Summary of the UPGLLC’s Privacy Policy 

                   

§   INTRODUCTION –

The Introduction identifies the basic UPG Services covered by this Privacy Policy and provides a brief overview of what this Policy covers.

§   SUBMISSION AND COLLECTION OF INFORMATION –

This section addresses the types of information that UPG collects directly from users and the collection of non- personally identifiable information via cookies and related technologies by, and on behalf of, UPG and third parties.

§   NOTICE AND CHOICE –

This section provides information on users’ options to control how their information is collected and used, how UPG notifies users about future Privacy Policy changes, where UPG stores data, and third-party websites and services that may link to the UPG Services.

§   USE AND DISCLOSURE –

This section describes how UPG uses your information to provide and manage the UPG Services, including when UPG may disclose your information to third parties that assist UPG in providing those services.

§   SECURITY –

This section describes UPG’s security measures.

§   USER CONTROL AND ACCOUNT CANCELLATION –

This section informs users how to access and change their personal information stored by UPG, and how to cancel their accounts.

§   CONTACT US –

This section instructs users how to contact UPG.

 

1.   INTRODUCTION

Universal Phoenix Group, LLC, through itself and its subsidiaries (“UPG” or “we”), operates several websites, including, but not limited to www.upg-corp.com, www.teammenfes.com, www.mud-  ld.com,  www.menfesinteractive.com (together, the “UPG Sites”), which provide a collection of online

services, including, without limitation, various online games, online forums, social networking features, personalized content and branded programming, and any other features, content or applications offered from time to time by UPG in connection with UPG’s business, including when the UPG Sites are accessed via the Internet, mobile or other device (collectively, the “UPG Services”).

This Privacy Policy applies to all “users,” including both those who use some of the UPG Services without being registered and “Members” who have registered with UPG to create a profile, or otherwise  participate in an activity on the UPG Services. The Policy describes UPG’s collection and use of users’ personal information (e.g., information that identifies a specific person, such as full name or email address) where that information is not otherwise publicly available on the UPG Services. It also describes generally UPG’s practices for handling non-personally identifiable information (e.g., interests, demographics and site usage) to the extent such information is associated with a particular user or user account.

2.   SUBMISSION AND COLLECTION OF INFORMATION ON UPG SERVICES

User Submitted Information

Registration Information is the information that users provide to UPG: (a) to register for certain UPG Services, for example, participating in online gaming, supplying user reviews, or participating in chat rooms; or (b) to purchase products or services from or through the UPG Services. Registration

Information may include one or more of the following: full name, email address, gender, date of birth, postal address, telephone number and credit card number.

My UPG Profile Content consists of information Members may choose to add to their My UPG profile, including a Member’s profile picture or avatar, user name, vanity URL, stated location, gender, online addresses or gamer profile (i.e., gaming name, clan affiliation, game play statistics, and the like and free- form content such as a Member’s Bio, stream, blog, friends, games, photo albums, videos, audio conversations, and similar information). You can control which UPG users can post to or comment in your My UPG Profile Content by adjusting your My UPG Profile Settings. My UPG Profile Content is always public, which means it is available to everyone and may be displayed in search results both on the UPG Services and on external search engines.

Public Site Content consists of information you disclose in public areas of an UPG Site, such as the [My UPG Profile Content, Member home pages], message boards, chat rooms and other community areas. Please be aware that Public Site Content is always public and available to everyone and may be displayed in search results both on the UPG Services and on external search engines.

Correspondence consists of information you disclose when you contact UPG, for example, for customer service purposes.

UPG Collected Information

UPG Site Activity Information. When users access the UPG Services, we may collect certain non- personally identifiable information about those visits. For example, in order to permit your connection to the UPG Services, our servers receive and record information about your computer and browser,  including potentially your IP address, browser type, and other software or hardware information. If you access the UPG Services from a mobile or other device, we may collect a unique device identifier assigned to that device or other transactional information for that device in order to serve content to it. We also may use cookies and other tracking technologies (including browser cookies, pixels, beacons, and Adobe Flash technology including cookies), which are comprised of small bits of data that often include  an anonymous unique identifier. Websites send this data to your browser when you first request a web page and then store the data on your computer so the website can access information when you make subsequent requests for pages from that site. We may use these technologies to collect and store information about your usage of the UPG Services, including your actions while using the UPG Services, such as pages you have visited, search queries you have run, advertisements you have seen, as well as other anonymous, non-personally identifiable information. UPG may also use cookies and similar tools to relate your use of the UPG Sites to personal information obtained from you or a third party. For example,  if you’ve asked us to provide you information about our upcoming products or promotions, cookie and/or click stream data about your activities on the UPG Sites may allow us to limit the materials we provide   you to items we think you will find interesting, based on your prior online activities and preferences.

However, we will not coordinate your personal information and cookie or click stream information in this manner without first obtaining your express affirmative consent.

Third parties that support the UPG Services by serving advertisements or providing services, such as allowing users to share content or tracking aggregate site usage statistics, may also use these

technologies to collect similar information. UPG does not control these third-party technologies and their use is governed by the privacy policies of third parties using such technologies. For more information about third-party ad networks that use these technologies, see www.aboutads.info.

Most browsers are initially set to accept cookies, but you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information (e.g., http://windows.microsoft.com/en-US/windows-vista/Block-or-allow-cookies). Users can manage the use of Flash technologies, including cookies, with the Flash management tools available at Adobe’s website, seehttp://www.adobe.com/products/flashplayer/security/privacy_policy/faq.html.

Please note that by blocking any or all cookies you may not have access to certain features or personalization available through the UPG Services.

Third Parties. To improve the quality of the UPG Services, we may supplement the information we collect with information from third parties. If you access the UPG Services through a third-party connection or log-in, we may also collect your user ID and/or user name associated with that third-party service, or any information you have made public in connection with that service or which the third party shares with partner services.

3.   NOTICE & CHOICE

Means of Notice. This Privacy Policy is the primary means by which UPG provides you with notice about its collection and use of your personal information. UPG will not use your personal information in a manner different from what is described in this Privacy Policy without your permission.

Privacy Policy Changes. UPG may modify this Privacy Policy as necessary. If we make material changes to this Privacy Policy that expand our rights to use your personal information, we will notify you to seek your consent through email or a prominent posting on the site.

Location of Data. The UPG Services are hosted in the United States. If you are a user located outside the United States, you understand and consent to having any personal information you provide transferred to and processed in the United States. U.S. data protection and other relevant laws may not be the same as those in your jurisdiction. As a result, please read this Privacy Policy with care.

Linked Websites or Services. The UPG Services may also be linked to sites or services operated by UPG affiliates (i.e., that are part of the News America Group: “Affiliated Companies”) or third parties, and may carry advertisements or offer content, functionality, games, newsletters, contests or sweepstakes, or applications developed and maintained by third parties. UPG is not responsible for the privacy practices  of any such third parties, and once you leave the UPG Services via a link, enable a third-party service, or click an advertisement, you should check the applicable privacy policy of the third-party site. Additionally, although all Affiliated Companies adhere to the News Corporation corporate Privacy Principles, users  who visit an Affiliated Company site should still refer to its separate privacy policy, which may differ in some respects from this Privacy Policy.

4.   USE AND DISCLOSURE

Information Made Public Through Use of UPG Services and User Privacy Settings

Public Site Content, including, without limitation, the My UPG Profile Content, is always publicly available to anyone, including other users, search engines, advertisers, third-party application developers, and anyone else with access to the UPG Services. You control what information you add to your My UPG Profile Content. You may also restrict which other UPG users can post content or comments to your My UPG Profile through your My UPG Profile Settings.

UPG’s Use and Disclosure of Information

We only share your non-public personal information with non-affiliated third parties when we believe sharing is permitted by you or authorized by this Privacy Policy. In addition, UPG may share your personal information with Affiliated Companies.

We use the information we collect from and about users for the following purposes:

To provide and manage the UPG Services. We use the information we collect from and about users to provide the UPG Services and features to you including to measure and improve those services and features, to personalize your experience by delivering relevant content, advertising and marketing messages, to allow you to participate in online games, contests or promotions, to enable you to communicate and share with other users, and to provide you with customer support and respond to inquiries. We may use aggregated, anonymous data about use of and activity on the UPG Services to assist us in this regard and such data is not subject to this Privacy Policy.

To allow third-party service providers to assist us in providing and managing the UPG Services. UPG may make your non-public personal information available to certain third-party service providers, such as contractors, agents or sponsors, who help us manage or provide the UPG Services. These outside  service providers are required to protect non-public personal information entrusted to them and not use it for any other purpose than the specific service they are providing to UPG.

To allow other users to find you. In order to locate My UPG Members that a user may already know in the physical world and/or want to get to know in the online world, UPG allows users to search for Members using information the user already knows, such as username, full name, or gamer profile, and identifies users matching that search information.

To deliver relevant advertising. We may use the information you provide to us, and information we collect about your use of the UPG Services through cookies and other technologies, to assist us in delivering you relevant ads when you visit the UPG Services. We may work with third-party advertising networks and advertisers who help deliver these ads to you. We do not share your non-public personal information with these third parties, but we may share anonymized or aggregated information with them to improve the relevancy of the ads you see on the UPG Services. As noted above, these third-party advertising  networks and advertisers may also use cookies and similar technologies to collect and track non- personally identifiable information such as demographic information, aggregated information, and Internet activity to assist them in delivering advertising that is more relevant to your interests. To find out more about third-party online advertising and to opt out of this type of advertising, visit the Network Advertising

Initiative website located at http://www.networkadvertising.org/managing/opt_out.asp.

To contact you. UPG may periodically send promotional materials (e.g., newsletters) or notifications related to the UPG Services to the email address you provided to us at registration or to your account. If you want to stop receiving promotional materials from UPG, you can follow the unsubscribe instructions at the bottom of each email. There are certain service notification emails that you may not opt-out of as long as you are a Member, such as notifications of changes to the UPG Services or policies.

To protect the rights of UPG and our users. There may be instances when UPG may disclose user information without providing notice or choice, including situations where UPG has a good faith belief that such disclosure is necessary in order to: (i) protect or defend the legal rights or property of UPG, our Affiliated Companies or their employees, agents and contractors (including enforcement of our agreements); (ii) protect the safety and security of users of the UPG Services or members of the public;

(iii) protect against fraud or for risk management purposes; or (iv) comply with the law or legal process.

To complete a merger or sale of assets. If UPG sells all or part of its business or makes a sale or transfer of its assets or is otherwise involved in a merger or transfer of all or a material part of its business, UPG may transfer your information to the party or parties involved in the transaction as part of that transaction.

5.   SECURITY

UPG uses commercially reasonable administrative, technical, personnel and physical measures to safeguard user information and credit card information in its possession against loss, theft and unauthorized use, disclosure or modification.

6.   ACCESS, REMEDIES AND COMPLIANCE

User Control. To access, correct or update your account or other personal information such as your city or interests, please use the “My Account” link on the UPG Site on which you are registered. You may unsubscribe from any premium UPG Service for which you have previously subscribed by following the instructions included in the UPG Terms of Use: http://menfesinteractive.com/termsofuse. Remember that  even after you cancel your account, copies of some information from your account may remain viewable  in some circumstances – where, for example, you have shared information with a third-party application  or website. We may also retain backup information related to your account on our servers for some time after cancellation for fraud detection or to comply with applicable law or our internal security policies.

Because of the nature of caching technology, your account may not be instantly inaccessible to others, and there may be a delay in the removal of the content from elsewhere on the Internet and from search engines.

7.   CONTACT US

If you have questions about this Privacy Policy, please contact UPG via our online form, available at:support@upg-corp.com or write to us at:

Universal Phoenix Group, LLC

 

Attn: menfesinteractive.com

POST OFFICE BOX 3171

Atlanta, GA 30302