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PRIVACY STATEMENT (OCTOBER 2013)

FEN, a division of Pearson Education, Inc., ("FEN") operates this website ("Website") and is committed to protecting the privacy and security of its online visitors. We are also extremely sensitive to family and educator concerns about children's safety and information related to them. We want you to know about and understand the measures we have taken to keep the websites and online services provided by FEN a safe and secure environment for everyone. This privacy statement tells you about the types of information that we collect from you, how we collect that information from you and how we use that information.

We encourage our visitors to read through and understand our privacy statement. We may update it from time to time to address new issues or reflect changes on our Website. Please refer to this privacy statement regularly. FEN reserves the right to revise this privacy statement at any time and such revisions shall be effective immediately upon notice thereof. Notice may be given by any means including, but not limited to, posting the revised privacy statement on this Website. Any use of our site by you subsequent to such notice shall be deemed to constitute acceptance by you of such revision.

If you have any questions or concerns about this privacy statement, or your dealings with FEN, please:

a) E-mail us at Customer Support;

b) Write to us at: FEN, 501 Boylston St, Suite 900, Boston, MA 02116; or

c) Call us at: 1-800-498-3264.

Information We Collect From You

When you use this Website, we may collect personal information and anonymized information from you. Personal information means information that would identify you, directly or indirectly, such as your name, mailing address, email address or telephone number. Anonymized information means information that does not or could not reasonably be used to identify a specific individual.

When a player creates a user account we may request that he or she creates a unique username and password and provide us with certain information, such as, gender or age.

In connection with a purchase transaction, we will ask you for the following information: first name, last name, email address, billing address, credit card number, card expiration date and card security code.

This Website may contain blogs, bulletin boards or other public forums where free form entry is permitted. We highly recommend that you do not post your personal information when using these features. If you provide your personal information through any of these features, then such personal information will be posted publicly.

We also collect anonymized information from your computer or device such as browser type, operating system, referring pages, pages visited, time spent on a particular page and IP address.

How We Collect Your Information

When you use this website, we collect personal information and anonymized information through a variety of methods.

We collect personal information from you when you interact with this Website by filling out a form such as registering for a user account, submitting a customer service request, conducting a purchase transaction, or participating in a public discussion forum.

We collect anonymized information from you by using technologies like cookies, web beacons and server logs.

This Website contains cookies from FEN and third parties. While browsing through this Website, you may get cookies from our advertisers or sponsors. FEN does not control these cookies.

How We Use Your Information

FEN and its affiliates may use your personal information to tailor the content programming, services, and applications that we provide to meet your needs and interests. When you conduct a purchase transaction through this Website, you are providing purchase transaction information to FEN's third party service providers (such as transaction processors and financial institutions) who will use the information solely for the purpose of the purchase transaction.

When visitors request pages from FEN sites, our servers log users' IP addresses. We typically do not link IP addresses to any personal information. This means that a visitor's session will be logged, but the visitor remains anonymous to us.

FEN collects IP addresses for system administration, to report aggregate information to our advertisers, sponsors, and partners, and to audit the use of our site. We will use IP addresses to identify a user in the following situations: (a) in response to subpoenas, court orders or legal process, to the extent permitted and as restricted by law; (b) when disclosure is required to maintain the security and integrity of this site, or to protect any user's security or the security of other persons, consistent with applicable laws.

The anonymized information we track with cookies is not used to identify, or lead us back to, any particular visitor. Visitors to this Website may have the option of disabling cookies via their browser preferences (most browsers are initially set up to accept cookies). Cookies make our Website easier for you to use because they save your preferences while you are visiting our sites (although we do not save passwords in cookies). Cookies also help us know which areas are your favorites, which areas need improvement, and what technologies and Internet services our visitors are using. Knowing this information helps us continually improve the online experience for our visitors and members.

FEN may also use third party vendors who supply applications, web hosting and other technologies for this Website that may have access to your personal information and anonymized information but they will never use such information for any other purpose except to provide services in connection with this site.

FEN will not share any personal information about you with any third party (a party not affiliated with Pearson Education, Inc.), except as otherwise stated in this Privacy Statement and in the following circumstances: (a) in response to subpoenas, court orders or legal process, to the extent permitted and as restricted by law; (b) when disclosure is required to maintain the security and integrity of this site, or to protect any user's security or the security of other persons, consistent with applicable laws; (c) when disclosure is directed or consented to by the registered member who has inputted the personal information; (d) in the event that Pearson Education, Inc. (the owner of FEN) or any of its subdivisions or units goes through a business transition, such as a merger, divestiture, acquisition, liquidation or sale of all or a portion of its assets, your personal information will, in most instances, be part of the assets transferred; or (e) in limited circumstances, FEN may disclose your email address in order to comply with laws and regulations, including the Controlling the Assault of Non-Solicited Pornography and Marketing Act (CAN-SPAM of 2003).

Helpful Explanations

An IP address is a number that is assigned automatically to your computer whenever you use the World Wide Web. Web servers -- the big computers that "serve up" Web pages -- automatically identify your computer by its IP address.

The use of "cookies" is common in the Internet industry; you will find them used on this Website, as you will at other major websites. "Cookies" are small text files written to your computer. For more information about cookies please go to: http://www.allaboutcookies.org/.

Children's Privacy

FEN encourages parents and guardians to supervise their child's use of the Internet. We urge parents to instruct their children to never give out their real names, addresses, phone numbers, or other personal information without a parent's or guardian's permission when using the Internet. We recognize a special obligation to protect personal information obtained from children.

As a parent, you've probably done a lot of thinking about protecting your family's privacy on the Internet. We have been thinking and working hard to provide you with the best information and the highest quality interaction on the Internet in an environment that is safe. In compliance with COPPA (the Children's Online Privacy Protection Act), we have adopted the following policies to keep kids safe (there are exceptions to these policies as noted below under the heading "Exceptions to Verifiable Parental Consent and Information Collected from Children"):

- We will NOT knowingly collect, use, or distribute personal information from children under the age of 13 without prior verifiable consent from a parent or guardian.

- Personal information we collect from children under the age of 13 will be used solely by FEN or its agents for internal purposes only and will NOT be sold or otherwise distributed to third parties.

- We will NOT knowingly allow children under the age of 13 access to free form chat, message boards, email accounts, or other services within FEN that would allow them to publicly post or otherwise distribute personal information without prior verifiable consent from a parent or guardian.

- We will NOT knowingly ask a child under the age of 13 to divulge more information than is needed to participate in any activity, game, or service.

- We will NOT knowingly keep any personal information that is inadvertently included in a child's email submission, help inquiry, or other one-time request, if we know that the child is under the age of 13. Any such information will be purged promptly after the issue has been resolved.

- We will NOT knowingly post any personal information that is inadvertently included in a child's submission to a general audience contribution area if we know that the child is under the age of 13. Upon notice to us, these submissions will be deleted and handled anonymously thereafter.

- We will NOT knowingly provide any direct link to websites that are unsuitable for children or teens.

- We will advise children under the age of 13 that they MUST obtain permission from their parent or guardian before sharing ANY personal information.

- Upon request, FEN will provide a parent or guardian with a description of the information that may have been provided about their child during a registration process for a program or service of this site. FEN only asks for a child's or teen's personal information if it is necessary to participate in an activity, game or service.

If you have any questions about this Privacy Statement, please call FEN at: 1-800-498-3264.

Notification and Verifiable Parental Consent:

Before any personal information is collected, we will do our best to notify the parent or guardian that their child is participating. Notification will include the exact nature and intended use of the information we are collecting, as well as the opportunity for the parent or guardian to prevent the use of the information and the child's participation in the activity. For every child (anyone under 13 years of age) we require the parent or guardian to provide verifiable parental consent such as: by email plus a fax, phone or letter follow up by the parent or guardian; mail, fax or scan of a consent form; or toll-free phone call to FEN.

In order for us to provide notice to a parent or guardian and seek verifiable parental consent, we may request the contact information of a parent or guardian. This contact information will only be used for the sole purpose of obtaining verifiable parental consent or providing notification to the parent or guardian.

Exceptions to Verifiable Parental Consent and Information Collected From Children:

In the following instances we will NOT get verifiable parental consent for the collection of a child's personal information:

- Collecting a child's contact information solely to directly respond to the child's request on a one-time basis (for example, to provide assistance with a particular customer service question). We will not use that information to re-contact the child for any other purpose (we will purge from our system the child's personal information after responding);

- Collecting a child's contact information and the contact information of his/her parent or guardian solely to directly respond more than once to a specific request from the child (for example, to satisfy the request for a newsletter subscription). In this instance, the parent or guardian will be notified that the child made such a request and be informed of the information provided by the child. The parent or guardian will have an opportunity at any time to revoke the child's request (i.e., unsubscribe). We will not use the child's personal information to re-contact the child for any other purpose.

- Using persistent identifiers on our Website to support the internal operations of our Website which include: maintaining and analyzing the functioning of the Website; performing network communications; authenticating users; personalizing content on the Website; serving contextual advertising or capping the frequency of advertising; protecting the security or integrity of the user, Website or service; and to ensure legal and regulatory compliance. A "persistent identifier" is a series of numbers that we assign to a user but cannot be reasonably used to identify a specific user.

- A child may provide the email address of their parent or guardian for the purpose of retrieving or resetting a child's lost password for their user account. A parent or guardian's email address collected in this instance will only be used for this purpose.

About Our Advertisers:

This Website allows advertising by third parties. FEN does not control the linking practices of advertisers or sponsors and does not monitor or claim responsibility for any content or privacy practices of such websites. Once you have clicked on an advertisement and have left this Website, you must read the privacy policy of the advertiser or sponsor to see how your personal information will be handled.

FEN may offer contests, sweepstakes, and promotions that are sponsored by third-party advertisers or sponsors. These third parties may obtain personal information that visitors voluntarily submit to participate in the activity. FEN does not control the third parties' use of information.

FEN may use advertising servers developed by third parties to display ads on this Website. Some of these ads may contain cookies that are set by third parties (advertisers, sponsors) and may use anonymized information (not including your name, address, email address, telephone number) about your visits to this and other sites in order to provide advertisements about goods and services of interest to you. We do not have access to these cookies or any information that they transmit. The FEN privacy statement does not cover any use of information that a third-party ad server may have collected from you.

For more information on ad serving, please go to http://www.allaboutcookies.org/ad-serving/. If you would like to know your choices about not having information used by these third parties, please go to: http://www.networkadvertising.org/understanding-online-advertising/what-are-my-options.

A Notice About External Links

Occasionally, you will find links from FEN to independently owned, controlled, and/or managed Websites whose content we believe will be of possible interest and value to our visitors. Additionally, you'll see links from advertisers, sponsors, and other partners who may use a FEN owned logo as part of a co-branding agreement.

In many cases, these links represent cooperative projects or mutual links established with the organizations connected with these sites. We do not control the content of these links. These other sites may send you their own cookies, collect data, or solicit personal information. While we identify sponsor and advertiser areas of our Websites, we do not control these cookies or the content of these third parties.

FEN has partnered with other companies to provide certain services. In some cases, you may see a FEN owned logo on another company's site. FEN does not share any of your personal information with these partners and they do not share any information with us.

Once you leave our servers (you can generally tell where you are by checking the URL in the location bar on your browser), the use of any information collected from you is governed by the privacy policy of the operator of the site you are visiting. That policy may differ from ours. If you cannot find the privacy policy of any of these sites via a link from that site's Home page, you should contact the site directly for more information.

We specifically recommend that children check with their parents, guardians, or teachers before connecting to any new sites.

Security, Purchases and Credit Card Use:

FEN has security measures in place to protect the loss, misuse, and alteration of the information under our control. Essentially, we encrypt all transmission of sensitive data and secure all of our repositories of data. When you use your credit card to make a purchase transaction with FEN, your transaction is secure. Our servers use encryption technology to safeguard your personal information and privacy. However, you should understand that "perfect security" cannot be guaranteed.


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