Last modified: December 16, 2010

Fluent Mobile Inc. is committed to maintaining the privacy of your personal information when you visit our website, download and use Fluid Mobile™ applications such as Fluent News™, and when we provide products that optimize the mobile marketplace inclusive of ads and app download environments, on behalf of our mobile application provider clients ("Clients"). This Privacy Policy describes how we treat the personal information received about you on this website, in connection with our Fluent News application, and when providing marketing services to application publishers.

Links to Other Content
We frequently make content or services from other websites available to you from links located on our websites or within our applications. These other websites are not subject to this Privacy Policy, and Fluent Mobile has no control over how such websites may use the personal information collected on those sites. We recommend that you review the privacy policy at each such website to determine how that site protects your privacy.

Fluent Mobile Websites and Applications
When you use certain features of our website and applications, we may collect personally identifiable information from you that may include your email address and mobile phone number.

We automatically collect IP addresses, website usage and application usage information from you when you visit our website or use our applications. When you use Fluent Mobile applications, we may also collect your "unique device ID" or "UDID," which is a number uniquely associated with your mobile device. Fluent Mobile cannot use the UDID to identify you personally, this information helps us evaluate how our visitors use our websites and applications, and permits us to enhance those sites and applications.

We may use the information collected about you in the following ways:

• For the purposes for which you specifically provided the information including, for example, to send email/SMS alerts that you have requested.
• To provide advertisers and other third parties with aggregate information about our user base and its usage patterns.
• To allow us to personalize the content and advertising that you and others see based on personal characteristics or preferences.

We may combine the information that we collect from you from Fluent Mobile websites and applications with information that you provide to us in connection with your use of our other products, services and websites.

We use third-party network advertisers, to deliver ads to you on our behalf. These network advertisers may be supplied with or have access to your personally identifiable information solely for the purpose of providing these services to us or on our behalf.

Except as specifically set forth in this Privacy Policy, we will not share your personally identifiable information outside of Fluent Mobile Inc.

We may disclose and use personally identifiable information to resolve disputes, troubleshoot problems, enforce our Terms of Service (for example, when necessary to protect our or a third party’s intellectual property or proprietary rights), or to alert you to changes in our policies or agreements that may affect your use of our application and websites. We may also disclose personally identifiable information when we, in our sole discretion, believe it is necessary or appropriate, in connection with a sale or transfer of some or all of our assets in the application or website, or when we, in good faith, believe that the law requires us to do so.

Fluent Mobile Application Marketing
Fluent Mobile buys mobile advertising space on behalf of certain mobile application providers (Clients). When you click on a Client ad or application link delivered by Fluent Mobile, Fluent Mobile servers receive and store the "unique device ID" or "UDID," which is a number uniquely associated with your mobile device. Fluent Mobile cannot use the UDID to identify you personally, but it does enable us to collect information about the kind of mobile device you use, the operating system for your mobile device, the applications you download from Fluent Mobile Clients, when, how, and how often you use those applications.

We use your UDID and information about Client applications you download to report on the number of unique users who click through Fluent Mobile Client ads, and the number of those users who download Fluent Mobile Client applications as a result of those ads.

We also use your UDID and the information associated with your UDID over time (e.g., the applications you download, when and how you use those applications, and any publisher-provided demographic data) to enhance our services and to select Fluent Mobile Client ads that are most likely to be of interest to you.

Fluent Mobile may use agents and contractors in order to provide our services to Clients. If such agents and contractors have access to your UDID and/or the information associated with your UDID, they are required to protect this information in a manner that is consistent with this Privacy Policy by, for example, not using the information for any purpose other than to carry out the services they are performing for Fluent Mobile. We disclose your UDID and/or the information associated with your UDID over time for the following purposes only:

• To Fluent Mobile Clients when you click on their ad and/or download their application;
• In response to legal process (for example, a court order, search warrant or subpoena);
• When we, in our sole discretion, believe it is necessary or appropriate, in connection with a sale or transfer of some or all of our assets in the application or website, or when we, in good faith, believe that the law requires us to do so.
• In other circumstances when necessary either to protect the rights or property of Fluent Mobile, Fluent Mobile Clients, and third parties.

Cookies
Some of the advertisers and Web analytics firms used on our site may place "tracking cookies" on your computer. These are small text files that can tell such companies what you are doing online, even though they usually don’t record your name or other personally identifiable information. These cookies are used by these companies to try and match ads to a user’s interests. They are used all over the Web. Fluent Mobile may place cookies on your computer, in addition to any placed by advertisers.

You can change the preferences or settings in your Web browser to control cookies. The Help menu on the menu bar of most browsers will tell you how. In some cases, you can choose to accept cookies from the primary site, but block them from third parties. In others, you can block cookies from specific advertisers, or clear out all cookies.

Children’s Privacy
Fluent Mobile does not knowingly collect information from children under 13.

Security
The personally identifiable information we collect about you is stored in limited access servers. We will maintain safeguards to protect the security of these servers and your personally identifiable information.

Transfer to the U.S. or other countries
Your information may be stored and processed in the United States or any other country where Fluent Mobile has facilities, and by using our website or application, you consent to the transfer of information outside of your country.

Changes to this Privacy Policy
When we make any material change to this Privacy Policy, we will inform you by posting a notice on the home page of this site that the policy has been updated and by changing the date on this page noting when the policy was last updated.