Updated: October 31, 2006

The policy contained herein is designed to protect Pando users from advertisers and specific advertising content that may jeopardize a positive overall consumer experience. The policy below outlines specific guidelines on advertising content and advertiser behavior. If at any time, a violation of this policy is discovered, we ask that you contact us immediately at support@pando.com. Additionally, to assist us in investigating the manner as quickly as possible, we ask that you provide a screenshot and attach it to the email as well as provide any additional information that you are able to obtain.

Any advertiser that is running any advertising on any version of the Pando clients or any subsidiary, website or other affiliate property of Pando Networks, Inc., is asked to please read this policy carefully and assume that all aspects will apply to you, unless the policy explicitly states otherwise.

Please note that we may change our policies at any time, and pursuant to our Pando Policies, it is your responsibility to keep up-to-date with and adhere to the policies posted here.

The entire Pando team thanks you for your cooperation!

Advertising Content Policy

Pando is extremely concerned with providing all of our users with a positive and ethical advertising experience. All Pando advertisers must ensure that each and every campaign complies with the following guidelines:

Advertisements may NOT include:

• Pop-ups, pop-unders, double pop-ups or exit windows that interfere with site navigation, change user preferences, or are for downloads
• Any form of adware, spyare, Trojans, hijackers, or virus
• ActiveX installations
• Excessive profanity
• Racial intolerance or advocate violence in general or against any individual, group, or organization
• Hacking/cracking content
• Illicit drugs and drug paraphernalia
• Pornography, adult, or mature content
• Any other content that promotes illegal activity or infringes on the legal rights of others
• Sales or promotion of certain weapons, such as firearms, ammunition, balisongs, butterfly knives, and brass knuckles
• Deceptive advertising to include advertisements that are designed to look like a system security notice or some form of Windows notice. The advertisement must be formatted and labeled as an advertisement not a notice.
• Restrictions or the blocking of normal browser navigational controls
• Automatically redirects to another site
• Resizing of delivery browsers and serving full page advertisements
• Promotion of applications or software that could interfere with the users' PC performance
• Direct or indirect promotion of "pay-for-play" and/or gambling. This is not allowed in the United States, Singapore, Australia or New Zealand.
• Illegal or fraudulent activity, including without limitation phishing
• Pornography or "adults only" sites. All keywords must be at least two-word combinations and specifically adult in nature to prevent accidental triggering of an advertisement and ensure that the advertisement is not viewed by someone under 21 years of age.
• Visible genitals, sexual acts (whether explicit, implied, or obscured), and explicit sexual language and this is also prohibited from the landing pages.

Below is a more detailed description of the Pando definition of specific Advertising Content categories:

Adult Content

Advertisements that (i) display or promote pornography or are otherwise indecent or obscene, (ii) display or promote child pornography or other non-consensual material or (iii) promote prostitution.

Dietary Supplements, Health Foods, Vitamins and Similar Products

Claims for dietary supplements, health foods, vitamins and similar products must be truthful and advertisers must have substantiation for any objective product claims that they make. For more information regarding dietary supplements, please ask the Federal Trade Commission for a copy of "Dietary Supplements: An Advertising Guide for Industry," currently available at http://www.ftc.gov/bcp/conline/pubs/buspubs/dietsupp.htm.

Disclaimers and Disclosures

Disclaimers and disclosures must be clear and conspicuous; consumers must be able to notice, read or hear, and understand the information.

Environmental Claims

Advertisements must not misrepresent - directly or indirectly - that a product offers a general environmental benefit. Advertisements should qualify broad environmental claims - or avoid them altogether - to prevent deception about the specific nature of the benefit. In addition, advertisements should not imply significant environmental benefits if the benefit is not significant. For more information regarding environmental claims, please ask the Federal Trade Commission for a copy of 'Environmental Advertising and Marketing Practices Guide', currently available at http://www.ftc.gov/bcp/grnrule/guides980427.htm#260.7.

Gambling

Advertisements are not permitted to consumers in the United States for online casinos, sports books, bingo, and affiliates with the primary purpose of driving traffic to online gambling websites.

Illegal Drugs and Detection

Advertisements and associated websites may not promote or sell illegal drugs (including illegal dietary supplements), illegal drug paraphernalia or any product designed to thwart detection of illegal drugs.

Intellectual Property, Replicas and False Documents and Credentials

Advertisements and associated websites may not promote or sell products or services specifically designed to infringe on a third party's intellectual property or related rights or false documents and credentials, including, but not limited to (i) products that descramble cable and satellite signals in order to get free cable services, (ii) replicas or imitations of designer goods, (iii) fake identification cards, passports, diplomas and noble titles, (iv) hacking or cracking tools or services (including instructions or equipment to illegally access or tamper with software, servers, or websites), (v) mod chips or other devices that unlock copyright protection and (vi) dialers.

Jewelry

Advertisements must comply with the Federal Trade Commission's "Guides for the Jewelry, Precious Metals, and Pewter Industries," currently available at http://www.ftc.gov/bcp/guides/jewel-gd.htm.

Made in the U.S.A.

Advertisements that state that a product is "Made in the U.S.A.", must ensure that the advertised product "be all or virtually all" made in the United States. For more information regarding "Made in the U.S.A." claims, please ask the Federal Trade Commission for the "Enforcement Policy Statement on U.S. Origin Claims," currently available at http://www.ftc.gov/os/1997/12/epsmadeusa.htm.

Prescription and Over-The-Counter (OTC) Drugs

Advertisements for prescription drugs must comply with the Federal Drug Administration's regulations and guidelines. For more information regarding prescription drug advertising, please visit the FDA's website at www.fda.gov, contact the FDA at 1-888-INFO-FDA or contact your legal advisor. As with any other product, claims for OTC drugs must be truthful and non-deceptive. Given the health and safety issues that can arise in marketing these products, advertisers should take care in substantiating their claims. Advertisers may be required to back up their representations with competent and reliable scientific evidence, including tests, studies, or other objective data.

Refunds

Advertisements that promise to refund money to dissatisfied consumers must honor such promise. In addition, if an advertisement uses phrases like "satisfaction guaranteed" or "money-back guarantee," an advertiser must be willing to give full refunds for any reason.

Spam and Related Products

Advertisements and associated websites may not promote or sell bulk marketing products, including email lists that are not opt-in, bulk email software and bulk messaging, if the stated or implied use of such products is unsolicited spam.

Testimonials and Endorsements

Testimonials and endorsements must reflect the typical experiences of consumers, unless the advertisement clearly and conspicuously states otherwise. A statement that not all consumers will get the same results is not enough to qualify a claim. Testimonials and endorsements cannot be used to make a claim that the advertiser itself cannot substantiate. Connections between an endorser and the company that are unclear or unexplained to a consumer must also be disclosed. For more information regarding testimonials and endorsements, please ask the Federal Trade Commission for "FTC Guides Concerning Use of Endorsements and Testimonials in Advertising," currently available at http://www.ftc.gov/bcp/guides/endorse.htm.

Truth in Advertising

Advertisements must be truthful and not deceptive, must have evidence to back up their claims (simply offering a money-back guarantee will not suffice) and cannot be unfair. An advertisement will be construed as "deceptive" if it contains an express or implied statement or omits information that is (i) likely to mislead consumers acting reasonably under the circumstances and (ii) material - this is, important to a consumer's decision to buy or use the product or service. An advertisement will be construed as "unfair" if it (i) causes or is likely to cause substantial consumer injury which a consumer could not reasonably avoid and (ii) is not outweighed by the benefits to consumers.

Weapons and Violence

Advertisements and associated websites may not promote or sell certain weapons, including, but not limited to, firearms, ammunition, butterfly knives and brass knuckles.

Pando reserves the right to review and reject any advertisement at any time, at our sole discretion. We also reserve the right to de-activate any campaign not in compliance with our Advertising Content Policy or if it negatively impacts our users.

If you have any questions about your campaigns or this Advertising Content Policy, please contact either policies@pando.com or support@pando.com.

Thank you.