Organization Information:

HillClimb Media, Inc.
1333 Second Street, Suite 100
Santa Monica, California 90401
Phone: (310) 394-6400
Fax: (310) 394-6499
Contact Information:

Contact Office: HillClimb Media, Inc.
Contact Name: Matt Polesetsky, SVP, Legal
Phone: (310) 394-6400 Fax: (310) 394-6499 Email: mpolesetsky@demandmedia.com

Corporate Officer Information:

Corporate Officer: Matt Polesetsky, SVP, Legal
Phone: (310) 394-6400 Fax: (310) 394-6499 Email: mpolesetsky@demandmedia.com

Safe Harbor Information:

Signed up to safe harbor 08/21/2009 01:42:37 PM
Next certification 08/21/2010
EU/EEA Countries From Which Personal Information Is Received: United Kingdom
Industry Sector: Information Services - (INF)
Personal Information Received From the EU: HillClimb Media operates a number of Internet web sites. This application pertains solely to the operation of the HillClimb site <ehow.co.uk>. At this time, HillClimb is not seeking Safe Harbor Certification for the web sites that it operates other than <ehow.co.uk>. A copy of the privacy policy applicable to ehow.co.uk is set forth below.

Effective Date: August 18, 2009
We are Hillclimb Media, Inc ("Hillclimb", "we", "us" or "our"), a subsidiary of Demand Media, Inc..
Hillclimb is committed to protecting your privacy and providing a safe online experience for all our users. This Privacy Policy ("Privacy Policy" or the "Policy") sets out how we use and process your personal information (meaning any information about you which is personally identifiable or can be related back to you like your name, date of birth, address, telephone number, email address and queries) ("PII") that we collect about you when you use the services we provide at http://www.ehow.co.uk, which includes all of the ehow.co.uk articles and videos and other services we provide on the website (collectively, the "Site"). Please read the complete Policy below and contact us if you have any questions.
If you are not comfortable with this Privacy Policy, please do not provide us with PII or other information or content or otherwise use the Site.
1. What information may be collected by us, and how is it collected?
Type of Information We Collect. We collect any information you enter on the Site or give us in any other way (such as through an email, survey, or letter). The information that we collect varies depending upon how you use our Site. For example, our account registration process requires that you provide us with your user name, birthday and email address, and that you create and provide us with a password. We may also request other information, such as but not limited to, your actual first and last name, gender, and post code. You may make changes, corrections, or updates to some PII provided through this Site which we use for communications with you, by visiting the "Edit My Profile" page on the Site. We may keep a record of all information that is changed (including deletions) and disclose it for any lawful purpose. We may determine what may be changed (e.g. if we are required to keep track of certain kinds of transactions, you may not change relevant information).
Information in Public Areas of the Site. Please keep in mind that whenever you voluntarily provide information in public areas of the Site, such as the user profile pages or forums, that information can be viewed and possibly used by others. We therefore advise users not to disclose contact information, including phone number, email address, street address or instant messenger address (within these public areas) that they do not wish to share. We are not responsible for PII you choose to submit in these public areas.
Cookies. Like many websites, we use "cookies." Cookies are alphanumeric identifiers that we transfer to your computer's hard drive through your Web browser to enable our systems to recognize your browser. We use persistent, identifying cookies to remember your information and to link your activities to you. While you can take steps to warn off, block or disable cookies, if you do, the Site may not function and appear as we have designed it. Nonetheless, if you want to take these steps, you can do so by following the instructions associated with your browser. For more information about cookies, including controlling and deleting them, please visit the www.aboutcookies.org website.
Our cookies do not collect PII that you provide to us during the registration process, but they do collect other information such as the following:
• the domain name and host from which you access the Internet and the Internet address of the site from which you direct-linked to ours;
• the date and time you access the Site and pages you visit;
• your computer's IP address and information about its operating system, platform and the Web browser type and version you use;
• demographic and other non-personally identifiable profile information about you; and
• information to combat fraud or misuse.
Pixel Tags. In our emails to you, we may use "pixel tags" to determine if your email software or service can display html-formatted email (this helps us optimize the size of our email messages and conserve bandwidth).
Collection of Information by Third Parties. Our Site may include third-party advertising, links to other websites, and other content from third party businesses. The content posted by these parties will be reasonably identifiable as coming from a third party. We do not provide any PII to these advertisers, third-party websites, or other businesses, although on occasion we may mutually share non-personally identifiable (e.g. demographic) information to facilitate delivery of relevant advertisements. These third-party websites, businesses, and advertisers, or advertising companies working on their behalf, sometimes use technology to deliver (or "serve") the advertisements that appear on our Site directly to your browser. They automatically receive your IP address when this happens. They may also use cookies, JavaScript, web beacons (also known as action tags or single-pixel gifs), and other technologies to measure the effectiveness of their ads and to personalize or optimize advertising content. We do not have access to or control over cookies or other technologies that they may use, and the information practices of these advertisers and third-party websites or businesses are not covered by this Policy but are covered by their respective privacy policies. Some, but not all, third party advertising companies provide a mechanism to opt-out of their technology.
Promotions, Sweepstakes, and Contests. From time to time, we may host a promotion, sweepstake, or contest on the Site. You may be asked to provide PII or permit the transfer to a third party of your PII in connection with such promotion, sweepstake or contest. It will be disclosed at the point of collection or transfer who is collecting or transferring the information and whose privacy statement applies, and it will be your choice whether or not you wish to permit such transfer or collection of PII to a third party.
2. What Do We Do With Collected Information?
Use of PII. We use your PII for purposes such as responding to your requests, monitoring and providing the Site, maintaining your account, providing you with advertising and non-advertising content on the Site that we believe would be of interest to you, enforcing our rights and the rights of third parties, and investigating and ensuring compliance with the Terms of Use. We also may use your PII to contact you regarding your account, such as to inform you that you have received a message from another member, or to forward user comments to you about the content that you have posted. We may also email newsletters and similar communications about the Site and, where you have consented to us doing so, we may email marketing messages, including offers from third parties.
Opting-Out. Users can unsubscribe from any newsletters or opt out of various promotional e-mailings they may have consented to at any time by sending an e-mail to the same address, or by clicking on "unsubscribe" links in each of our newsletters or emails. We reserve the right to send you customary business communications such as acceptance/rejection notices regarding content submissions, general system and administrative messages regarding the Site, address confirmations, and transactional information about your account, and we may not offer you the opportunity to opt-out of receiving such communications so long as you are registered with the Site. However, we provide you with the opportunity to choose not to receive other types of communications, such as friend requests or the eHow of the day messages. If you want to update your email address or stop receiving our eHow of the day messages, you may opt out these messages by following the unsubscribe link at the bottom of the email, or visiting the "Edit My Settings" page on the Site. You may also opt-out of receiving email notifications of friend requests on this page.
Use of Other Information. We use non-PII about our users for purposes such as measuring the number of visitors to sections of our Site, making the Site more useful to visitors and delivering targeted advertising and non-advertising content. We use IP addresses to analyze trends, administer the Site, track a user's movement, and gather broad demographic information for aggregate, non-personally identifiable use.
Retention of Information. We retain information for as long as is necessary. We advise that you keep your own, separate back-up records of any of your PII or other information.

3. Does Hillclimb Share Information With Other Parties?
We share information with third parties, but only as described in this Section 3.
• Advertisers and Others. We share non-personally identifiable information with advertisers, service providers, and other persons with whom we conduct business. Similarly, these advertisers, service providers, and other persons may share with us non-PII about you that they have independently gathered or acquired.
• Third Party Services. We contract with affiliated and non-affiliated third parties to provide services to us or to you on our behalf. Examples include providing marketing assistance, providing customer service, sending emails to you, removing repetitive information from customer lists, and analysing data. These third parties may have access to your PII, but will be required to use this information solely in connection with these authorised business activities.
• Business Transfer. As we develop our business, we might sell or buy businesses or their assets, or engage in transfers, acquisitions, mergers, restructurings, changes of control or similar transactions. In such transactions, customer information generally is one of the transferred business assets, and your PII may be subject to such a transfer. Also, in the unlikely event of a bankruptcy, PII may be transferred to a bankruptcy trustee or debtor in possession and then to a subsequent purchaser.
• Affiliates. We may share PII, non-PII and other information with our corporate affiliates. Some of our most significant affiliates are identified on the website of our parent company, Demand Media, Inc. http://www.demandmedia.com. Corporate affiliates are those entities that we control, are controlled by us, or are under common control with us and any joint venture in which any of the controlled entities may participate from time to time. Any use of your information by our corporate affiliates is subject to this Policy or another policy no less protective of your privacy. Conversely, we may obtain information about you from our corporate affiliates or from your visits to other websites that we or our corporate affiliates control.
• Compliance and Safety. We may release user information when we believe release is appropriate to:
• comply with applicable law, and to respond to legal requests and to respond to or otherwise address written complaints of copyright infringement;
• make disclosures under programs intended to prevent potential crimes or investigate persons;
• enforce or apply agreements, including the Terms and Conditions of Use; or
• protect the rights, property, or safety of our Site, our users, or others, including exchanging information with other companies for fraud protection and credit risk reduction.
4. How Secure Is My Information?
Your Obligations. You must protect against unauthorised access to your password and to your computer. Please sign off when you have finished using a shared computer. Your emails to us are not necessarily secure against interception so do not include sensitive information in them. We generally will not ask for passwords in an email and you should assume that if you get such a request, it might be fraudulent. YOU MUST DO WHAT YOU REASONABLY CAN TO ENSURE THE SECURITY OF YOUR PERSONAL INFORMATION.
Our Security Measures. We take reasonable precautions to protect the security of our users' information. We have physical, electronic, and managerial procedures to help safeguard, prevent unauthorized access, maintain data security, and correctly use your information. However, neither people nor security systems are foolproof, including encryption systems. In addition, people can commit intentional crimes, make mistakes or fail to follow policies. Therefore, while we use reasonable efforts to protect your PII, we cannot guarantee its absolute security.
5. What About Links to Other Sites?
The Site contains links to other sites. We are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our Site and to read the privacy statements of every web site that collects your PII. This Policy applies only to information collected by the Site.
6. What Does Hillclimb Do When This Privacy Policy Changes?
We reserve the right to change our Policy at any time. Non-material changes and clarifications will take effect immediately. If we make non-material changes, we will indicate at the top of this page the revised Policy's new effective date. If we make material changes, we will notify you by email or through notice on the home page of the Site, and will also indicate so at the top of this page. The material changes will take effect 30 days after such notice. We encourage you to refer to this Policy at least every 30 days to check for material changes to this Policy.
7. Transfers Overseas
Your PII may be transferred outside of the European Economic Area to us for processing.
Because protecting your privacy is important to us, we adhere to the Safe Harbor Agreement concerning the transfer of personal data from the European Union ("EU") to the United States of America. Accordingly, we follow the Safe Harbor Principles published by the U.S. Department of Commerce ("Principles") with respect to all PII that we receive from the UK. If there is any conflict between this Privacy Policy and the Principles, the Principles will govern with respect to PII from the UK. This Privacy Policy outlines our practices for implementing the Principles, including the types of information we receive, how we use it, and the choices users of our Site have regarding our use of, and their ability to correct, that information.
This privacy statement applies to all PII we receive from the UK (except as noted below). For purposes of this privacy statement, PII includes information that:
• is transferred from the EU to the United States;
• is recorded in any form;
• is about, or pertains to, a specific individual; and
• can be linked to that individual.
It does not include information that pertains to a specific individual, but from which that individual could not reasonably be identified.
We utilize the self-assessment approach to assure our compliance with this Privacy Policy. We periodically verify that the Privacy Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented, and in conformity with the Principles. We encourage interested persons to raise any concerns with us using the contact information below. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the Principles.
8. What If I Have Other Questions Or Concerns About Privacy Or This Policy?
Privacy Concerns. If you have any concern or complaint about privacy at the Site, please contact us at Hillclimb Media, Inc. Legal Department, 15801 NE 24th Street, Bellevue, WA 98008, U.S.A or email us at legal@demandmedia.com. We will do our best to respond to you in a timely and professional manner to answer your questions and resolve your concerns.
In the unfortunate and unlikely event that we cannot resolve your concerns, we have contracted with BBBOnline as a dispute resolution provider. You can contact the BBBOnline at http://www.bbbonline.org/consumer/complaint.asp and follow their guidelines for initiating their dispute resolution procedures.
Customer Services. For customer service matters (including questions relating to this Policy), you may email via our contact form [hyperlink to form here]
Demand Media and eHow are registered trademarks of Demand Media, Inc. in the United States and other countries.
Copyright 2009. Hillclimb Media, Inc.

Privacy Policy Effective: August 18, 2009
Location: company Intranet; soon to be made available on the company website
Regulated by: Federal Trade Commission
Privacy Programs: none
Verification: In-house
Dispute Resolution: BBBOnline as a dispute resolution provider. You can contact the BBBOnline at http://www.bbbonline.org/consumer/complaint.asp and follow their guidelines for initiating their dispute resolution procedures.
Personal Data Covered: on-line
Human Resource Data Covered: No

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Certification Status: Current
Compliance Status:

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