Last Modified: May 2007

Welcome to www.saddleclubmobile.com (the "Website") operated by GS New Media, Inc., a Canadian corporation located at 119 Spadina Avenue, Toronto, Ontario M5V2L1 ("GS", "we", "our", or "us"). This privacy policy is intended to inform you ("you" or "your") about how your personally identifiable information (such as name, address, telephone number, email address) ("Personal Information”) and other information is collected and used by us in operating the Website.

How does the Website work?
The Website offers visitors the opportunity to browse the Website, and adults to purchase certain products such as ring tones and wallpapers for use with their mobile phones.  By using the Website, you consent to the collection and use of your Personal Information by GS as described herein. GS reserves the right to change how we handle the information we collect through the Website at any time. We will update this privacy policy to reflect any changes in our privacy collection and handling practices, and will indicate that changes to this privacy policy have been made by updating the “Last Modified” date (above) each time any such change is made.  Such changes will take effect immediately once they are posted to the Website.  You agree to review this Privacy Policy periodically to be aware of such modifications.  

What type of Personal Information does GS collect from you?
GS cares about the integrity of your Personal Information.  GS does not require you to provide us with any Personal Information in order to use the Website. However, if you wish to purchase products through the Website, GS will collect your mobile phone number and the products you purchase will be delivered to you at such number.  This is the only Personal Information that GS collects from visitors to the Website and such Personal Information will be used only to process transactions requested by such visitor.  After we have used your Personal Information for such a purpose, it is deleted from our records.  Unless you provide Personal Information to GS through the Website, we will not collect any Personal Information from you.
In order to purchase products offered on the Website, will also request certain non-Personal Information like the name of the mobile phone carrier and the model of mobile phone for which such products will be used.  The policies regarding requested purchases made by you through the Website are explained in greater detail in our Terms of Use <www.saddleclubmobile/term>.

What are our policies regarding Children?
GS operates the Website in accordance with the Children’s Online Privacy Protection Act of 1998 and its implementing rule (“COPPA”).  COPPA prohibits website operators from collecting Personal Information from children under the age of thirteen (13) without first obtaining verifiable parental consent or meeting one of the exceptions of the statute.  Even though GS does not authorize Website visitors to purchase products offered through the Website who are under the age of eighteen (18) or a minor in their state of residence, GS is careful to comply with COPPA because the Website promotes the popular children’s television program “Saddle Club” and is therefore likely to be used by children under the age of thirteen (13), and GS does not authenticate the age of visitors who purchase products through the Website.  
COPPA enables website operators to collect Personal Information from children under the age of thirteen (13) if such information is used only for purposes of responding to a one-time request from such child.   In accordance with this policy, we use the mobile phone number submitted by a visitor purchasing products on the Website only for the purpose of fulfilling the transaction ordered by such visitor.  Once the transaction has been completed, we delete the mobile phone number from our records.  We do not collect more Personal Information from visitors than is required in order to fulfill their requests.

Do we share your Personal Information with third parties?
We will share your Personal Information with our service providers and your mobile service carrier (as indicated by you) in order to fulfill requests made by you.
We will also release your Personal Information (while it is still being used to fulfill your requests and prior to its deletion by us) to third parties if we believe the release of such information is necessary (i) to comply with the law (e.g. a legal process or a statutory authorization), or (ii) to protect or enforce our rights.

What other information does GS collect?
We also may collect anonymous and aggregate information from you about your preferences in navigating the Website by using cookies, action tags and other methods. Cookies are small text files that identify your computer. We may use cookies to, among other things, monitor Website usage, customize Website features, identify your computer's operating system and browser, and complete transactions. An action tag is a small, graphic image on a webpage that is designed to allow a website owner or a third party to monitor who is visiting a website by collecting the IP address of the computer to which the tag is sent, the URL of the webpage that the tag comes from and the time that such webpage was viewed. Tags may be associated with cookie information.
If you do not want us to track such non-Personal Information about you, you can set your browser to warn you before accepting cookies and refuse cookies when your browser alerts you to their presence. You can also adjust the settings in your browser to refuse all cookies. Please keep in mind that if you make such adjustments, you may not be able to use certain features of the Website.

How is Personal Information protected?
While we take precautions to safeguard Personal Information while it is under our control, we cannot guarantee that such information will not be lost, disclosed or accessed by accidental circumstances or by the unauthorized acts of others.  Please note that once your Personal Information is transferred to your mobile carrier by us, we no longer have any control over the use of such Personal Information, and the use of your Personal Information after such transfer will be subject to the privacy practices of your mobile carrier.

Does GS provide links to other websites?
GS and/or third parties may provide links to other websites or resources of possible interest to you.  Because we do not control unaffiliated websites to which we provide links, the collection and use of your Personal Information and other information by such websites shall be subject to the policies and procedures of such websites and not this privacy policy. 

Do we have a mechanism to address questions and complaints about the handling of information that we collect?

If you have questions or concerns about any of our information collection or handling practices, or if you wish to change or remove any Personal Information provided to us, please contact us by e-mail at contact@saddleclubmobile.com or by postal mail at GS new media, 119 Spadina Avenue, Toronto, ON M5V 2J4.