- Kabuse Privacy Policy

This Privacy Policy and the User Agreement together govern your use of this website and the other websites listed in the User Agreement (each a “Website” and, together, the “Websites”). You (“You” or “User”) must read and accept the terms of the User Agreement and Privacy Policy before you will be allowed to register as a user of the Websites. If you do not register as a user, you will not be able to visit all sections or use all features of the Websites.

This Privacy Policy explains how we collect your personal data on our Websites, how we protect such data, and the choices you have concerning our use of such data. Please read this Privacy Policy carefully. For the purposes of this Privacy Policy, “we”, “us”, and “our” means Kabuse Inc. and its affiliates. A complete list of Kabuse’s group affiliates can be found on the www.kabuse.com website. Our global representatives include Donzi Capital Management Ltd.

This Privacy Policy represents our current (as of August 09, 2006) data collection and usage practices. Kabuse will from time to time review and revise these practices. We will post any changes to this Privacy Policy here. Please refer back to this Privacy Policy on a regular basis.

This Privacy Policy applies only to information collected by our Websites. We are not responsible for the privacy of any information you reveal or post in any public forum (e.g., message board or chat room), or for the privacy practices of websites that are operated or owned by third parties.

Collection of Personal Data

Personal data is information that identifies you or can be used to identify or contact you, e.g. your name, email address, address, or phone number (“Personal Data”). Kabuse requests Personal Data from you when you register on any of our Websites. The registration process requests that you provide your name, business email address, business address, business phone number, and company affiliation, and agree to the User Agreement presented at the time of registration. In addition to information collected during registration, Kabuse may collect Personal Data knowingly provided by you in emails to our Websites, online forms, order and registration forms, surveys, and contest entries. In addition, on some of the Websites including www.kabuse.com, you are able to maintain “portfolios”, listing financial instruments in which you have a special interest. Providing this information is always at your option. If you provide such information you will be required to select a username and a password. To be useful, this information must be stored on the relevant Website, and is accessible to any site visitor who knows your username and password. For this reason, please safeguard your username and password carefully and do not disclose it to any other person.

In all of these cases, we will collect Personal Data from you only if you voluntarily submit such information to us. Unless you give us permission to do so, we will not sell, share, license, trade or rent your Personal Data other than as specified in this Privacy Policy.

You do not have to provide us with any Personal Data to visit our Websites. However, if you choose to withhold requested information, you may not be able to visit all sections or use all features of our Websites.

Collection of Monitoring Data and Use of Tracking Tools

In addition to Personal Data, Kabuse may collect and/or track information that by itself cannot be used to identify or contact you, e.g., demographic information, domain names, computer type, browser types, screen resolution, and other anonymous statistical data involving the use of our Websites (“Monitoring Data”). We use Monitoring Data to help us understand who uses our Websites and to improve and market our Websites. Whenever we use Monitoring Data to create a user profile, we do so under a username.

To enhance the Internet experience on its Websites, Kabuse may use various Internet technologies such as ‘cookies,’ ‘action tags,’ ‘web bugs,’ ‘.gif tags,’ and ‘JavaScript’ (together, “Tracking Tools”). Tracking Tools are files or tools that are placed on your computer in order to identify your Web browser and the activities of your computer on our Websites. Kabuse uses these technologies to customize and enhance the Internet experience of individual users. When you revisit a Website, Kabuse may recognize you by a Tracking Tool and customize your experience accordingly. For example, once you have completed the registration process, a cookie will be used to avoid having you register again. You may decline Internet cookies, if any, by using the appropriate feature of your Web browser software, if available. If cookies are disabled, however, all features of a Website may not operate as intended. Information about the procedure you are required to follow in order to disable cookies can be found on your Internet browser provider’s website.

We believe Tracking Tool technologies add value to the user experience, and the information resulting from these technologies is not sold or otherwise made available to third parties by Kabuse.

Use of Personal Data Collected

Kabuse may use Personal Data it collects for editorial and feedback purposes, marketing and promotion, statistical analysis of users’ behavior, product development, delivering products and services, providing customer support, customizing and improving the content and layout of its Websites, completing business transactions, administering individual accounts and meeting government regulatory requirements such as sales tax collection. Monitoring Data may be used for internal or external purposes such as researching and identifying market segments and needs. Kabuse will not disclose to third parties any of your Personal Data, except to the extent necessary to comply with applicable laws, rules, or regulations, with your express permission, or to preserve Kabuse legal rights in the Websites’ content. Kabuse reserves the right to transfer such information within the group (the details of which can be found on the www.kabuse.com website), to successors to the relevant portion of any of Kabuse businesses, or to independent contractors it engages to assist with or perform on Kabuse behalf any of the foregoing activities. In addition, Kabuse reserves the right to use Personal Data to contact you regarding your account status and changes to the User Agreement, this Privacy Policy, or any other policies, agreements or transactions relevant to your use of any of the Websites. Kabuse will take reasonable steps to maintain the integrity of the collected data so that it is reliable and appropriate for the foregoing uses.

Your Choices Regarding Personal Data Collection and Use

You may “opt-in” to having your Personal Data used by Kabuse to send promotional correspondence to you now by checking the appropriate box at the end of the User Agreement, or at any time in the future by contacting Kabuse via postal mail, e-mail, or telephone at the address below. Except as described in the paragraph above, Kabuse will not share any Personal Data with a third party without giving you the opportunity to “opt-in” and give or deny us permission to do so.

Upon request via postal mail, e-mail, or telephone, Kabuse will provide to you a summary of any Personal Data retained by Kabuse regarding you. You may modify, correct, change or update Personal Data that Kabuse has collected via any of the Websites. You may refuse to have your Personal Data processed by Kabuse or you may request that your Personal Data be anonymised, blocked (so that Kabuse continues to hold your Personal Data but temporarily refrains from processing it) or removed from Kabuse database by contacting Kabuse via postal mail, e-mail, or the telephone number indicated below, provided, however, that such requests may require you to register again with Kabuse in the event you later wish to access any of the Websites. You may ask Kabuse to certify that it has notified the entities to whom your Personal Data has been transferred of any such changes to or removal of your Personal Data. You should be aware that it may not be technologically possible to remove or verify each and every record of information you have provided to us from our system. The need to back-up our systems to protect information from inadvertent loss means that a copy of your Personal Data may exist in archived systems. However, promptly after receiving your request, all Personal Data stored in databases we actively use and other readily searchable media will be updated, corrected, changed, deleted or confirmed to you, as appropriate, as soon as reasonably practicable.

Links

Each Website may contain links to other Internet websites. Kabuse does not endorse, and is not responsible for, the privacy practices or the content of these websites. You should review the applicable privacy policies in connection with your use of such third party websites.

Security Measures

Kabuse has established reasonable precautions to protect collected Personal Data from loss, misuse, unauthorized access, disclosure, alteration or destruction, which include contractual, administrative, physical, and technical steps. Technical measures include use of firewall protection and encryption technology where appropriate. Although Kabuse takes reasonable precautions to assess the reliability of such technology, it relies on the statements of the vendors of those products and services as part of its security evaluation. Please note that while Kabuse has endeavored to create a secure and reliable site for users, the confidentiality of any communication or material transmitted to/from Kabuse via any of the Websites or e-mail cannot be guaranteed.

Export of Personal Data

You acknowledge and consent to the fact that Personal Data provided by you or collected by us through your use of any of the Websites is stored and processed by us in the United States where data protection laws may not afford the same level of protection as those of the country in which you are located (this is the case for users located in the European Economic Area (“EEA”). You also acknowledge and consent to the fact that we may, at our discretion, store and process such data in other countries (including countries outside the EEA) where data protection laws may not afford the same level of protection as those of the country in which you are located.