30, 2007

nTowns is dedicated to providing a safe, secure online environment for families and their communities. At nTowns we recognize that privacy is important. This Policy applies to all websites offered by nTowns, Inc. or its subsidiaries or affiliated companies (collectively, nTowns “services”). If you have any questions about this Policy, please feel free contact us through our website or write to us at Privacy Matters, c/o nTowns Inc., 440 Totten Pond Road, Waltham, MA 02451

Children

Consistent with the federal Children’s Online Privacy Protection Act of 1998 (COPPA), we will never knowingly request personally identifiable information from anyone under the age of 13 without parental consent. We provide parents with information so they can decide whether to provide their personal information or permit their children to use our services. If we receive parental consent, we may receive personal information from children under the age of 13 in order to provide our services to them. We allow parents to monitor their children’s information, usage of service and communications. We allow parent to edit or delete their children’s information.

nTowns Privacy Policy Overview:
Personal information and other data we collect

• nTowns collects personal information when you register for a nTowns service or otherwise voluntarily provide such information. We may combine personal information collected from you with information from other nTowns services or third parties to provide a better user experience, including customizing content for you.
• nTowns uses cookies and other technologies to enhance your online experience and to learn about how you use nTowns services in order to improve the quality of our services.
• nTowns servers automatically record information when you visit our website or use some of our products, including the URL, IP address, browser type and language, and the date and time of your request.

Uses

• We may use personal information to provide the services you’ve requested, including services that display customized content and advertising.
• We may also use personal information for auditing, research and analysis to operate and improve nTowns technologies and services.
• We may share aggregated non-personal information with third parties outside of nTowns.
• When we use third parties to assist us in processing your personal information, we require that they comply with our Privacy Policy and any other appropriate confidentiality and security measures.
• We may also share information with third parties in limited circumstances, including when complying with legal process, preventing fraud or imminent harm, and ensuring the security of our network and services.
• nTowns processes personal information on our servers in the United States of America and in other countries. In some cases, we process personal information on a server outside your own country.

Your choices

• We offer you choices when we ask for personal information, whenever reasonably possible.
• You may decline to provide personal information to us and/or refuse cookies in your browser, although some of our features or services may not function properly as a result.
• We make good faith efforts to provide you access to your personal information upon request and to let you correct such data if it is inaccurate and delete it, when reasonably possible.

Information we collect and how we use it:

• Information you provide - When you sign up for an account or other nTowns service or promotion that requires registration, we ask you for personal information (such as your name, email address and an account password). For certain services, such as our advertising programs, we also request credit card or other payment account information which we maintain in encrypted form on secure servers. We may combine the information you submit under your account with information from other nTowns services or third parties in order to provide you with a better experience and to improve the quality of our services. For certain services, we may give you the opportunity to opt out of combining such information.
• nTowns cookies - When you visit nTowns, we send one or more cookies - a small file containing a string of characters - to your computer that uniquely identifies your browser. We use cookies to improve the quality of our service by storing user preferences and tracking user trends. Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some nTowns features and services may not function properly if your cookies are disabled.
• Log information - When you use nTowns services, our servers automatically record information that your browser sends whenever you visit a website. These server logs may include information such as your web request, Internet Protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser.
• User communications - When you send email or other communication to nTowns, we may retain those communications in order to process your inquiries, respond to your requests and improve our services.
• Affiliated sites - We offer some of our services in connection with other web sites. Personal information that you provide to those sites may be sent to nTowns in order to deliver the service. We process such information in accordance with this Policy. The affiliated sites may have different privacy practices and we encourage you to read their privacy policies.
• Links - nTowns may present links in a format that enables us to keep track of whether these links have been followed. We use this information to improve the quality of our services and advertising.
• Other sites - This Privacy Policy applies to web sites and services that are owned and operated by nTowns. These other sites may place their own cookies or other files on your computer, collect data or solicit personal information from you.

nTowns only processes personal information for the purposes described in the applicable Privacy Policy and/or privacy notice for specific services. In addition to the above, such purposes include:

• Providing our products and services to users, including the display of customized content and advertising;
• Auditing, research and analysis in order to maintain, protect and improve our services;
• Ensuring the technical functioning of our network; and
• Developing new services.

nTowns processes personal information on our servers in the United States of America. We may process personal information to provide our own services. In some cases, we may process personal information on behalf of and according to the instructions of a third party, such as our advertising partners.

Choices for personal information
When you sign up for a particular service that requires registration, we ask you to provide personal information. If we use this information in a manner different than the purpose for which it was collected, then we will ask for your consent prior to such use.
If we propose to use personal information for any purposes other than those described in this Policy and/or in the specific service notices, we will offer you an effective way to opt out of the use of personal information for those other purposes. We will not collect or use sensitive information for purposes other than those described in this Policy and/or in the specific service notices, unless we have obtained your prior consent.
You can decline to submit personal information to any of our services, in which case nTowns may not be able to provide those services to you.

Information sharing
nTowns only shares personal information with other companies or individuals outside of nTowns in the following limited circumstances:

• We have your consent. We require opt-in consent for the sharing of any sensitive personal information.
• We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable Terms of Service, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against imminent harm to the rights, property or safety of nTowns, its users or the public as required or permitted by law.

If nTowns becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, we will provide notice before personal information is transferred and becomes subject to a different privacy policy.

We may share with third parties certain pieces of aggregated, non-person information, such as the number of users in a particular town, for example, or how many users clicked on a particular advertisement. Such information does not identify you individually. Please contact us at the address below for any additional questions about the management or use of personal data.

Information security
We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store personal data.
We restrict access to personal information to nTowns employees, contractors and agents who need to know that information in order to operate, develop or improve our services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

Data integrity
nTowns processes personal information only for the purposes for which it was collected and in accordance with this Policy or any applicable service-specific privacy notice. We review our data collection, storage and processing practices to ensure that we only collect, store and process the personal information needed to provide or improve our services. We take reasonable steps to ensure that the personal information we process is accurate, complete, and current, but we depend on our users to update or correct their personal information whenever necessary.

Accessing and updating personal information
When you use nTowns services, we make good faith efforts to provide you with access to your personal information and either to correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. Some of our services have different procedures to access, correct or delete users’ personal information.

Enforcement
nTowns regularly reviews its compliance with this Policy. Please feel free to direct any questions or concerns regarding this Policy or nTowns’s treatment of personal information by contacting us through this web site or by writing to us at Privacy Matters, c/o nTowns Inc., 440 Totten Pond Road, Waltham, MA 02454. When we receive formal written complaints at this address, it is nTowns policy to contact the complaining user regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between nTowns and an individual.

Changes to this policy
Please note that this Privacy Policy may change from time to time. We will not reduce your rights under this Policy without your explicit consent, and we expect most such changes will be minor. Regardless, we will post any Policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Policy changes). Each version of this Policy will be identified at the top of the page by its effective date, and we will also keep in an archive for your review.

If you have any additional questions or concerns about this Policy, please feel free to contact us any time through this web site or at Privacy Matters, c/o nTowns Inc., 440 Totten Pond Road, Waltham, MA 02451.