VerbaLearn is committed to providing a fun, enriching, and safe website for people of all ages. We are dedicated to safeguarding any personal information collected by our site. We ensure that our privacy policy and our information practices adhere to the U.S. Department of Commerce's Safe Harbor Principles. Because many of the visitors to this site are teenagers or younger students, we take care that our content is suitable for them. We do not ask anyone to disclose more personal information than is necessary for them to participate in any particular activity, and we take efforts to prevent anyone from obtaining contact information from our site.

To help ensure a rewarding online experience for our visitors and for the parents, grandparents or sponsors of our visitors we provide you with this summary of our information practices.

As we continue to offer our visitors new types of content and services, we may modify our practices from time to time. However, we will treat all personal information we collect in accordance with the privacy notice in effect at the time the information is collected.

1. The Information We Collect

At VerbaLearn, the only personally identifiable information we collect from users is a name and valid email address.

When signing up, we may ask users to provide additional information that is not personally identifiable, such as zip code or information regarding your studying habits or history.

We do not knowingly collect names and email addresses from children under the age of 13.

Additionally, when visitors come to our site, we automatically collect some non-personally identifiable "computer" information, such as the user's "IP Address" and the web browser (e.g., Firefox, Internet Explorer) being used.

Finally, to participate in certain activities we collect personal and financial information from members or sponsors as set out in Section 6 of this Privacy Policy. At VerbaLearn, we respect your personal privacy and we will never use your confidential financial information for any purpose other than processing your payments. The personal and financial information that you enter to make a purchase from VerbaLearn is not stored by VerbaLearn, but only by our financial institution for the purpose of processing credit card payments. This information is safeguarded with high, bank-level security and all credit card processing is done using completely secure, above industry standard encryption.

2. How We Use the Information

We use a visitor's email address internally to track usage, progress, give updates, and ensure users are following the site's Terms and Conditions.

We sometimes use the non-personally identifiable information that we collect to improve the design and content of our site, or the personally identifiable information to personalize each unique visitors' experience on VerbaLearn. We also may use this non-personally identifiable information to analyze site usage, attract new clients, as well as to offer products, programs, or services.

We will disclose information we maintain when required to do so by law, for example, in response to a court order or a subpoena. We also may disclose such information in response to a law enforcement agency's or other public agency's request or if we feel that such disclosure may prevent the instigation of a crime. Finally, we may disclose information to a prospective purchaser of VerbaLearn acquiring all or part of the assets relating to VerbaLearn, to the extent permitted by law.

We may transfer personal information and store it outside of the jurisdiction in which a member of VerbaLearn is located and, although such personal information will be protected by the security measures described in this privacy policy, it will be also be subject to local laws.

We will not use or transfer personally identifiable information in ways that are materially different from the ones described above without also providing notification of such practices and obtaining consent for any materially different uses.

3. Collection of Information for Third-Party Sites and Sponsors

VerbaLearn is proud of the fact that we allow only minimal and non-invasive 3rd party solicitation or sponsors to advertise to our users and all of our ad categories have been previously approved for all audiences. NO PERSONALLY IDENTIFIABLE INFORMATION IS GIVEN TO ANY 3RD PARTY SOLICITOR.

4. Cookies

VerbaLearn uses a software technology called "cookies." Cookies are small text files that we place in visitors' computer browsers to store their preferences. Cookies themselves do not contain any personally identifiable information. Although cookies could enable us to relate a visitor's use of this web site to personal information that a visitor has provided, such as an email address.

5. Security

We have put in place appropriate physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect on our site.

6. Financial Information

If you decide to sponsor yourself, your child, or anyone else, additional information will be required at the time of purchase. That information is not stored by VerbaLearn and is only stored by our financial institution for the purpose of processing payments. That information is safeguarded with high, bank-level security and it will never be used for any other purposes.

7. Guardian or Users Over 18 Review of Information

Guardians or users over 18, please send an email care of our Privacy Manager to support@verbalearn.com if you would like to do any of the following:

Access the personally identifiable information that VerbaLearn has collected online from you or your child, correct factual errors in such information, request to have this information deleted, request that we no longer collect or maintain such information, or request that we do not disclose any of a users information to a 3rd party.

Please be sure to include your email address and a telephone number where we can reach you. To protect you or your child's privacy and security, we will take reasonable steps to help verify your identity before granting you access to the personal information that we collect and maintain about you or your child.

8. Contact Us

Contact VerbaLearn should you have any inquiries regarding the privacy policy and/or practices herein.

If you have any questions please contact us through any of the following methods.

• Email: feedback@verbalearn.com
• Phone: (617) 535 - 9707
• Mail: VerbaLearn, Inc. 45 Jackson Dr. Acton, Ma 01720

9. Effective Date

The privacy policy set out above is effective as of 11/18/08, and applies to all information previously obtained by VerbaLearn. VerbaLearn reserves the right to change its privacy policy at its sole discretion. VerbaLearn users will be informed of any such change by VerbaLearn posting a new privacy policy on the VerbaLearn website. The effective date of any change of privacy policy will be clearly marked.