REFTEK LLC PRIVACY POLICY

LAST UPDATED: JUNE 9, 2003

RefTek LLC ("RefTek") is committed to protecting your privacy. This privacy policy ("Privacy Policy") explains the type of information RefTek collects through www.reftek.net (the "Site") and any services offered therein (the "Services"). For purposes of this Privacy Policy, viewing any portion of the Site or the Services is considered a "use" of the Services.

Please read the following Privacy Policy carefully before using the Services. If you use any of the Services, you will be bound by the terms of this Privacy Policy. This Privacy Policy may change from time to time so you should check it frequently. If you have any questions, concerns, or comments about this Privacy Policy, please contact us at privacy@reftek.net.

REFTEK COLLECTS AND STORES INFORMATION ABOUT THE WEB PAGES YOU VIEW AND THE DATA YOU ENTER IN ONLINE FORMS AND SEARCHES. ALTHOUGH REFTEK DOES NOT ATTEMPT TO ANALYZE INTERNET USAGE DATA TO DETERMINE THE IDENTITY OF ANY SERVICE USER, SOME INFORMATION COLLECTED BY THE SERVICES ARE PERSONALLY IDENTIFIABLE. REFTEK AGGREGATES AND ANALYZES THE INFORMATION IT COLLECTS TO IMPROVE ITS SERVICES AND TO PREPARE REPORTS ABOUT AGGREGATE INTERNET USAGE AND YOUR SERVICE USAGE HABITS.

What types of information does RefTek collect?

If you are using any of the Services, we may collect the following information: the full Uniform Resource Locator ("URL") of the Web page from which you came to the Services; your Internet Protocol ("IP") address, which may include a domain name; the date and time for each page you view; the name of and information about any advertisement that brought you to the Web pages that offer the Services; searches you perform, links you click on; and computer and connection information such as browser type and version, operating system, and platform. We also transmit cookies to your computer so we can track the pages of our Web site that you view and the order in which you view them.

If you e-mail RefTek we collect your message, the recipient e-mail address(es), and your e-mail address for the purpose of sending the e-mail. We do not send other e-mail to these address(es).

If you use the Services, we collect any information voluntarily provided by you during the registration process (if applicable), which can include your e-mail address as well as billing information and demographic information such as gender, age, occupation, household income, zip code and country. We also collect the name of and information about any advertisement that brought you to the Web pages that offer the Services. Any e-mail address that you give us during the registration process is kept separate from information collected during your use of the Service and is not used to correlate your identity to Internet usage path. Demographic information is correlated to Internet usage collected during your use of the Service, but we do not attempt to determine your identity by analyzing this information.

When you use the Services we transmit cookies to the hard drive of your computer. These cookies assign your Web browser a unique series of numbers, letters, or characters that enable RefTek's servers to recognize and identify your Web browser when you are using the Service. They also enable RefTek to track and store information about your Internet usage path while using the Service. See below for more information about how RefTek uses this data.

When you use the Services we collect information about the Web sites you visit (e.g., by clicking on advertisements) and the Web pages you view. This information allows us to build our database of information about related Web pages. Thus, for every Web page you view while using a Service, the Service transmits and stores the following information from your computer to RefTek:

your IP address, which may include a domain name;

the full URL of the Web page you are visiting;

general information about your browser;

general information about your computer's operating system;

your cookie number; and

the date and time the above information is logged.

All of the above information is logged together in a single data string for each Web page you visit. Each string is logged in our database.

Does RefTek collect personally identifiable information?

The URLs we collect through your use of the Services sometimes contain personal information about you. For example, when you enter information on a Web page (e.g., when you complete an online registration form or advertisement form) the operator of the Web site may insert that information into its URL for that or the next page. This information often appears after a question mark ("?") in the URL, although it can appear in other places. This means that your name, your address, your e-mail address, or similar information you might consider private or personally identifiable which you enter into a Web page sometimes becomes part of a URL and is automatically stored in RefTek databases. This can also occur with words, topics, products, or phrases you enter into search engines - whether those engines are provided by the Services or found elsewhere on the Internet - while using the Services. RefTek has no control over what information third party Web sites put into their URLs or where they put it, and any information in each URL is collected and stored by RefTek when you are using the Services.

RefTek analyzes its logs of usage path collected from users to determine Internet usage in the aggregate. Further, by storing this information with users' cookie numbers, RefTek correlates each user's usage path information and demographic information to each other.

All transmissions between you and RefTek, including e-mails, URLs, cookie identification numbers, usage paths, and any personally identifiable information they might contain, pass through many third party machines, operating systems, programs, browsers, Internet servers, networks, routers, Ethernet switches, ISPs, proxy servers, intranets, the public telephone systems, or other devices, any of which may create activity logs containing such transmissions.

What does RefTek do with the information it collects?

If you gave us your e-mail address when you registered, we may use it to send you RefTek newsletters, product updates, service-related information, and other offers and information from RefTek or its business partners. RefTek also may contact you by e-mail to respond to any customer service inquiries you submit. We do not disclose your e-mail address to business partners or to anyone other than employees and agents working for or on behalf of RefTek, except as required by subpoenas, court orders, or legal requirements. We do not use your e-mail address to correlate your identity to your Internet usage paths. If you do not want to receive RefTek newsletters, offers, and product and service information, simply click the unsubscribe link at the bottom the e-mail address where such information is being sent.

We use cookies for such functions as verifying that you are a Services user and counting and tracking your Web site visits. We further use cookies to determine the number of visitors that use the Services or come to a web site offering the Services through a particular advertisement. Your cookie number is also used to create usage paths and to correlate those with any demographic information you provide, but we do not use your cookies, usage paths to attempt to determine your identity.

We use IP addresses to diagnose problems with our servers and to administer our Web sites. Your IP address also is used by RefTek to gather broad demographic information, such as your general geographic location and Internet Service Provider. IP addresses are further used to help determine the number of Service users. This demographic information may also be used by RefTek to analyze aggregate Internet usage behavior.

How does RefTek share the information it collects?

RefTek does not intentionally disclose personally identifying information collected from any user to any third party without the user's consent.

We provide "stripped" usage path information and demographic information to researchers. They use it to prepare analyses of aggregate Internet patterns and trends. Such analyses are used in research and commercial reports provided to third parties.

We disclose any information we possess in response to subpoenas, court orders, or legal requirements, and such information might be used by the receiving party to determine your identity, your Internet usage, or other things about you. We generally do not inform users of such requests for information, although we might try to do so in some cases.

We employ other companies and individuals to perform functions on our behalf, such as technical support services. To perform those functions, it may be necessary for them to obtain access to RefTek's databases and servers, which may contain personally identifying information about users. They may not use such access or information for any purpose other than that for which they are retained.

In the event that RefTek or substantially all of its assets are sold or acquired, all information collected by RefTek would be transferred to the acquiring party. In any such transfer, however, such information would remain subject to any applicable terms and conditions, including the terms of this Privacy Policy and any amendment thereto.

How We Use Financial Information

For certain Services, you may provide RefTek with certain financial information. We use your financial information to check your qualifications, to bill you for products and services and to enable you to participate in discount, rebate and similar programs in which you may elect to participate. By making a purchase, or engaging in any other kind of activity or transaction that uses financial information you provided during your registration, you consent to our providing your financial information to our service providers and to such third parties as we determine are necessary to support and process your activities and transactions, as well as to your credit card issuer for their purposes. These third parties may include the credit card companies and banking institutions used to process and support the transaction or activity. By using the Service you consent to our providing your financial information to those third parties. Any of these various third parties may be authorized to use your financial information in accordance with our contractual arrangements with such third parties and in accordance with their own privacy policies, over which we have no control, and you agree that we are not responsible or liable for any of their actions or omissions. Additionally, you agree that we may use and disclose all such information so submitted to such third parties in the same manner in which we are entitled to use and disclose any other information that you submit to us.

How can I view or edit my account information?

You can view or edit your Service account information (if applicable) at anytime. In order to view or edit your information, login to your pertinent Service offering. Once logged in, follow the procedures delineating how you can revise your account information.

How is your information protected?

RefTek uses commercially reasonable computer security safeguards to protect its databases and servers against risks of loss, unauthorized access, destruction, misuse, modification, or inadvertent or improper disclosure of data. These risks, however, cannot be completely eliminated and RefTek therefore cannot guarantee complete security.