The owners of Habbo and any other services that we may offer from time to time, Sulake Canada Inc. ('we', 'our' or 'us'), and our parent company and affiliated companies (collectively, 'Sulake Canada Affiliates') are committed to protecting your privacy in accordance with this Privacy Policy. We try to keep our Websites as secure and as private as we can and we comply with the privacy protection rules contained in Canada’s Personal Information Protection and Electronic Documents Act.

We have a few rules that you need to accept before you can become a member of one of our Websites, and you need to read this Privacy Policy and the rest of the relevant Terms and Conditions all the way through before you can join. Terms not defined here are defined in the relevant Terms and Conditions. By clicking the 'accept' button when you register you are agreeing to our collection, use and disclosure of your personal information as described in this Privacy Policy.

If you are under 18 years old, you must check with your parents or guardians before you agree to this Privacy Policy and to ensure that they agree that you can visit our Websites. Please have them explain anything in this Privacy Policy that you may not fully understand.

If you have any concerns regarding your personal information, website content, or any queries with regard to our practices please email us.

YOUR CONSENT
By using our Websites and submitting any personal information to us or any Sulake Canada Affiliate, you consent to our collection, use and disclosure of your personal information as described in this Privacy Policy.

PERSONAL INFORMATION
'Personal information' is information about you that allows you to be identified. Personal information can include information such as:

• your name,
• home addresses,
• email addresses,
• other web addresses,
• usernames and passwords,
• age (including your date of birth), which will be provided for the purpose of
deciding if you are eligible to use the service, and to check if advertising material shown in the service can be shown to you.
• telephone numbers,
• credit card numbers or other payment information, or
• the items you purchase from the Websites.


COLLECTION OF PERSONAL INFORMATION
You may submit personal information to us when you visit our Websites. Information is collected through your interaction with us, including:

• your completion of online forms (such as the registration form),
• your participation in contests and surveys,
• your subscription for certain newsletters and enhanced services,
• your posting of messages to the message boards and chat services, or
• your emails or other communications with us.

We may from time to time collect other personal information. If we do so, we will notify you and, as appropriate, obtain your consent.

Cookies
In certain circumstances, we may also keep a record of the conversations that you have with other end users within our Websites We also collect "cookie" information automatically about your visit to our Websites. A cookie is a small piece of information sent by web server to a web browser, which enables the server to collect information from the browser about your computer, but not about you. We use cookies to identify your computer when your computer is used to visit us and to keep track of which webpages and websites you visit so we can build up a demographic profile and learn about what your preferences are. Our use of cookies also allows you to be presented with a personalised version of the Websites and promotional information, and to enable you to access your account.

USE OF PERSONAL INFORMATION
Personal information we collect about you may be used for the purposes of:

• Understanding your needs and improving our offering of information, products and services to you, such as special discounts and deals.
• Enabling you to send other end users emails and SMS without them knowing your contact details.
• Administering your account with us, such as collecting payments and monitoring your credit status, and managing invoicing, accounting and information security services related to our relationship with you.
• Keeping track of the virtual goods, services and privileges you have purchased through Habbo.
• Where you have agreed, to send you newsletters and other information (including marketing information) about the Websites, us and Sulake Canada Affiliates, in any format or media, including via third parties.
• Informing you about changes or new information that might affect you or your account (e.g. changes to our procedures, changes to the Terms and Conditions, etc.).
• Maintaining information as a reference tool or general resource to help us to understand trends and visitor needs. This information will be maintained to help us to further improve our service, and information used for this purpose will be anonymous not personally identifiable.
• Where you have agreed, providing you with personalised information about products and services of ours, Sulake Canada Affiliates, and third parties with whom we do business.
• Detecting and protecting us and Sulake Canada Affiliates and other third parties against error, negligence, breach of contract, theft, fraud and other illegal activity, to comply with our audit requirements, and to audit compliance with our corporate policies, the relevant Terms and Conditions, this Privacy Policy, laws and contractual obligations.
• As permitted by, and to comply with, applicable laws and regulations.
• Any other purposes to which you consent.


To the extent that the above uses of personal information also require that information to be disclosed, we may also disclose the information for that purpose.

DISCLOSURE OF PERSONAL INFORMATION
We will not disclose your information to others except as set out in this Privacy Policy. Personal information we collect may be shared with Sulake Canada Affiliates, business partners, purchasers of our business, suppliers and service providers we engage, but only for the purposes described in this Privacy Policy or to which you otherwise consent. When we provide personal information to a third party, we use contractual or other means to provide a comparable level of protection and limit their use of such information to the purposes set out in this Privacy Policy.

In addition to the purposes described above in 'Use of Personal Information', from time to time, we may disclose your personal information to:

• prospective purchasers, investors, professional advisors, and other third parties for the purpose of a prospective or actual sale, merger, acquisition, financing or other corporate business transaction involving us (or a Sulake Canada Affiliate) or our assets.
• service providers retained by us or a Sulake Canada Affiliate for the purpose of performing functions on our behalf or to provide services to us or a Sulake Canada Affiliate, such as Website hosting, data processing and storage, software development and support, advertising and marketing, research, delivery, payment processing, office services, in each case provided that such service provider does not use or disclose your personal information for purposes other than those described in this Privacy Policy or with your consent.
• credit bureaus and credit reporting agencies.
• government and regulatory authorities or other organizations, as required by law.
• a person who, in our reasonable judgment, is providing or seeking information as your agent (such as your parent or guardian).
• Our and Sulake Canada Affiliates' insurers and professional advisors.


OTHER USES AND DISCLOSURES
We may from time to time use or disclose the information that we hold for other purposes than those noted above. If we intend to use or disclose any of your personal information for a purpose other than the purpose for which it was originally obtained, we will, as appropriate, notify you and obtain your consent. This consent may be obtained expressly or implicitly, such as by asking you to provide information with stated purposes, but without any express statement of consent.

RETENTION OF INFORMATION
We retain your information as long as it is required for the purposes identified when you provided the information or for any new purposes identified by us and consented to by you. Certain information is retained for longer periods for our internal audit and quality control purposes.

CHAT ROOMS AND MESSAGE BOARDS
We make chat facilities and message boards available to you. No personal information that you provide to us shall, by default, be displayed to other users in our chat facilities and message boards. If you have connected to Habbo using a third party service such as Facebook, your screen name with that service will be shown to other users who are also part of your network with that third party. Please remember that any information you choose to disclose in these areas may become public information. We would encourage you to exercise caution when deciding to disclose information, and be careful what you reveal to people you don't yet know. Please refer to the relevant Terms and Conditions.

OPTING-OUT - WITHDRAWING YOUR CONSENT
While there is certain personal information that we require from you in order to provide you with all of the features, products and services of the Websites, under most circumstances you may withdraw your consent to our collection, use and disclosure of information for certain purposes. For example, you may chose not to receive the Website newsletters or information about products and services supplied by us or Sulake Canada Affiliates or third parties by ticking the boxes at the bottom of the registration form. You may also change these options anytime by selecting the ‘Account Settings’ link (for Habbo) or the ‘Own Info’ link (for Luupi) on our Websites’ home page. Alternatively, you may opt-out by emailing us.

DELETING YOUR ACCOUNT
You may delete your account with us by informing our customer support and asking them to delete your account. If you request to have your account deleted, you will not be able to reactivate your account or retrieve any of the content or information you have added. Personal information that was collected by us related to your account may be retained by us for a reasonable period of time but will not be generally available to other users of the Websites.

ACCESS, UPDATE OR CORRECT YOUR INFORMATION
Following registration you may be able to review and change some of the information that you provided to us by emailing us. To ensure that the personal information that you provided to us is accurate, complete and up to date as is necessary for the purposes for which it is to be used, we rely on you to provide us with updates and to inform us of any errors by emailing us.

SECURITY
We protect your personal information with appropriate security safeguards, including physical, administrative and technical measures designed to protect against loss, theft and unauthorized access, disclosure, copying, use or modification. All personal information you provide us with on the Websites, and all personal information contained in your account, is encrypted. This coding lets your browser automatically encrypt or scramble data before you send it to us. Transactions will not be permitted if your browser does not accept the encryption. Only authorised personnel of ours and Sulake Canada Affiliates or their partners can decode this information and such personnel will only do so when necessary and in accordance with our, or their, privacy policy. In certain cases, personal information may be transferred outside of Canada in order to continue to provide our products and services to you. In those cases, the information will be subject to the laws and regulations of the jurisdiction where the information is transferred.

Please note that unlike your communications with the Websites, we have no control over the privacy of your e-mail messages with us. We recommend that you do not include personal information in e-mails, including your account password. We are not responsible for any loss or damage if you send us personal information by e-mail.

CHILDREN
If any of your children under 18 years of age disclose information about themselves using our Websites or in our public discussion areas, they may get unsolicited messages from other parties. Accordingly, it is up to you to ensure they abide by the relevant Terms and Conditions., caution them not to share personal information, and to monitor their use of the Websites. If you're worried about your children's activities or their privacy on our Websites, we encourage you to email us.

CHANGES TO THIS PRIVACY POLICY
We reserve the right, at any time, and from time to time, to modify this Privacy Policy and to reflect those changes in our information practices, and you agree to be bound by such modifications. However, any changes or additions to the purposes for which we collect, use or disclose your personal information will not apply to you unless you consent to them or unless otherwise permitted by law. Changes to this Privacy Policy shall be effective immediately upon providing you with notice, which notice may be given by any means, including without limitation, by posting the change on the Websites or by electronic or conventional mail. You agree to regularly review the Privacy Policy. Your use of the Websites following any change (other than changes to the purposes for which we collect, use or disclose your personal information) shall constitute your agreement to the modified Privacy Policy. If at any time the Privacy Policy is no longer acceptable to you, you should not use the Websites.

LINKS TO THIRD PARTY WEBSITES
Please be aware our Websites may have advertisements and links to third party websites and services that may collect personal information about you. These third party websites operate independently of us and are not under our authority or control. This Privacy Policy does not cover the practices and policies of these other third parties, and we cannot control the information practices of these third parties. We encourage you to read the policies of all websites you use, as their policies and practices may be very different from ours. Sulake Canada and Sulake Canada Affiliates are not responsible for any information that is provided by, or collected through, those websites or for any other use of those websites.

APPLICATION OF THIS PRIVACY POLICY
Nothing in this Privacy Policy will create or add to any right or claim (whether legal, equitable or otherwise) that any individual or person may have at law or otherwise against us or a Sulake Canada Affiliate; nor will the existence of this Privacy Policy or its application impose any obligations or liability upon us or a Sulake Canada Affiliate, or add to any obligation or liability, that we or a Sulake Canada Affiliate does not already otherwise have to any individual or person at law or in equity or otherwise.