MSN TV service ("MSN TV service") is a limited Internet access service for television provided by WebTV Networks, Inc. in conjunction with Microsoft Corporation (collectively "Microsoft").

Your privacy is important to us. At Microsoft, we are committed to maintaining the privacy and accuracy of your personal information and to protecting such information from loss, misuse and unauthorized access and disclosure.

This Statement of Privacy describes how Microsoft treats information received about you when you become a subscriber to the MSN TV service, when you provide information to us, and when you use the MSN TV service. This statement addresses the following:

• Collection and use of Personal Information
• With whom Personal Information is shared
• How to access and modify Personal Information
• How we safeguard children's privacy
• Collection and use of Operating Information
• With whom Operating Information is shared
• How Personal and Operating Information is protected
• Other Situations in which Personal and/or Operating Information May Be Disclosed
• Cookies

Collection and Use of Personal Information

When you register as a primary user of the MSN TV service, Microsoft will request information that personally identifies you or allows us to contact you. On the MSN TV service, this information is your name, home address, phone number, e-mail address, and payment information ("Personal Information"). Any such information collected from Secondary Users is treated as the Personal Information only of the Primary User (Primary and Secondary Users are discussed in the MSN TV Service User Agreement). Personal Information is also collected at other times by specifically requesting it from you, such as when you order premium services, when you request other promotional material, when we ask you to complete customer surveys, and in other circumstances when you interact with the MSN TV service or our employees, agents and contractors working to provide the MSN TV service to you.

Microsoft collects, stores and processes Personal Information for the following purposes:

To service accounts, process or collect payments, and otherwise operate and deliver the MSN TV service.

To assist with questions about membership, billing, or use of the MSN TV service, or the Internet.

To conduct both business and individual surveys to be used for the purposes set forth in the survey.

To alert you to new products, product upgrades, special offers and other information related to the MSN TV service.

With Whom Personal Information Is Shared

Microsoft may share your Personal Information with third parties for their use to provide services to Microsoft in the operation and delivery of the MSN TV service, such as to process or collect payments, service MSN TV service accounts, or provide the products and services associated with the MSN TV service. All such third parties are prohibited from use of such Personal Information except to provide such services, and they are also required to maintain the confidentiality of such Personal Information.

Occasionally Microsoft may select third parties to send you information or special offerings about products or services that we believe may be of interest to you. Microsoft also may forward some Personal Information (name, home and e-mail addresses, and phone number) to the equipment supplier that manufactured your Internet unit. Microsoft will share Personal Information for these purposes only with those third parties whose policies regarding Personal Information are consistent with our privacy policies or who agree to abide by our policies with respect to Personal Information. If you do not want Microsoft to send your Personal Information to third parties for these purposes, you may elect not to have this done ("opt out") by selecting Setup Sharing Personal Information.

Except under the circumstances described above, or as described below under "Other Situations in which Personal and/or Operating Information May Be Disclosed," Microsoft does not disclose Personal Information to third parties.

How to Access and Modify Personal Information

You may access your MSN TV service account to review and, if necessary, modify your Personal Information. You may do so by selecting "Account" from the MSN TV service Web Home Page, and then selecting "Subscriber info".

How We Safeguard Children's Privacy

Microsoft currently does not knowingly collect or use Personal Information from children under 13, and Microsoft will not do so in the future without first obtaining verifiable consent from their parents. Should a child whom Microsoft knows to be under 13 send Personal Information to Microsoft, Microsoft will only use that information to respond directly to that child or seek parental consent. Parents are ultimately responsible for the use of the MSN TV service by their children. Microsoft encourages parents to use a password to prevent inadvertent identification of your child to others or access to inappropriate materials by your child. Microsoft also encourages parents to talk to their children about safe and responsible use of their Personal Information while using the Internet.

Collection and Use of Operating Information

Microsoft collects and stores Operating Information, which consists of the electronic instructions and data communicated from your set-top device to the MSN TV service. Operating Information includes the websites you have chosen to access and the television channels you have selected to view through the MSN TV service.

Microsoft uses Operating Information to effectively operate the MSN TV service and enhance your experience on the Internet. For example, Microsoft stores the websites that you have selected to be part of your list of favorite sites, so that you can access them quickly, and stores the most recent websites that you have visited to make browsing more efficient. Operating Information may also be used to customize the advertising, content, information and services that are delivered to your set top device.

Microsoft also uses Operating Information to understand how our system is being used and navigated. For example, Microsoft processes aggregated Operating Information concerning the amount of hits on certain websites, the use of certain features, such as "Mail," "Search," and "Explore," the number of set-top devices that are exposed to certain advertisements placed by advertisers on our system, and the number of set-top devices that are tuned in to certain television programming.

Understanding the use and navigation of the MSN TV service helps Microsoft in a number of ways. For example, collection and analysis of Operating Information helps us track traffic volume for revenue reporting purposes, evaluate the popularity of certain television programs for advertising purposes, and measure the costs of providing certain features and programs to ensure our pricing and business models are appropriately aligned with usage patterns. In addition, Microsoft uses Operating Information to improve connections to popular websites, enhance the selection of interactive television programming, and ensure the technical success of interactive television features. In general, the collection and use of Operating Information allows Microsoft to analyze the use of the MSN TV service to continue to develop and provide improved advertising, content, features and services that are of the most interest to our subscribers.

With Whom Operating Information Is Shared

Microsoft may provide Operating Information to third parties for their use to provide services to Microsoft in the operation and delivery of the MSN TV service. All such third parties are prohibited from use of such Operating Information except to provide such services to Microsoft, and they are also required to maintain the confidentiality of such Operating Information. Operating Information that includes the websites you have chosen to access or the television channels you have selected to view through the MSN TV service is not provided to any such third party.

Microsoft may also provide Operating Information in aggregate form to third parties. This aggregate information contains no Personal Information about any of our individual subscribers. It simply describes on an aggregate level how our subscribers are using the MSN TV service. Except under the circumstances described above, or as described below under "Other Situations in which Personal and/or Operating Information May Be Disclosed," Microsoft will only share Operating Information with third parties if the Operating Information is in aggregate form and is disclosed in a manner that does not otherwise identify individual subscribers to the third parties.

Microsoft is sensitive to the concerns some of our subscribers may have with respect to the use of Operating Information containing the television channels selected for viewing through the MSN TV service, even when such use is in aggregate form. If you do not want Microsoft to collect or store the television channels you have selected to view through the MSN TV service, you may elect not to have this done ("opt out") by selecting TV data collection opt-out.

How Personal and Operating Information Is Protected

Microsoft takes reasonable steps to protect Personal and Operating Information. Microsoft uses technologies and processes such as encryption, access control procedures, network firewalls and physical security. These technologies and methods increase the security and privacy of information traveling to, from and within the MSN TV service.

Microsoft also safeguards Personal and Operating Information from unauthorized access. Most Operating Information is maintained in databases that are separate from those containing Personal Information, and only authorized Microsoft employees or agents carrying out permitted business functions are permitted to access Personal or Operating Information. Employees who violate Microsoft's privacy access policies are subject to disciplinary actions, including termination when appropriate.

Microsoft urges you to use a password to protect your account from unauthorized access by others. If you do allow others, including family or household members, to access the MSN TV service through your account, including Secondary Users or other members of your household, please understand that you are responsible for the actions of those individuals.

Microsoft also encourages you to explain this privacy policy to others that use the MSN TV service through your account, including Secondary Users or other members of your household. In addition, Microsoft encourages all users of the MSN TV service to review the privacy policies posted by the websites visited over the Internet, including those appearing on or linking to or from the MSN TV service, to ensure that these websites also protect Personal Information. Microsoft is not responsible for Personal Information you provide to such sites or the privacy and other polices of such sites.

Other Situations in which Personal and/or Operating Information May Be Disclosed

Microsoft may disclose Personal Information and/or Operating Information if required to do so by law or in the good-faith belief that such action is necessary or appropriate to (a) conform to the edicts of the law or comply with legal process served on Microsoft, (b) protect and defend the rights or property of Microsoft, the MSN TV service, or users of the MSN TV service, whether or not required to do so by law, or (c) protect the personal safety of users of the MSN TV service or the public. Microsoft reserves the right to contact and disclose Personal Information to appropriate authorities at its discretion when it appears that activities which are illegal or violate the MSN TV Service User Agreement are taking place within the context of a user account.

Cookies

Cookies are pieces of information that a website creates for record-keeping purposes. The MSN TV service does not create or use cookies, but the websites you access, including website pages built by users on the MSN TV service using the Page Builder function, might create cookies and transfer these cookies to MSN TV service servers. Cookies can make your experience on the Internet more useful by storing information about your preferences and choices on a particular site. This enables websites to customize delivery of their website content and advertisements. Microsoft does not control the use of cookies by other website operators, website page builders or their advertisers.

Changes to the MSN TV service Statement of Privacy

Microsoft may make changes to this statement from time to time. We will post changes to our privacy statement here, so be sure to check back periodically. We may also notify you of significant changes by e-mail or in other ways.

Questions, Comments, Concerns

If you have any questions or comments about our use of Personal Information or about this Statement of Privacy, please contact us at privacy@corp.webtv.net. Microsoft will use reasonable efforts to promptly investigate any complaint you may have regarding our use of Personal Information and to comply fully with the legal and regulatory supervisory authorities responsible for enforcing our adherence to the privacy principles stated above.

August 8, 2001