BEELINE INTERACTIVE, INC.
PRIVACY POLICY

Last Updated: November 9, 2012

INTRODUCTION

Your privacy is important to Beeline. This Privacy Policy explains how we collect, use, disclose, transfer and store your information. Please familiarize yourself with our privacy practices and contact us as described below under “Contact Beeline” if you have any questions.

This Privacy Policy applies only to the collection, use and disclosure of information that we may receive through your use of: (i) “Beeline Games,” which means our games for mobile devices and the internet, which may be accessible on third party social networking services such as Facebook (“SNS’s”) and (ii) our web domains and subdomains, including www.beeline-i.com (our “Sites”), and including web forums and messaging boards in Beeline Games and our Sites (“Forums”). We refer to the Beeline Games and the Sites as our “Services”.

As used in this Privacy Policy, “Beeline”, “we”, “us”, or “our” refer to Beeline Interactive, Inc., and its subsidiaries. This Privacy Policy does not apply to our parent company, Capcom Co., Ltd., or any of the other companies within the Capcom corporate group. Information of Beeline users that reside outside the United States may be controlled by Beeline Interactive, Inc., Beeline Interactive Europe, Ltd. (UK) and/or Beeline Interactive Japan, Inc.

Updates to this Privacy Policy

We reserve the right to update this Privacy Policy at any time. If we modify this Privacy Policy in a material way, a notice will be posted on the Sites along with the updated Privacy Policy. We will also update the “Last Updated Date” in the Privacy Policy. “Privacy Policy” as used herein includes any updates and modifications we may make from time to time.

By continuing to access or use the Services after we have posted an updated Privacy Policy or have provided you with notice of a modification, you agree to be bound by the modified Privacy Policy. If the modified Privacy Policy is not acceptable to you, you must immediately stop using any Services.

INFORMATION WE COLLECT

We may collect through the Services both information that may be used to contact you or identify you personally information (“Personal Information”) and non-personal information, which is data in a form that does not allow direct association with you (“Non-Personal Information”). We may also collect technical information, including the IP address through which you are accessing the Services and the unique mobile device ID for any mobile device you may be using (“Technical Information”).

Personal Information

Personal Information may include, but is not limited to, your name, e-mail address, month and day of birth, any personal photo or image representation and your login information and user ID for any SNS that you may use to access the Services, or that you may interact with through the Services. We will collect, use and disclose Personal Information only as described in this Privacy Policy.

Please note that some Non-Personal Information would be considered a part of your Personal Information if it were combined with other information in a way that enables you to be identified, but the same information is considered Non-Personal Information when taken alone or combined only with other Non-Personal Information.

Non-Personal Information

Non-Personal Information is aggregated information regarding usage of the Services. We may collect, use, transfer and disclose Non-Personal Information by any means and for any purpose. Any information in this Privacy Policy about how we may collect, use and disclose Non-Personal Information is not exclusive, and we may collect, use and disclose Non-Personal Information in other ways as well.

Technical Information

Technical Information relates to your mobile device or computer system and includes mobile device type, IP address, unique mobile device ID and Media Access Control (MAC) address, telephone number of mobile device, country of registration. It may also include browser type, language, Internet Service Provider (ISP), referring and exit pages, time spent, information searched for, time and date stamp, clickstream data and other statistics.

HOW WE USE PERSONAL INFORMATION

Generally, we use your Personal Information to provide you with an efficient and customized experience. For example, we may use Personal Information in the following ways:

If we send e-mail or SMS messages to you for the purpose of promoting Beeline products or services, or those of a third-party partner, we will generally provide you with choices about receiving further such promotional messages. Preferences for “push” notifications may in most cases be adjusted through Beeline Games or your mobile device.

HOW WE USE TECHNICAL INFORMATION

We may use Technical Information to enable Beeline Games to function properly, to analyze patterns in user behavior in order to improve Beeline Games, to associate your Beeline Account with any mobile device or personal computer you may be using and to analyze and respond to support requests. We may also use Technical Information to track clicks or other ad fulfillment metrics.

HOW WE COLLECT INFORMATION

Registration for Beeline Account

When you register for a Beeline Account, we may request your name, e-mail address, gender, month and day of birth, country of residence and other Personal information. We may also collect Technical Information relating to your mobile device or personal computer.

Interaction with SNS’s

If you are a member of an SNS, Beeline Games may enable you to log in through an interface provided by that SNS. Beeline Games may also enable you to access the SNS through the Beeline Games themselves. If you log in to a Beeline Game using an SNS, or access an SNS through a Beeline Game, we may receive the Personal Information that you have provided (or provide in the future) to that SNS. By connecting the Beeline Game to an SNS in this manner, you consent to Beeline’s access and use of this Personal Information. We may also receive Technical Information from the SNS.

You may be able to specify what Personal Information is provided by the SNS to Beeline using the privacy settings in your SNS profile information.

We do not store on the Services your login information for any SNS.

Other

In certain Beeline Games you may have the option to provide an e-mail address to enable us to contact you with updates about Beeline Games. Your e-mail address may also be used as your user name for certain Beeline Games.

Beeline may provide you the opportunity to participate in include sweepstakes or contests (“Promotions”). If you choose to participate in a Promotion, we may request that you provide us with Personal Information such as your e-mail address or mailing address.

If you request support relating to a Beeline Game, we may request Personal Information such as your name and e-mail address and your user name for any SNS’s, if that appears necessary to resolving the problem.

Our Sites may require you to enter a region and language in order to provide relevant information in your language.

We may also request or receive Personal Information in other interactions you may have with Beeline.

COOKIES AND OTHER TECHNOLOGIES

A cookie is a small string of text that we, or service providers acting on our behalf, such as Google Analytics, send to your computer’s or mobile device’s browser. Other types of cookies exist, but the cookies in the Services are only used to obtain browser-specific information.

Some cookies are necessary to enable a game to function properly and to allow your gameplay experience to continue from one session another, or to prevent you from having to reenter your region and language each time you access our Sites. Other cookies can show, for instance, which parts of Beeline Games are the most popular, how much time users are spending there, and how they are interacting with the content. Cookies may be linked to your Beeline user ID. They do not collect information from your computer or mobile device that is not related to the Service.

You may have the option to disable cookies by changing the options in your browser to stop accepting cookies or to prompt you before accepting a cookie from the pages you visit. If you do not accept cookies, however, you may not be able to use all portions of our Services.

We may also use “pixel tags,” “web beacons,” “clear GIFs” or similar means (individually or collectively “Pixel Tags”) in connection with our Services and to collect usage, demographic and geographical location data. A Pixel Tag is an electronic image, often a single pixel that is ordinarily not visible to users and may be associated with cookies on a user’s device or hard drive. Pixel Tags allow us to count users who have visited certain pages of the Services and to help determine the effectiveness of promotional or advertising campaigns.

Please note that third parties delivering advertisements through the Services may also use cookies or other technologies. Their placement and use of cookies and other technologies will be subject to their own privacy policies and terms and conditions.

BY CLICKING ON THE “SIGN UP” BUTTON, WHERE APPLICABLE, OR OTHERWISE BY ACCESSING OR USING OUR SERVICES YOU ARE CONSENTING TO THE USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES ON YOUR DEVICE.

HOW WE SHARE YOUR INFORMATION

Within the Beeline Services

As a Beeline Account holder, information you put in your user profile may be visible to other users of the Services.

The user ID name and number linked to your Beeline Account will be public and may appear in the URL of your profile page.

Users with Beeline Accounts may have the opportunity to communicate with other users of the Services through various channels. Should you do so, your login name and the content of your communications may be available to other Beeline Users. Communications may include your name and the photo or other personal image that you have uploaded to your profile. Some or all of your profile information, as well as your gameplay activity, may also be visible to other Beeline Users with whom you have connected through Beeline Games.

Beeline is not responsible for the activities of other users of the Services or other third parties with whom you choose to provide your Personal Information or otherwise interact.

With SNS’s

If you are a member of an SNS, Beeline Games may enable you to log in through an interface provided by that SNS. Beeline Games may also enable you to access the SNS through the Beeline Games themselves.

Please note that any SNS you may choose to use in connection with the Services is not subject to this Privacy Policy. Any collection of information by an SNS, or use or disclosure of information we provide them, will be subject to their own privacy policy, terms of use or other applicable policy. You should review the information posted by your SNS before deciding to provide information to the SNS or use the SNS in connection with any Beeline Game.

With Our Service Providers

To help administer the Services, we may use third-party service providers. These service providers will have access to your Personal Information only to perform the services they have been engaged to perform for us, and they have agreed not to disclose or use it for any other purpose.

Under Special Circumstances

We may disclose information about you to law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Beeline or a third party, to protect the safety of any person or to prevent or stop activity we may consider to be illegal or unethical.

In connection with a merger, acquisition, reorganization or sale of assets, or in the event of bankruptcy, we may sell, transfer or otherwise share some or all of Beeline assets, including your Personal Information.

No Sharing of Personal Information with Third-Party Advertisers without Consent

We will not share your Personal Information with third-party advertisers for their direct marketing purposes unless you provide your consent.

CHILDREN UNDER THE AGE OF 13

The Services are not intended for children under the age of 13, and we do not knowingly collect any Personal Information from such persons. If we discover that we have inadvertently collected Personal Information from children under the age of 13, we will take all reasonable measures to erase such information from our systems.

FRIEND-FINDING FUNCTION

The Services may include a function that may help you to identify friends with whom you may wish to play a Beeline Game. At your option, the function may access your contacts on Facebook, Google, Yahoo! or another SNS, or may scan your computer or mobile device. This function may identify which of your contacts have Beeline Accounts, in which case you may be connected with them through the Services. At your option, Beeline may also send an invitation to other contacts who do not have Beeline Accounts for them to use the Services.

Your use of the friend-finding function in connection with an SNS is subject to your user agreement with the SNS, and any policies of that SNS.

HOW WE PROTECT YOUR INFORMATION

Beeline is committed to protecting the security of your information. We have implemented security measures to protect against identity theft and unauthorized access.

We do not and will not, at any time, request your credit card information, your login information or other identification in a non-secure or unsolicited communication (such as e-mail).

Should any breach of security occur, we will make any legally required disclosure to you by e-mail or posting on the Services as soon as reasonably possible, subject to (i) the requests of law enforcement and (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

HOW YOU MAY CHANGE OR REMOVE INFORMATION

If you have a Beeline Account, you may update or delete Personal Information by logging in and accessing the account profile page.

You may also email us at privacy@beeline-i.com to request that we delete your Personal Information from our database. In that case, please place “delete my account” in the subject line and include your first and last name, e-mail address and Beeline Account user ID in the body of the message. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for business administrative purposes.

Please note that communications you may send through the Services, as well as any comments you may post, will be stored by Beeline, and may not be subject to modification or deletion.

CAPCOM PRESS CENTER

Please note that this Privacy Policy does not apply to any information collected through the “News” page of our Site at www.beeline-i.com. To read news items posted there, you must click through to the website of Capcom U.S.A., Inc. and register for the Capcom “Press Center.” Any information provided through such process, or in the course of interacting with the Press Center, will be governed by the Capcom privacy policy, available at www.capcom.com/capcom/legal_privacy/privacy.html.

LINKS TO THIRD-PARTY WEBSITES AND SERVICES

The Services may contain links to other websites and online services, including third-party advertisements. If you choose to click through to one of these other websites or online services, please note that any information you may provide will be subject to the privacy policy and other terms and conditions of that websites or service, and not to this Privacy Policy. We do not control third-party websites or services, and fact that a link to such a website or service appears in the Services does not mean that we endorse them or have approved their policies or practices relating to user information.

Before providing any information to any third-party website or service, we encourage you to review the privacy policy and other terms and conditions of that website or service. You agree that Beeline will have no liability for any matters relating to a third-party website or service that you provide information to, including their collection and handling of that information.

NON-US USERS

Information that you provide may be transferred or accessed by entities around the world as described in this Privacy Policy. If you are located outside the United States, you understand that we may transfer Personal Information to and process it in the United States. Your consent to this Privacy Policy followed by your submission of Personal Information represents your agreement to that transfer.

YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident and Beeline user, you are entitled to request certain information regarding our disclosure of certain “personal information” (as defined in California Civil Code Section 1798.83) to third parties for their direct marketing purposes. If you are a California resident and have provided Beeline with personal information within the last year, you may make such a request by emailing us at privacy@beeline-i.com and typing the following in the subject line of the e-mail: “California Privacy Rights”.

Within 30 days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for such third parties’ direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. A request may be made no more than once per calendar year and we are not required to respond to requests made by means other than through the e-mail address above.

CONTACTING BEELINE

If you have any questions, inquires, requests or complaints concerning this Privacy Policy or our information practices, please contact us at privacy@beeline-i.com or by regular mail at the following address: Privacy Officer, Beeline Interactive, Inc., 10960 Wilshire Blvd, Suite 1500, Los Angeles, CA 90024 USA.