PRIVACY POLICY

March 20, 2006

QOPEL RECORDS PRIVACY POLICY
Qopel Records and this site care about your privacy. This privacy policy tells you what information we collect at our web sites and how we use it. If you choose to visit any of the Qopel Records web sites, your visit is subject to this privacy policy, and you agree to the terms of it.

WHAT INFORMATION WE COLLECT
There are many places at our sites where you can share your personal information with us, and where you can communicate with others.

Registration. Some of our sites give you the opportunity to register with us, and sometimes registration is required before certain site features can be used. Our registration forms may request your contact information (such as your name, email address, mailing address, etc.), demographic information (such as your country, gender, etc.), and profile data (such as your music preferences, entertainment practices, etc). You may be assigned a site username and/or password. For our internal purposes, we use this information to communicate with you and provide the services you have requested, and to provide a more personalized experience on our sites. For example, your registration may allow you to use and post to site message boards, create site profiles, etc. We use aggregate demographic and profile information about our audience in order to improve our service, for research purposes, marketing/promotional purposes and/or for industry reporting purposes, among others. By visiting our sites, you affirmatively consent to our collection and use of your data.

Newsletters and Other Communications from Us. Our registered users and customers may receive newsletters, email communications, or communications through other channels for, among other purposes, the promotion and marketing of a product or service from our family of sites and record labels, as well as other Qopel Records companies, and business partners, and we may also offer other visitors to our sites the opportunity to sign up to receive such information. When there is a separate sign-up for newsletters, we ask for contact information such as name and email address, and, sometimes, demographic and profile information. By visiting our sites, you affirmatively consent to our collection and use of your data. We use this information in the same manner as we use the contact information in the Registration process described above. We may offer our users the choice whether to receive mailings from others that we think will be of interest. Recipients of our mailings can unsubscribe by following instructions that may appear at the end of email communications. Note that in order to keep our registered users informed about the operation of our services, we may send emails and announcements that are needed for the proper functioning and administration of our sites and service.

Communications with Us. We have features where you can submit information to us (such as when contacting us with a question or feedback). We may retain your emails and other information you submit to us for our internal purposes, and to help us to serve you better.

Communications with Friends. We may offer features where you can send information to others, such as e-cards or "Tell A Friend" features. We will use the contact information you enter for your friends to send the email or e-card.

Interactive and Community Features. Our sites may offer interactive and community features, such as message boards, chat, email accounts, short message service (SMS), instant messaging, profiles, personal homepages, etc. All information posted or sent through these features may be publicly available, and you should be aware that when you voluntarily disclose personal information (e.g., user name, email address, phone number) through these features, that information can be collected and used by others and may result in unsolicited communications from other people. By accessing these features and disclosing personal information, you affirmatively consent to the distribution of your personal information as described above. Users' posts may be publicly and/or internally associated with their profiles/screen-names. Users are solely responsible for the content of messages they post or send on public forums.

Contests, Sweepstakes and Surveys. We may also have contests, sweepstakes and surveys at our sites. When you enter or participate in them, we request contact information from you (such as your full name, email address, mailing address, and telephone number) and may also request demographic or profile information. We will use the information you provide for the purpose of conducting the promotion (for example, to contact you if you have won). We may also use the information to send you newsletters and other information we think may be of interest. Recipients of our mailings can unsubscribe by following instructions that may appear at the end of the email communication. Any personal information we collect may be associated with registration information. We may share aggregate information with others. We may sometimes partner with sponsors in offering contests, sweepstakes or surveys, and may share (provide and receive) information with them. By entering or participating in such contests, sweepstakes, and surveys, you affirmatively consent to our collection and use of your data.

AUTOMATIC DATA COLLECTION
Our web sites have features that automatically collect information from users to assist us in creating sites that honor our users' preferences and serve their interests and needs.

Some of our sites use cookies, which are small data files containing information about the user that are stored on the user's hard drive. Some cookies are used to make login to our sites easier (such as by remembering usernames and passwords). If users reject cookies, they may be limited in using some areas of our sites. Cookies can also enable us to track users' movements and target their interests to enhance their experience at our sites. We may also collect clickstream data and assign unique identifiers to our users for the same purposes. Information obtained with these technologies may be associated with your personal information.

We or a third-party advertisement server may also use cookies in connection with targeting advertisements or promotions to users. Our advertisers and other third parties whose products or services are promoted on our sites may also use cookies or other technology, and we advise you to check their privacy policies for information about their privacy practices.

We may also gather information such as the date, time, browser type, navigation history, and IP address of all visitors to our site(s). We use this information for our internal security audit log, trend analysis, and system administration, and to gather broad demographic information about our user base. We may associate this information with your personal information. By visiting our sites, you affirmatively consent to our collection, use, and distribution of your data.

WITH WHOM YOUR INFORMATION IS SHARED
Information provided at Artist sites that we host or manage may be shared with that Artist, including their management, representatives, and any new label they may join. As with other third parties, we are not responsible for how the Artists handle the data once they receive it. When we have co-branded or sponsored services, when we host a site, or when we join with other parties to provide specific services, we may share (provide and receive) your personal information with them. By visiting these sites, you affirmatively consent to our collection, use and distribution of your data.
We may share your information with other third parties with whom we have business relationships and, in some cases, we cannot control or know their privacy practices. By visiting our sites, you affirmatively consent to our collection, use, and distribution of your data.

Other than as set forth in this policy, we do not share your personally identifiable information with other companies, apart from those acting as our agents in providing our service to you, and which agree to use it only for that purpose and to keep the information secure and confidential. We will also disclose information we maintain when required to do so by law, for example, in response to a court order or a subpoena or other legal obligation, in response to a law enforcement agency's request, or in special cases when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property. You should also be aware that courts of equity, such as U.S. Bankruptcy Courts, may have the authority under certain circumstances to permit your information to be shared or transferred to third parties without your permission.

We may share (provide and receive) aggregate information, which is not personally identifiable, with others. This information may include demographic data such as the gender and/or geographic location of groups of users, but it will not include personal information (such as your name or email address). We use aggregate demographic information about our audience in order to improve our service, for research purposes, marketing/promotional purposes and/or for industry reporting purposes, among others.

CHOICE
By accepting this privacy policy, you expressly choose to receive certain communications from us and third parties, and you expressly agree to the privacy practices described herein. Our sites may also provide you with additional specific opportunities to select communications you wish to receive. You may change your privacy preferences, e.g. choose to cease receiving certain communications, by informing us of your new preferences. We will be able to honor your new preferences most quickly if you inform us of them by following the appropriate instructions in any communication you receive from us. Please be aware that messages you receive from us through SMS and instant messaging systems (and other systems apart from email) may not include an option to cease receiving communications; to change your privacy preferences with respect to those communications, please go to the profile page at the site where you provided your personal information or direct your instructions to the Contact identified at the end of this policy.

ACCESS
If a user's personally identifiable information changes (such as zip code), we endeavor to provide a way to correct or update that user's personal data. Please feel free to contact us if you have any questions regarding making changes to your data.

DATA COLLECTION FROM CHILDREN
We strive to comply with the Children's Online Privacy Protection Act (COPPA). We do not knowingly collect personal information from U.S. children under 13 without appropriate parental notice and consent. Sites that are directed to children where personal information is collected should have a Children's Privacy Policy setting forth our COPPA-compliant practices. At many sites, we actively screen-out children from data collection and/or use of interactive or community features. We are committed to protecting children's privacy.

NOTICE: Visit www.ftc.gov/kidzprivacy for information from the Federal Trade Commission about protecting children's privacy online.

SECURITY
Security for all personally identifiable information is extremely important to us. We store your personal information securely, and use special procedures designed to protect the information we collect from loss, misuse, unauthorized access or disclosure, alteration or destruction.

MERCHANT/E-COMMERCE AREAS
We do not generally make e-commerce offerings at our sites. Some of our sites do have merchant/e-commerce areas, where users can purchase merchandise. Universal Music Group does not run those areas of our sites. Personal information collected at those areas is not shared with Qopel Records without the purchasers' consent. At each of those areas, we endeavor to provide a privacy policy link where users can review the privacy policies that apply to data collection and use at those areas, and we urge our users to review them. Please be aware that the site at iClassics.com is an exception, where we do make e-commerce offerings, and it is covered by a separate privacy policy. Please review it if you use that site.

LINKS
We may provide links to non-Qopel Records sites. We are not responsible for those other sites, their privacy policies or how they treat information about their users, and we advise you to check their privacy policies.

PRIVACY POLICY CHANGES
We reserve the right to modify, alter or otherwise update this Privacy Policy at any time, so we encourage you to review this policy from time to time. Changes to this privacy policy are effective at the time they are posted and your continued use of our sites after posting will constitute acceptance of, and agreement to be bound by, those changes.