Rules of LuckySurf

• OFFICIAL RULES
• TERMS AND CONDITIONS

PRIVACY POLICY

The www.luckysurf.com website is owned and operated by Mediastay North America 350 Sansome Street, Suite 740 – San Francisco, CA 94104 ("Mediastay").
This privacy policy describes how, on the www.luckysurf.com website (“Website”), Mediastay collects, uses and shares Personally Identifiable Information and Non-Personally Identifiable Information obtained from and about individuals who visit the Website. Mediastay respects the privacy of persons who choose to visit the Website and is committed to making the Website a safe and secure environment.

I. COLLECTION OF INFORMATION

A. Personally Identifiable Information.

• 1. Personally Identifiable Information (“PII”) is information that identifies you or can be used to identify or contact you which is collected via the Website. To register with the Website (and establish a Game Account, which is required to play the LUCKYSURF Game and otherwise use the Website), the only PII that must be provided is one's first and last name and e-mail address; and, a unique password must be created. Additionally, if a registered individual wins certain prizes in an installment of the LUCKYSURF Game and/or he/she wishes to redeem accrued Luckypoints for awards via the Luckypoints Awards area, he/she will also be required to provide his/her residential address and telephone number. Note also that for the redemption of Luckypoints for awards, sales and shipping records will be generated and maintained by Mediastay. Mediastay does not require more PII than is reasonably necessary to participate in particular activities on the Website or to use the Website effectively. But, to use the Website and play the LUCKYSURF Game, a person must register (and establish a Game Account) and provide his/her first and last name and e-mail address as well as create a password.
• 2. Optional Information. In certain areas and/or for certain activities on the Website, registered individuals may be asked for additional personal or demographic information, some of which may be PII. Provision of such additional information is completely optional and your decision whether (or not) to provide such information will NOT affect your ability to participate in the LUCKYSURF Game or otherwise use the Website (with the possible exception of usage of the designated area and/or participation in the specified activity on the Website related to the collection of such Optional Information).
• 3. THIS WEBSITE IS INTENDED FOR USE ONLY BY PERSONS 18 AND OVER. MEDIASTAY WILL NOT KNOWINGLY REQUEST PII FROM PERSONS WHO ARE YOUNGER THAN 18.
• 4. The Website is intended for use exclusively by U.S. citizens. Our computer systems are based in Europe. Persons who are not U.S. citizens should NOT disclose any PII on the Website.

B. Non-Personally Identifiable Information.

• 1. Non-Personally Identifiable Information (“Non-PII”) is information that, by itself, CANNOT be used to identify or contact you. Examples of Non-PII are your date of birth, title, zipcode, certain responses to surveys and questionnaires (e.g., how often you visit the supermarket), your IP address, browser types, domain names, or other anonymous statistical data involving use of the Website. Certain Non-PII (specifically, date of birth, gender and zipcode) is required as part of the registration process in order to establish a Game Account. The provision of other non-PII is optional (see Clause IA §2).
• 2. Non-PII will also be collected PASSIVELY, via cookies or web beacons. Cookies are files or pieces of information that are stored by your browser on your computer's hard drive. A cookie records your preferences in using the www.luckysurf.com Website to facilitate your use of the Website. Mediastay may use cookies to track unique visitors to the Website; to track who has used certain areas of the Website, and the path used to get to those areas; to track Non-PII about users of the Website, the browser used, and to allow Mediastay to create data reports for internal use and for use by third parties. Mediastay will also use cookies to collect or otherwise record Non-PII on the Website which will be combined with PII provided by registered individuals to create profiles of such individuals (see Clause IIC).

YOUR COMPUTER MUST BE CONFIGURED TO ACCEPT COOKIES IN ORDER FOR YOU TO REGISTER WITH THE WEBSITE, ESTABLISH A GAME ACCOUNT AND USE THE WEBSITE. IF YOU DO NOT WISH TO HAVE YOUR COMPTUER ACCEPT COOKIES, DO NOT USE THE WEBSITE. If you are using a public access computer that is configured not to accept cookies, you will NOT be able to register with the Website, establish a Game Account or use the Website. Web beacons (also known as clear GIFs or action tags) are a web technology, used in conjunction with cookies, which enable Mediastay to track Website usage information, such as the number of times a given web page has been viewed. Web beacons are invisible to you and (unlike cookies) are not placed on your computer. Web beacons, which can be “read” by cookies, may be embedded in certain areas of the Website, including advertisements on the Website. Mediastay may use web beacons for tracking Website access and usage as well as to log Non-PII provided by users, so that Mediastay may create internal and external reports regarding Website usage. Mediastay does not use web beacons to collect or otherwise record any type of PII provided by or about any Website visitor.

II. HOW PERSONALLY IDENTIFIABLE & NON-PERSONALLY IDENTIFIABLE INFORMATION ARE USED

A. PII.

Mediastay may use PII collected in conjunction with Website registration, participation in an installment of the LUCKYSURF Game, collection and redemption of Luckypoints in the Luckypoints Awards area or other activities as follows:

• To register you for the Website and establish your Game Account, including transmission of an e-mail message to confirm the validity of the e-mail address provided by you at time of registration.
• To allow you to participate in an installment of the LUCKYSURF Game (including sending you a confirmation e-mail message with all Game grids played by you on a single day of the Game; after the Draw for an installment of the LUCKYSURF Game has been conducted for a given day, sending you an e-mail message with the winning
• numbers for that day's Draw; and in the event that you are a potential prize winner, sending you an e-mail message advising you of such status) as well as to otherwise verify your compliance with the Official Rules for such installment of the LUCKYSURF Game.
• To allow you to participate in the Luckysurf Awards area (including collection of your residential address and telephone number in conjunction with fulfillment of requests to redeem Luckypoints for awards) as well as to verify your compliance with the Terms & Conditions of the Luckypoints Awards area.
• To enable your use of certain areas of the Website and your participation in other activities on the Website (e.g., surveys and questionnaires) and to verify your compliance with the applicable requirements to use such areas and/or to participate in such activities.
• To inform you, via e-mail message, of upcoming installments of the LUCKYSURF Game, special prizes in the current installment of the Game, other games, offers and/or goods/services from Mediastay that may be of interest to you.
• To personalize and enhance the Website and your experience in using the Website as well as to send you personalized information about the Website via e-mail.
• For internal research reports to be used with the objective of improving the Website.
• To contact you for feedback regarding Mediastay, its advertisers or business partners.
• To ensure that Mediastay fully complies with all applicable laws.

PII which you disclose WILL be shared with third parties who may administer the Website (and/or a given activity on the Website) for Mediastay (and/or Mediastay's own personnel) as well as shipping companies that may deliver awards (from the Luckypoints Awards area) and/or prizes (from an installment of the LUCKYSURF Game). Such third parties (and/or Mediastay personnel, as appropriate) will only receive the PII that is absolutely necessary for the third party (and/or Mediastay personnel) to be able to fully perform its assigned function; and, the third parties (and/or Mediastay personnel) will be contractually bound to only use the PII for authorized purposes only as well as to maintain its confidentiality. Mediastay will inform you when the PII is being collected that such collection is required to participate in the indicated activity or to use a certain, designated area of the Website.

Should you respond to a particular offer from one of Mediastay's advertisers or business partners, Mediastay may also use your PII to provide a report to such advertiser/business partner that identifies who responded to a particular offer. And, if you accept an advertiser/business partner offer, Mediastay may provide the advertiser/business partner with the PII that is necessary for the advertiser/business partner to fulfill that offer. However, should one of Mediastay's advertisers or business partners request your PII for a direct use in marketing or advertising (i.e., to contact you directly, as opposed to Mediastay contacting you on behalf of the advertiser/business partner in question), you will always be given the opportunity to remove yourself from the list and you will NOT be contacted directly by the advertiser/business partner without your prior consent (and your refusal to provide such consent will not interfere in any manner with your use and enjoyment of the Website).

B. Non-PII.

Mediastay may use Non-PII in aggregate form for internal purposes or for creating reports for Mediastay's own use and/or for use by third party advertisers and business partners. Note that Mediastay will not obtain your permission before so using your Non-PII.

C. Profiles.

With the objective of customizing each registered individual's experience in using the Website so that an individual may maximize his/her use of the Website, Mediastay conducts internal research on registered individuals' demographics, interests and on-line preferences/conduct, based on information that registered individuals themselves provide (be it PII or Non-PII) as well as through the use of cookies (see Clause IB §2). Mediastay may combine the information yielded by such sources so as to create profiles about registered individuals which may be specific to a given individual or aggregate in form. Mediastay will only use such information for purposes related to the services offered by Mediastay, its advertisers and business partners. IF YOU OBJECT TO A PROFILE BEING CREATED ABOUT YOU, DO NOT REGISTER FOR THE WEBSITE, ESTABLISH A GAME ACCOUNT OR USE THE WEBSITE.

III. OPT-OUT

A. Generally. Subject to the exceptions set forth in the following subsection of this Clause, at the time Mediastay gathers any PII from you for a specific purpose, Mediastay will give you the opportunity to "opt-out" of allowing Mediastay to use your PII for other purposes, such as sending you future e-mails or advertising or sharing your PII with business partners or advertisers. When you opt-out, Mediastay will refrain from using your PII only for the specific purpose expressly addressed by the opt-out request. If you wish to change your decision to “opt-out” or “opt-in,” click here to inform Mediastay (see also Clause VIII).

B. Exceptions. Mediastay may, in the circumstances set forth in this section, use your PII even if you have notified Mediastay of your desire to opt-out. Mediastay may still use your PII

• For internal purposes, or as may be necessary to administer the Website; for example, sharing that data with those persons or entities that administer the Website for Mediastay.
• To comply with applicable law; for example, but not limited to, compliance with valid legal process such as a search warrant, subpoena or court order.
• In special cases when Mediastay has reason to believe that disclosing this information is necessary to identify or contact you, or bring legal action against you, if, for example, you may be causing injury to or interfering with the Website or Mediastay's rights or property, or the rights of other users of the Website (or otherwise to protect Mediastay from liability), whether your actions are intentional or unintentional.

Finally, your PII may be shared with any successors and assigns Mediastay may have.

IV. SAFETY & SECURITY

If you share your computer or use a computer that is accessed by the general public, always remember to sign off and close your browser window when you have finished your session. This will help to ensure that others cannot access your PII. Mediastay takes steps to help ensure that all information provided by you, whether PII or Non-PII (as well as the profile that has been created about you), is treated securely. Regardless of the precautions taken, no data transmission over the Internet, however, can be guaranteed to be totally secure. While Mediastay tries to protect your PII and the information comprising your profile, Mediastay cannot guarantee the security of any information you transmit to Mediastay.

Your use of the website and provision of information (including but not limited to PII) to Mediastay is solely at your own risk and Mediastay makes no representation, warranty or guarantee as to the safety or security of your information (including PII and the profile that has been created about you).

V. CO-BRANDED MICROSITES

Web pages and/or micro websites may be included within the www.luckysurf.com Website and may be co-branded with third party names, logos, and/or properties, and are operated and maintained by Mediastay. While such third parties are sponsors of these web pages or micro websites, they do not receive from Mediastay any PII collected within those web pages or micro websites (nor will profiles created about registered individuals based on information collected within those web pages or micro websites be provided to such third parties).

VI. THIRD PARTY ADVERTISEMENTS/WEBSITES

Mediastay will include on the Website banner and/or text advertisements for third parties (or for websites operated by third parties) that are not sponsors of and are not affiliated with the www.luckysurf.com Website. Mediastay will attempt to make it obvious when you are leaving the www.luckysurf.com Website and going to a third party website, by opening a new window or otherwise notifying you that you are leaving www.luckysurf.com. However, notwithstanding the clarity or effectiveness of such notification, Mediastay disclaims any and all responsibility for the content, practices, or information practices of the websites operated by these third parties. Your use of such third party websites is solely at your own risk. In addition, these advertisements do not constitute sponsorship, endorsement, authorization or approval by Mediastay of the content, policies, or practices of these websites. All users should check the relevant website's privacy policy in order to understand their policies and practices regarding the collection and use of PII prior to providing any PII on such websites.

VII. CONSENT TO PRIVACY POLICY/CHANGES TO PRIVACY POLICY

By accessing and using this Website, you agree to abide by and be bound by this Privacy Policy; IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, DO NOT USE THE WEBSITE, REGISTER FOR ANY INSTALLMENT OF THE USA LUCKYSURF GAME (OR ESTABLISH A GAME ACCOUNT) OR OTHERWISE PROVIDE ANY PII. Mediastay reserves the right, at any time or times, to change the content of this Privacy Policy. Mediastay will post such changes on the Website. Such revisions to the Privacy Policy will take effect immediately upon publication and, by using the Website (and/or providing PII) after such changes have taken effect (except only as noted below), you agree to the Privacy Policy in such revised form, without caveat or qualification of any kind. It is therefore strongly recommended that you regularly review the Privacy Policy for changes. Notwithstanding the foregoing, if Mediastay decides to use your PII in a manner which is significantly different than as set forth herein (as determined by Mediastay in its sole discretion) or otherwise materially changes this Privacy Policy (as determined by Mediastay in its sole discretion), Mediastay will post a notice of such action on the Website and notify you by e-mail, and you may then decide whether or not Mediastay may use your PII in the new manner.

VIII. ACCESS TO PERSONALLY IDENTIFIABLE INFORMATION/COMPLAINT PROCEDURE

Persons who have registered with the Website may review their PII collected at the Website by Mediastay, North America, at any time. To access your PII for the purpose of reviewing, updating or deleting it, log-in to your Game Account by entering your user ID (e-mail address) and password and click on the “My Account” link. If you have a question, comment or complaint regarding Mediastay's privacy practices, click here or send us a letter at the following address: Mediastay North America 350 Sansome Street, Suite 740 – San Francisco, CA 94104. Please allow approximately (5) business days for a response to your comment/complaint.