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• What this Privacy Policy applies to
• What personal information may be collected
• What non-personal information may be collected
• What gameplay information we may collect
• Special Notes Regarding Certain Information, Including Public Information, Resumes, Investor Relations, Email Correspondence, and Member Names/Gaming Console IDs
• The consequences, if any, resulting from your refusal to provide personal information
• Whether we use cookies, track IP Addresses or use other passive means to collect information
• Who, if anyone, is collecting your personal information and how it will be used
• With whom, if anyone, your personal information be shared
• What choices you have with regard to the use of your personal information
• How you can opt-out of leaderboard data displays and access, change, or delete the personal information we collect and maintain
• Links to other parties
• Whether and how information is collected from Children under 13
• How we ensure data security, quality, and integrity
• Your California Privacy Rights
• Where information is stored
• What other Company terms apply
• What other third-party terms apply
• How to ask questions or file a complaint

WHAT DOES THIS PRIVACY POLICY APPLY TO?

This Privacy Policy applies to the Company’s Online services including the TRUSTe certified Company websites that link to it. In addition, the Company may also own several other domain names that relate to its labels, feature its products, or point to the websites listed above, and we may from time to time add new sites and services. To view a complete list of these certified Take-two sites, please click on the TRUSTe seal on this page.

The Company complies with the U.S. – E.U. Safe Harbor framework and the U.S. - Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries and Switzerland. The Company has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view our certification, please visit http://www.export.gov/safeharbor/.

Please note that this Privacy Policy applies only to information submitted and collected online through the Online Services, and does not apply to information that may be collected by the Company offline. In addition, this Privacy Policy does not apply to websites or services maintained by other companies or organizations (such as those who promote the Company’s products and services or sell related items) and the Company cannot and does not guarantee the security of any personal information disclosed to those third-parties. In addition, please note that we may hire vendors (agents or contractors) to collect personal information on our behalf and in such cases such vendors will be instructed to comply with this Privacy Policy. These vendors may not use your personally identifiable information for their own marketing purposes.

We use the third party service provider Arvato Digital Services as our in-game and online official re-seller. As indicated at the point of purchase, such transactions are between you and Arvato Digital Services and they are subject to Arvato’s privacy policy and terms of service.

We also use third parties for various services related to the Online Services, including customer support, contest data collection, and email fulfillment. When you enter a contest or sign up to receive a newsletter, we may share your personally identifiable information as necessary for third parties to provide services on our behalf. These third parties are not permitted to use such information for their own marketing purposes.

We reserve the right to make changes to this Privacy Policy. Please check back from time to time to ensure that you are aware of these changes. If we make a material change to this Privacy Policy, we will notify you here, by email, or by means of a notice on our home page. If necessary we will give you additional choices regarding such change in these notices. Your continued use of the Online Services will signify your acceptance of these changes.

You may choose to voluntarily provide us with various personal information and non-personal information through your use of the Online Services. We also may use “cookies” and other passive technologies including clear gifs to collect certain non-personal information from you in connection with your use of the Online Services, such as the pages you visit and the features you use. Our cookies are linked to personal information.

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WHAT PERSONAL INFORMATION DOES THE COMPANY COLLECT?

Personal information is information that identifies you and that may be used to contact you online or offline. The Company collects personal information from you on a voluntary basis. When you submit personal information to the Company, it will usually take the form of:

• Registration for websites, jobs, online services, products, contests and special events;
• Subscribing to newsletters or alerts;
• Posting in or commenting on our message boards, forums, news blogs, chat rooms or other online services;
• Purchasing a product or services through our online stores;
• Using “tell a friend,” “email this page,” or other E-Card features;
• Requesting technical support;
• Downloading demos, programs, or other software;
• Participating in polls, surveys, and questionnaires; or
• Otherwise through use of our software, including console products, mobile products, and personal computer products, and through the use of our online products or online services where personal information is required for use and/or participation.

The types of information collected in connection with the activities listed above will vary depending on the activity. The information we collect may include personal information such as your first and/or last name, e-mail address, phone number, photo, mailing address or payment information. In addition, we may collect demographic information such as your age or date of birth, favorite styles of gaming and the systems or software products you own or plan to buy. If demographic information is collected for an activity that also requires personal information, we may combine the demographic information with your personal information. Prize winners may be required to provide additional information for prize fulfillment. Prize winners may be required to provide additional information for prize fulfillment.

If you use, purchase or register for an Online Service through a third-party service such as a gaming console’s network service, an internet based gaming service, or a social network website, or request that we associate a Company account with a third-party service account, then limited user account personal information may be transferred to the Company as part of the registration process and we may be able to collect information about your use of the Online Services.

When you use an application on a Social Networking Site “SNS”, you allow us to access certain information from your profile from that SNS. The information you allow us to access is affected by the privacy settings you establish at the SNS. For example, our Facebook applications may access and store some or all of the following information, as allowed by you, the SNS and your preferences: your “basic information” you have shared with everyone on the SNS; your profile picture or its URL; your friend’s list, your user ID number, which is linked to publicly available information such as name and profile photo; or other information indicated as part of the “Request for Permission” prompt from the SNS. Your agreement to share this information takes place when you "accept" (or similar terms) one of our applications on an SNS. Once your information is received from an SNS, that information is stored and used by us in accordance with this Privacy Policy. The Company is not responsible for the terms, policies, disclosures or actions of any SNS.

When you use Facebook Connect, OpenID or another multisite ID to log in to an Online Service, those ID services will authenticate your identity and provide you the option to share certain personal information with us to pre-populate our sign up form. Depending on your account settings, multisite IDs may also provide other information to us. Please check the terms of those services before using them to log into an Online Service.

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WHAT NON-PERSONAL INFORMATION DOES THE COMPANY COLLECT?

In connection with your use of its Online Services, the Company collects certain non-personal and demographic information. Non-personal information cannot be used to specifically identify you, such as zip code, gender, hardware configuration, console ID, scores, survey data, purchases, Internet Protocol address and other information.

When you play certain software products published by the Company, information about your gameplay may be collected and transmitted to the Company through a gaming consoles network services or any other internet connection method using the hardware on which you play such games (collectively and individually your “Internet Connection”). See “What Gameplay Information Does the Company Collect?” below for further details.

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WHAT GAMEPLAY INFORMATION DOES THE COMPANY COLLECT?

When using products or services on internet-capable hardware, the Company may receive information regarding your gameplay without any additional notice to you or actions taken by you. The Company will not receive personal information such as your name and address but may receive other information such as your PlayStation ID, Games for Windows LIVE or Xbox Live ID, game achievements, game scores and performance, Internet Protocol (IP) address, other console use information, or other information and statistics regarding your usage of the games. Information about gameplay may be collected while you are offline and transmitted to the Company when you next connect to the Internet whether or not you are currently logged into your Internet Connection from your console, handheld, computer, or other gaming platform. The Company may use such information as set forth in this Privacy Policy whether or not you register for or use the Online Services.

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SPECIAL NOTES ABOUT CERTAIN INFORMATION

• Member Names & IDs/Gaming Consoles/Social Network Services/Other Third Party Services: Certain Online Services offered by the Company, including multiplayer gaming and specialized websites, use third party services to (i) provide authentication for Online Services, or (ii) associate a Company service account with a third-party account such as a Gaming Console ID, Gaming Network Service account, or Social Network Service account. When you use a third-party authentication service or link your Company account with a third-party account you will be asked to provide account information associated with that third party account. Certain membership information may be transferred automatically to the Company when you register to join an Online Service from a third-party gaming network system or link your Online Service membership with a third party service, such as your friend’s list on that gaming network or social network service.
  
• Public Information Including Message Boards, User Generated Content, Forums, News Blogs, Comments, User Profiles and Chat Rooms: Whenever you give out personal information in public areas such as on a message board, chat room, comment field or profile page, that information can be collected and used by other people. Information that you disclose in any of these forums is public information, and there is no expectation of privacy or confidentiality there. You should be aware that any personally identifiable information you submit in the course of these public activities can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages or identify you. If you post a video, image, photo or other content through an Online Service for public view you should be aware that these may be viewed, collected, copied and/or used by other users without your consent. . If your screen name or an ID that contains your real name, then that name will be made publicly available on leaderboards and elsewhere. Therefore, you are strongly encouraged not to discose personal information on while using our services or use personal information to identify yourself while using our services. We are not responsible for any public information or content you post using our Online Services.
  
• E-mail Correspondence: We may provide e-mail addresses or forms to which visitors can send us questions or comments, or which visitors can use to request customer support. In the process of receiving and responding to such requests, we may collect personal information about you, such as your e-mail address or any other personal data contained in the body of your e-mail message. By allowing you to send us these requests, we are not attempting to solicit personal information from you. We only use the information for the purpose of responding to your questions and/or comments or to provide customer support. In most cases, your message is deleted immediately after we've resolved your inquiry; however, in some instances, copies of your requests may be kept on file for our records, for quality control purposes, or to provide ongoing support services you have requested. If we have actual knowledge that the person with whom we're communicating is a child under the age of thirteen, we delete the child's e-mail address and message immediately after responding.
  
  In addition to responding to your email correspondence and sending you information you have requested via our email lists, we send activation emails and other transactional emails to your e-mail address as necessary. You may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.
  
• Resumes: The Company allows for the online submission of resumes. Personal information collected from resumes will be used solely for the purpose of accepting and evaluating candidate submissions for job postings, and is therefore not governed by this Privacy Policy. Information obtained from resumes may be shared within the Company by parents, subsidiaries, or affiliates.
  
• Investor Relations: The Company provides investor relations materials on its websites. Personal information collected on the investor relations' portion of the Take Two Interactive Software, Inc. website is used solely in a business capacity and is not governed by this Privacy Policy.

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WHAT HAPPENS IF I REFUSE TO PROVIDE MY PERSONAL INFORMATION?

Your refusal to submit personal information may limit your ability to participate in some activities, such as sweepstakes or the use of certain Online Services. However, as described above, regardless of registration we may nonetheless publish gameplay boards and multiplayer match records that contain certain information as a result of your use of the products, such as your player ID.

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DO YOUR WEBSITES USE COOKIES, TRACK IP ADDRESSES OR USE OTHER PASSIVE MEANS TO COLLECT INFORMATION?

The Company uses cookies, web beacons, and similar tracking devices on its websites to collect information that is not personally identifiable. If you choose to provide us with information, it may be linked to the data stored by these technologies.

• Cookies: A “cookie” is a small bit of record-keeping information that websites often store on a user's computer. Our cookies do not include people's names, e-mail addresses, or other information that is personally identifiable; they are typically used to quickly identify a user's computer and to “remember” things about the user's visit (such as the user’s use of various features on the service). You can disable cookies or set your browser to alert you when cookies are being sent to your computer; however, disabling cookies may affect your ability to use certain portions of the websites.
• Flash Cookies: We may also use flash cookies, also known as “shared objects,” on our sites that employ Flash technology. Flash cookies are small files similar to browser cookies and are used to remember the site's settings to personalize the look and feel of the site. Flash cookies only collect data in the aggregate. Like normal cookies, Flash cookies are represented as small files on your computer and are not tied to your personally identifiable information. One method of preventing Flash cookies from being placed is to adjust your preferences in the Macromedia Website Privacy Settings Panel at www.macromedia.com.
• Web Beacons: A “web beacon” is an electronic image that allows websites to count users who have visited certain pages or viewed certain advertisements. Web beacons, like cookies, do not include personally identifiable information.
• Internet Log Files: The Company may also keep track of your Internet Protocol (IP) and computer MAC addresses for various reasons. An IP address is a number that is used by a networked device and will identify your point of connection to the internet. Depending on your network configuration, it may also identify your computer. A computer MAC address identifies one specific piece of hardware. These log files are tied to your personally identifiable information if you have linked your console user account to online service accounts offered by the Company.
• Analytic Metrics Tools and Other Technologies: Other information that may be passively collected by the Company includes log files that record information about your hardware, product use or website navigational activity. We also use these log file entries for our internal marketing and demographic studies, so we can constantly improve the Online Services we provide you.
• Third-party Advertisers: The Company works with various third-party advertising agents that use cookies, web beacons and similar technologies to collect non-personal information. Please click on the links below to learn more about these vendors, their privacy policies, and the ability to opt out of their tracking programs. Please note that the inclusion of a vendor in the list below does not mean that the Company is currently using them as advertising agents or that it is currently conducting any campaigns that use such technologies. We do not have access or control of the third party tracking technologies.
  
  Mediaplex
  
  Yahoo
  
  DoubleClick
  
  Nielsen/Netratings
  
  Omniture
  
  ATLAS

In addition to visiting the websites of each of the vendors listed above, you may opt-out of certain targeted advertising by multiple thirty party advertising networks at one time if they belong to the Network Advertising Initiative. Visit the Network Advertising Initiative’s website at http://www.networkadvertising.org/managing/opt_out.asp to select the applicable networks.

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WHO IS COLLECTING MY INFORMATION AND HOW WILL IT BE USED?

When you submit information to the Company via our Online Services, or information is automatically collected as described in this Privacy Policy, that information is received by the Company. The Company uses the submitted information to send you promotional materials, to provide you with access to our services, to fulfill product orders, fulfill “tell a friend” requests, and to respond to questions or technical problems. We also use your personal information for our internal marketing and demographic studies, so we can constantly improve the products and services we provide you and to better meet your needs.

Your participation in tournaments or other online game events is conditional upon our collection, use, storage, transmission and public display of statistical data (such as your scores, rankings and achievements) generated through your participation.

Users of certain Online Services, such as the Rockstar Games Social Club, may be automatically entered into contests as a result of their membership and/or use of certain services. Check www.rockstargames.com/socialclub/events frequently for details regarding contests.

Online gaming and Social Networking Services are by their very nature open communities where gameplay information including user name, game activity, and leaderboard rankings are publicly posted for other people to see. Therefore, the Company will automatically post certain information, such as your Screen Name or ID and gameplay statistics, within the game, on Social Networking Services, on Online Services, or on specialized game websites. However, we will not post information that we know directly and clearly identifies you (such as your real name or email address) unless you provide that information voluntarily for such use. As with other gameplay information services, your gameplay, leaderboards, and multiplayer match information may appear nested in our games or third-party webpages via frames or widgets.

We may match and/or combine information collected by various Online Services and display it publicly, including on our websites, in our games, or in multiplayer game lobbies. For example, if you associate your Company website account with a game console account, your in-game achievements may be displayed combining your website account name with your in-game achievements.

Some of our Online Services offer SNS features and Widgets, such as the Facebook “Like” button, Google + button, or the Share This button. These third-party SNS features may set a cookie to enable the Feature to function properly and may collect information about you when you use them, such as your IP address and which page you are visiting on our site. SNS features and Widgets are either hosted by a third party or hosted directly by our Online Services. Your interactions with these Features are governed by the privacy policy of the company providing the Feature. Please review each company’s governing policies before using their services.

From time to time, the Company may employ vendors to perform services on the Company's behalf. These vendors provide internal support to the Company by operating some of the services we provide you such as contest entry collection and email services. Although these vendors, not the Company, may collect, use or maintain the information in connection with the Online Services, the Company still requires that they adhere to the Company's stated privacy policies and that they not share your personal information with third-parties or use the information for their own marketing purposes.

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WITH WHOM DOES THE COMPANY SHARE MY PERSONAL INFORMATION?

The Company may also share your personal information with third-parties as described in this Privacy Policy. The Company may share your personal information to fulfill a request you have made, such as signing up for an email list or requesting customer support. In the event we offer services or promotions where your personal information is separately collected and used according to the privacy policy of a third-party, we will inform you of that at the time of collection and you may elect not to participate in the service or promotion. In addition, we may share aggregate information (not personal information) regarding Online Service usage statistics and user demographics with third-parties, but this information will not include personally identifiable information.

We may share your personal information with third-parties, including as required by law enforcement or other government officials in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose you or us to legal liability. We also may share your personal information with third-parties when we have reason to believe that a disclosure is necessary to address potential or actual injury or interference with our rights, property, operations, users or others who may be harmed or may suffer loss or damage, or when we believe that disclosure is necessary to protect our rights, investigate or enforce our terms and conditions, combat fraud and/or comply with a judicial proceeding, court order, or legal process served on the Company. In addition, in the event of a merger, acquisition, reorganization, bankruptcy, or other similar event involving all or a portion of the Company, the Company's customer information may be transferred to our successor or assign.

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HOW YOU CAN CONTROL THE COLLECTION, USE, AND/OR DISPLAY OF DATA OR REVIEW YOUR DATA

If you are a member of an Online Service, you may use that service’s account and privacy settings to personalize the collection, use and/or display of your data via that service.

If you do not want the Company to send you communications such as newsletters or promotional offers, you may opt-out from receiving these communications at the time your personal information is collected or later by using the methods listed below. In addition to the methods below, along with every communication sent to you, the Company gives you the opportunity to discontinue receiving future communications.

If for any reason you wish to unsubscribe to Rockstar Games mailing lists please log in to manage your account or use the unsubscribe links at the bottom of any Rockstar Games email message. To delete your Rockstar Games account, sign into your Social Club account, go to https://socialclub.rockstargames.com/profile/requestdeleteaccount.html, and follow the instructions on the page. If you are unable to log in to Social Club or you do not have access to your account, please email deleteaccount@RockstarGames.com from the same email account you used to join Social Club, include your Social Club nickname in the message and include “Delete Account” in the subject field.

If you do not want your gameplay information to publicly appear via the Rockstar Games Social Club, then you should visit www.rockstargames.com/socialclub/privacy/opt and follow the instructions to opt out of our gameplay information services by masking your user ID. Please note that, even if you opt-out of participation in the Social Club, your gameplay information may still appear on certain gameplay boards including those hosted by third parties such as console manufacturers (including copies of those boards hosted on the Social Club) and the Company will continue to collect and store information regarding your usage of its games for internal purposes.

Data Retention: We will retain your personal information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your personal information to provide you services contact us as described above under “How You Can Control the Collection, Use and/or Display of Data or Review Your Data.” We will retain and use your personal information as necessary, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.

In addition to those methods, if you wish to view, delete or correct the personal information collected about you, you may also send an email to privacypolicy@take2games.com, or write to us at Take Two Interactive, Attn: Internet Privacy Policy Administrator, 622 Broadway, New York, New York 10012. We will review, update or remove information as appropriate. We will respond to your request within 30 days.

Even if information is changed or deleted, we may still retain some of your information in our files to resolve disputes, enforce our user agreement, administer our services, comply with technical and legal requirements, and/or other constraints related to the security, integrity and operation of our websites.

In all cases for all websites, we will respond to your request for access to update, delete, or correct inaccuracies to your personally identifiable information within 30 days.

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WHAT IS YOUR POLICY REGARDING LINKS TO OTHER SITES?

You should be aware that while you are on our websites you could be directed to other sites that are beyond our control. The fact that we link to a website is not an endorsement, authorization, or representation of our affiliation with that third-party. Because we cannot guarantee that the privacy policies of these websites meet our high standards, we recommend reading the privacy policy of the website you link to before you submit any of your personal information.

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DO YOU COLLECT PERSONAL INFORMATION FROM CHILDREN UNDER 13?

The Company does not knowingly collect personal information from children under 13 years old. If we find out we have collected any personally identifiable information from anyone under the age of 13 we will delete this information immediately. We encourage parents to instruct their children to never give out their real names, addresses or phone numbers, without permission, when using the Internet.

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WHAT SAFEGUARDS ARE USED TO PROTECT MY PERSONAL INFORMATION?

To protect your personal information, the Company follows generally accepted industry standards and maintains reasonable safeguards to attempt to ensure the security, integrity and privacy of the information you have provided. The Company has security measures in place designed to protect against the loss, misuse and alteration of the information under our control. Personal information collected by the Company is stored in secure operating environments that are not available to the public (e.g., locked rooms). To prevent unauthorized electronic access to personal information, the Company maintains information collected online behind a firewall-protected server and uses SSL encryption for purchases made through our online store. However, no system can be 100% secure and human errors occur, so there is the possibility that there could be unauthorized access to your information. By using our services, you assume this risk.

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Your California Privacy Rights

Since 2005, California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of personal information to third-parties for their direct marketing purposes. If this privacy policy states that any personal information may be shared with third-parties for their direct marketing purposes, you may send inquiries regarding our disclosure policy to:

Take Two Interactive
Attn: Internet Privacy Policy Administrator
622 Broadway
New York, New York 10012
privacypolicy@take2games.com

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STORING AND/OR EXPORTING DATA TO THE UNITED STATES

All data collected or received by the Company in connection with the Online Services are collected in or exported to the United States of America and stored on servers located in the United States. By using our services, you expressly consent to us exporting such data to, and storing such data in, the United States. The laws of the United States shall govern the use of such data and not the laws where you may be located. Backup data and similar administrative data may also be stored on media or servers located outside the United States.

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OTHER COMPANY TERMS

Use of our services and products may be subject to other terms, conditions and disclosures prescribed by the Company, console manufacturers and/or other partners, including: (i) the Limited Software Warranty; License Agreement and Privacy Disclosure that accompanied the purchase of the game, (ii) terms and conditions of our Online Services, (iii) other terms and disclosures which are made available to you by the Company, and (iv) the terms, conditions, and disclosures made available to you by third parties in connection with the use of their gaming consoles and/or online services. All such terms, conditions and disclosures are incorporated by reference into this Online Privacy Statement.

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OTHER TERMS FOR THIRD PARTY PLATFORMS

Use of our services and products may be subject to other terms, conditions and disclosures prescribed by the Company, console manufacturers and/or other partners, including: (i) the Limited Software Warranty; License Agreement and Privacy Disclosure that accompanied the purchase of the game, (ii) terms and conditions of our Online Services, (iii) other terms and disclosures which are made available to you by the Company, and (iv) the terms, conditions, and disclosures made available to you by third parties in connection with the use of their gaming consoles and/or online services. All such terms, conditions and disclosures are incorporated by reference into this Online Privacy Statement.

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HOW DO I ASK A QUESTION OR FILE A COMPLAINT?

Any questions or complaints about this Privacy Policy can be filed by contacting our Privacy Policy Administrator at 646-536-2842; via email at privacypolicy@take2games.com; or, by regular mail at Take Two Interactive, Attn: Internet Privacy Policy Administrator, 622 Broadway, New York, New York 10012.