January 25, 2008
PRIVACY POLICY

INTRODUCTION. Ole!Ole!, LLC ( “Ole!Ole!”) is committed to respecting the privacy rights of its customers, visitors, and other users of the Ole!Ole! Website (“the Site”). We created this Website Privacy Policy (“Privacy Policy”) to give you confidence as you visit and use the Site, and to demonstrate our commitment to fair information practices and the protection of privacy. This Privacy Policy is only applicable to the Site, and not to any other websites that you may be able to access from the Site, each of which may have data collection, storage, and use practices and policies that differ materially from this Privacy Policy.

Ole!Ole! is a licensee of the TRUSTe Privacy Program. TRUSTe is an independent, non-profit organization whose mission is to build user’s trust and confidence in the Internet by promoting the use of fair information practices. This privacy statement covers the Web site OleOle.com. Because this Web site wants to demonstrate its commitment to your privacy, it has agreed to disclose its information practices and have its privacy practices reviewed for compliance by TRUSTe.

If you have questions or concerns regarding this statement, you should first contact us at support@oleole.com. If you do not receive acknowledgement of your inquiry or your inquiry has not been satisfactorily addressed, you should contact TRUSTe at http://www.truste.org/consumers/watchdog_complaint.php TRUSTe will then serve as a liaison with us to resolve your concerns.

Information Collection Practices

Types of Information Collected

(a) Traffic Data Collected. We automatically track and collect the following categories of information when you visit our Site: (1) IP addresses; (2) domain servers; (3) types of computers accessing the Site; and (4) types of web browsers used to access the Site (collectively “Traffic Data”). Traffic Data is anonymous information that does not personally identify you but is helpful for marketing purposes or for improving your experience on the Site. We also use “cookies” to customize content specific to your interests, to ensure that you do not see the same advertisement repeatedly, and to store your password so you do not have to re-enter it each time you visit the Site. The information stored in Traffic Data cookies is not linked to any Personal Information. Some of our business partners use cookies on our site. We have no access to or control over these cookies. This privacy statement covers the use of cookies by OleOle.com only and does not cover the use of cookies by any third party.

(b) Personal Information Collected. In order for you to access certain premium, services and to purchase products that we offer via the Site, we require you to provide us with certain information that personally identifies you (“Personal Information”). Personal Information includes the following categories of information: (1) Contact Data (such as your name, mailing address, and e-mail address); (2) Financial Data (such as your account or credit card number); and (3) Demographic Data (such as your zip code, age, and income). If you communicate with us by e-mail, post messages to any of our chat groups, bulletin boards, or forums, or otherwise complete online forms, surveys, or contest entries, any information provided in such communication may be collected as Personal Information.

Uses of Information Collected

(a) OLE!OLE! USE OF INFORMATION. We use Contact Data to send you information about Ole!Ole!, our products or services, promotional material from some of our partners, or to contact you when necessary. You may opt-out of receiving such communication at any time by changing your Notification Preferences on your My Account/Notifications page. We use your Financial Data to verify your qualifications for certain products or services and to bill you for products and services. We use your Demographic Data to customize and tailor your experience on the Site, displaying content that we think you might be interested in and according to your preferences. When you log in to your account at OleOle.com, we link the information we store in your log in session cookie to Personal Information. Your Contact Data (e-mail address) is required for the proper functioning of certain content (e.g., our Fantasy Football game). For your privacy and security any personally identifiable information in cookies is stored and transmitted using 128-bit encryption.

(b) Sharing of Personal Information. We share certain categories of information we collect from you in the ways described in this Privacy Policy. We share Demographic Data with advertisers and other third parties only on an aggregate (i.e., non-personally-identifiable) basis. We may share Contact Data and Financial Data with our business partners who assist us by performing core services (such as hosting, billing, fulfilment, or data storage and security) related to our operation of the Site. Those business partners have all agreed to uphold the same standards of security and confidentiality that we have promised to you in this Privacy Policy, and they will only use your Contact Data and other Personal Information to carry out their specific business obligations to Ole!Ole!. We do not share, sell, rent or trade Personal Information with third parties for their promotional purposes.

You will be given a choice to opt out of sharing your Personal Information with our business partners at the point of collection, but please understand that this will likely limit or prevent you from using the features and services we offer on the Site. In addition, we maintain a procedure for you to review and request changes to your Personal Information; this procedure is described below.

(c) User Choice/Opt-out Regarding Collection, Use, and Distribution of Personal Information. You may choose not to provide us with any Personal Information. In such an event, you can still access and use much of the Site; however you will not be able to access and use those portions of the Site that require your Personal Information (e.g, user registration). If you are a registered user and do not wish to receive information and/or promotional material from us, you can opt-out from this by following the instructions included in each e-mail or communication, or via your My Account/Notifications page. You may e-mail us at support@oleole.com for further assistance.

(d) E-mail A Friend. If you choose to use our notification service to tell a friend about our Site, or to alert them to specific content, we will ask you for your friend’s e-mail address. We will automatically send your friend a one-time e-mail inviting him or her to visit the Site. Ole!Ole! does not retain the e-mail address, it is used for the sole purpose of sending this one-time e-mail.

(e) Live Support. We provide a live support chat feature on our Tickets and Travel pages. When used during regular business hours, this feature does not collect or retain any Personal Information. When used outside of regular business hours, the live chat feature collects your name and e-mail address for use in a one time e-mail that is used to forward your inquiry to our sales department. No personal information is retained.

CONFIDENTIALITY AND SECURITY OF PERSONAL INFORMATION. Except as otherwise provided in this Privacy Policy, we will keep your Personal Information private and will not share it with third parties, unless such disclosure is necessary to: (a) comply with a court order or other legal process; (b) protect our rights or property; or (c) enforce our Terms of Service.

The security of your personal information is important to us. OleOle uses industry-standard 128-bit SSL encryption to protect your information. When you enter sensitive information (such as a credit card number and/or passport number) at our online store, we encrypt that information using Secure Socket Layer (SSL) technology. Ole!Ole! uses thawte SSL Certificates to offer secure communications by encrypting data to and from the site. Click HERE for more information on the thawte SSL certification.

OleOle.com servers are housed in a secure data center behind a dedicated firewall, and access to the data contained on the servers is restricted with encryption and passwords.

We follow accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is perfectly secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee, and you cannot expect, its absolute security.

If you have any questions about security on our website, you can contact us via the “Contact Us” link at the bottom of each page, or send an e-mail to us at support@oleole.com.

USER ABILITY TO ACCESS, UPDATE, AND CORRECT PERSONAL INFORMATION. We maintain a procedure in order to help you confirm that your Personal Information remains correct and up-to-date. At any time, you may visit your personal profile at oleole.com. Through your Edit My Profile page you may: (a) review and update your Personal Information that we have already collected; and/or (b) choose whether or not you wish us to send you announcements or special offers through your My Account/Notifications page.

To access Edit My Profile: (a) Log in to your account and navigate to your personal profile; (b) click the “Edit” link in the “Personal Info” section. If you require assistance in updating and/or correcting your personal information, please use the “Contact Us” link, located at the bottom of each page, or send an e-mail to us at support@oleole.com.

LOST OR STOLEN INFORMATION. You must promptly notify us if your credit card, user name, or password is lost, stolen, or used without permission. In such an event, we will remove that credit card number, user name, or password from your account and update our records accordingly.

PUBLIC INFORMATION. If you use the forum, post blogs, or submit comments on this Web site, you should be aware that any personally identifiable information you submit there can be read, collected, or used by other users of the Web site, and could be used to send you unsolicited messages. We are not responsible for the Personal Information you choose to submit in forums, blogs, or comments.

The Site contains links to other websites. We are not responsible for the privacy practices or the content of such websites. We also make chat rooms, forums, message boards, and news groups available to you. Please understand that any information that is disclosed in these areas becomes public information. We have no control over its use and you should exercise caution when deciding to disclose your Personal Information.

UPDATES AND CHANGES TO THIS PRIVACY POLICY. We reserve the right to modify this privacy statement at any time, so please review it frequently. If we decide to change our privacy policy, we will post those changes to this privacy statement, the home page, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We will notify you here, by e-mail, or by means of a notice on our home page prior to implementing the changes. These changes will take effect 30 days after they are posted on the Site.

If you have additional questions not answered online, you may write to us at: Ole!Ole!, 9777 Wilshire Boulevard 10th Floor, Beverly Hills, California 90212, or by using the Contact Us form.