Privacy Policy

Habbo Hotel
Habbo Hotel is a place where people can create their own Habbos, have fun, hang out, play games, and make friends. Because of its interactive content, Habbo Hotel is for users who are 13 years of age or older. We urge everyone, especially teens and their parents to use and enjoy our web site responsibly. At Sulake, Inc. ("Sulake"), we respect your privacy concerns and we understand that visitors to the Hotel need to understand the uses of their personal information. The privacy policy below details the measures taken by Sulake to protect your privacy in connection with your use of www.habbo.com and other sites owned and operated by Sulake ("Sulake Sites"). Sulake does not intend to collect any personal information from children under 13, unless Sulake believes such collection to be permitted by law; please read below for Sulake?s policy with respect to children under 13.

Privacy Policy Overview
At Sulake, we explicitly ask when we want you to give us information that personally identifies you. By personal information we mean individually identifiable information about an individual collected online, including, but not limited to, first and last name, physical or email address, telephone number, instant messenger screen names etc., that is associated with individually identifiable information (Personal Information). For example, we ask you for your name and email address if you wish to register as a user of services found on Habbo Hotel, including, chat areas, games, contests, communities, and/or other message or communication facilities designed to enable you to communicate with Sulake, the online public or with a group (Service).

We may place a text file called a cookie in the browser files of your computer. The cookie enables us to collect information about your visits to our Services. We may use this information to enhance your Services experience and may share some information with our members, vendors, sponsors or others.

We reserve the right to collect and disclose (to our affiliates and to non-affiliate third parties) user behavior and Personal Information to the extent permitted by applicable law, as specifically restricted below or in the Terms of Use (click to link). Notwithstanding anything to the contrary in this Privacy Policy or elsewhere, we reserve the right at all times to disclose any information as necessary to satisfy any applicable law (including, without limitation, the Children's Online Privacy Protection Act), regulation, legal process, law enforcement requests, demands by parties claiming your infringement of their rights or governmental request, to edit, refuse to post or remove any information or materials, in whole or in part, in our sole discretion; or to act in an emergency to protect someone?s safety or legal rights.

We encourage you to use caution and common sense in giving out Personal Information when using Community Services or otherwise. We have no control over third parties to whom you may give Personal Information through the use of our Services.

A Special Note about Children, Childrens Privacy and Our Compliance with the Childrens Online Privacy Protection Act:
In compliance with the Childrens Online Privacy Protection Act (COPPA), we do not intend to collect any Personal Information from children under 13 years of age unless we believe such collection to be permitted by law. Our Services target an audience that is over the age of 13 and some content may not be appropriate for all ages. Parental supervision is recommended. If you are the parent or guardian of a child under 13 and believe that he or she is using the site please contact us at privacy.us@sulake.com. Upon request, the parent or guardian of a child under 13 may review and request the deletion of such child?s Personal Information, as well as refuse to permit the further collection or use of such Personal Information.

Opt-Out and Termination:
We believe that our ability to share your Personal Information with our affiliates, vendors and certain third parties improves our ability to provide services to you. However, if you object to our sharing of your personal information and would like to exercise your rights under the Financial Services Modernization Act and the Fair Reporting Act to limit our use of certain information governed by the mandatory opt-out provisions of those acts (should we ever collect such information and even though we are not governed by those acts), or if you would like to exercise your right under the CAN SPAM Act to not receive future e-mail correspondence from us, except with respect to your prior financial transaction or communications, or as otherwise required by law, please print, complete, sign and return the opt-out letter available at Opt-Out Notice
. Further, if you would like to terminate our use of your Personal Information on a going forward basis (except as it relates to prior financial transaction and communications, there is also a place on that form to select that option. However, this will result in the termination of your Habbo user account(s).

Common Questions and Details on Use of Information:

How is my personally identifiable information used by Sulake and when does Sulake collect my information, including personally identifiable information?
Sulake gathers user information to provide you with a customized experience on our sites. Your user information helps us tailor the content, services, goods and advertising to your current and future needs. For this reason, if you are 13 or older we will ask you to provide personal information when you first sign-up and create your Habbo, visit certain areas of Habbo Hotel?, or engage in activities (e.g. download software, enter a contest, order products, or subscribe to a newsletter). If you choose not to register, you may not have access to areas that require personal identification.

E-mail:
If you register with our site or purchase products from us, from time to time, we may e-mail you with informative messages about our services or third party products and services we believe may be of interest to you, such as new features and services, special offers and updated information. The newsletters may contain code that enables our database to track your usage of the newsletters, including whether the email was opened and/or what links (if any) were clicked. We will combine that information to other information we have about you and may use that information to improve your site experience and/or provide customized e-mail communications to you.

Registration:
When you register, Sulake asks for your e-mail address, a user-selected user name, and other information. Once you are a registered user you can update your profile and may be able to provide additional preferential information. Sulake may also ask for other optional information.

Order Forms and Products Store:
Sulake also uses forms for users to request information, products and services. For such forms, we collect a user's contact information (e.g., e-mail address and in the case of delivery of tangible products, delivery address and phone number) and necessary information to process the order (e.g., credit card number and billing address). Contact information from the order is used to send orders to our registered users and to get in touch with the user when deemed necessary. Sulake may use third parties to accept and process orders for merchandise and products, including software, and to operate the Sulake Sites and such third parties may have access to your Personal Information.

Contests, Sweepstakes and Promotions:
Sulake may occasionally present a special contest, sweepstakes or promotion that is sponsored by Sulake or another company. To qualify for entry in that contest or promotion, we may ask you to provide personal information. If we plan to share that information with the sponsor(s) or with others, we will provide a statement to that effect in the contest, sweepstakes or promotion terms.

IP Address:
An Internet Protocol (IP) address is unique string of numbers that is assigned to your computer by your Internet Service Provider. Web servers automatically identify your computer by its IP address. We will use your IP address to help diagnose problems with our server and to administer our site and to track and contact you. Your IP address also may be used to gather broad demographic information.

Cookies:
A "cookie" is a small line of text that is stored with your Web browser for record-keeping purposes and to help us provide better service to you. Your browser has options to accept, reject, or provide you with notice when a cookie is sent. We use cookies for many purposes such as to save your password so you don't have to re-enter it each time you visit our site. We also use cookies to deliver content (which may include third party advertisements) specific to your interests. Links to Other Sites. The Sulake Sites may contain links, including banner and other ads, to other web sites. Sulake is not responsible for the privacy practices or the content of such web sites. The Sulake Sites may also link to web sites that feature Sulake trademarks and names along with trademarks and names of other companies. You should look at the privacy policy on that co-branded web site, as the co-branded web site may not be under Sulake's control. Information from Other Sources. For reasons such as improving member experience and providing customized communications to our users, we may receive information about you from other sources and add it to the information that we have received from you.

Who does Sulake share information with?
We will not share your Personal Information with third parties (aside from entities that perform services for us, such as fulfilling orders or operating our Services, that either are bound to comply with our privacy policy or have privacy policies that protect your information) unless you have "opted-in" to such sharing. As stated, Sulake may use third parties to accept and process orders for merchandise and products, including Habbo Coins, and to help us operate our services. Notwithstanding anything to the contrary, Sulake may disclose any information you provide if required to do so by law or pursuant to a request by a law enforcement official or if we have a good faith belief that disclosure is necessary to (1) comply with the law or with legal process; (2) protect and defend the rights or property of Sulake or third parties; or (3) act in an emergency to protect someone's safety or legal rights (?Mandatory Disclosures?).

As we develop our business, we may buy or sell assets, and, depending upon the transaction, your personal information may be one of the transferred assets. In the event that Sulake is acquired by another company, your personal information may be part of the assets transferred to the acquiring party (?Change of Control?).

What are my options to control the use of my personally identifiable information?
Unless you opt-out we and our affiliates may e-mail you with information from Sulake, including information about selected third parties. If you have opted in to our sharing of your Personal Information with third parties, you may receive e-mails directly from third parties. If you do not want to receive information from Sulake or third parties that we have selected, you may Opt-Out Notice
. You may also contact Sulake by postal mail at the address below.

What else should I know about my privacy?

Security:
Sulake has security measures in place to attempt to protect against the loss, misuse and alteration of the information under our control. These include a firewall to prevent unauthorized access to our systems and maintenance of registration information in a separate database. Although we will exercise reasonable care in providing secure transmission of information between your computer and our servers, we cannot ensure or warrant the security of any information transmitted to us over the Internet and we accept no liability for any unintentional disclosure. We will attempt to protect the transmission of credit card information through industry standard, SSL (secure socket layer) encryption.

Sulake Polls and Surveys:
From time to time we may ask our site visitors to answer survey questions. Surveys generally deal with the site, our products or third party products. We may ask for age or age ranges, gender, and other non-personally identifiable information. No personally identifiable information is shared with third parties, unless specifically disclosed. We may have agencies administering our surveys, but these agencies are acting solely on our behalf and will agree to be bound to the terms of this Privacy Policy in the same way as Sulake. We may post answers to polls or surveys at the site, no identifying information is ever included.

Contacting Us about Privacy Questions or Concerns:
If you have questions or comments regarding this Privacy Policy please contact us at privacy.us@sulake.com or send a letter to:
Privacy Manager - habbo.com
225 Santa Monica Blvd., Fourth Floor
Santa Monica, CA 90401
1-888-515-4540

Effective Date This privacy policy is effective as of September 1, 2004

Privacy Policy Changes:
If we make changes to any terms or conditions of this Privacy Policy, the changes will be posted on this website in order to keep you better informed. We may change, add or remove portions of this Privacy Policy at any time, and any changes will become effective immediately upon being posted; provided, however, that your Personal Information will be governed by the last Privacy Policy accepted by you unless we send you notice of the changes and you affirmatively opt-in to the new policy.