shared with any third party outside Search123 and its affiliated companies within ValueClick, except for that necessary to conduct business, such as supplemental feed partners. The security of Member information is crucial to our success in the highly competitive field of online advertising.

Log Files

We record the IP address of new Members at sign-up. This can assist in administering the website and Member accounts, designed to enhance the Member experience. This information is part of the secure member database and is password protected.

Links

This website contains links to other websites. Please be aware that Search123 is not responsible for the privacy practices of such other websites. We encourage our users to be aware when they leave our website and to read the privacy statements of each and every website that collects personally identifiable information. This privacy statement applies solely to information collected by this website.

Security

This website employs industry standard security measures to ensure the security of all data. Any data that is stored on our servers is treated as proprietary and confidential and is not available to the public. We have an internal security policy with respect to the confidentiality of customer and other data, allowing access only to those employees or third parties who have a need to know such information for the purpose of effectively delivering our products and services by means of user login and password requirements. We routinely evaluate our data security practices to identify security threats or opportunities for improvement.

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 ValueClick to intercept or access transmissions or private communications unlawfully. While we strive to protect your PII, ValueClick cannot ensure or warrant the security of any information you transmit to us. You acknowledge and assume this risk when communicating with a ValueClick Network company.

Members Email List

Our Member email list is used for administrative purposes only. We send all new Members a welcoming email to verify password and user name.

Site and Service Updates

We may send Members website and service announcement updates by email. Members are not able to un-subscribe from service announcements, which contain important information about the service. We communicate with Members to provide requested services and in regards to issues relating to their account via email or phone.

Correction/Updating Personal Information

If a Member's personally identifiable information changes (such as your email address) we provide several ways for a Member to correct or update their personal information. The following options are provided:

Email: privacy.uk@search123.com
Contact your account manager

If a Member no longer desires our service we provide two ways to remove that Member's personal data from being live in our system. All requests to remove a Member from our system will be verified prior to removal to insure the proper identity of the requester.

The following options are provided:

Email: privacy.uk@search123.com
Contact your account manager

Notification of Changes

If we decide to change our privacy policy, we will post those changes on the first page a Member views after successful login so our Members are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify Members by way of an email. Members will have a choice as to whether or not we use their information in this different manner. We will use information in accordance with the privacy policy under which the information was collected.

DATA PROCESSING/SAFE HARBOR

The European Union ("EU") maintains strict privacy laws. These rules differ significantly from US laws. To reconcile these differences, the US and the EU have created a Safe Harbor that defines mutually acceptable privacy operations. For more information see www.export.gov/safeharbor.

By providing information to us, you acknowledge that we operate in the US and you agree to (i) permit us to transmit and use your user Information anywhere necessary, including across international boundaries, to better improve the services and transactions provided by Search123 ; and (ii) that such use by us shall be subject to the terms and conditions stated in this Privacy Policy and the Terms of Use.

MISCELLANEOUS

YOU UNDERSTAND AND AGREE THAT ANY DISPUTE OVER PRIVACY IS SUBJECT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND APPLICABLE TERMS AND CONDITIONS. You also agree that you have provide notice to, and obtained consent from, any third party individuals whose personal data you supply to us with regard to: (a) the purposes for which such third party's personal 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.

Contacting Search123

If you have any questions about this privacy statement, the practices of this website, or your dealings with this website, please email us at privacy.uk@search123.com or you can send correspondence to the following address: Jayne Taberner, Country Manager, Search 123, 182 Upper Richmond Road, Putney, London, SW15 2 SH, United Kingdom. .