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Last Updated: February 10, 2010

V12 Group brings together consumers who wish to be informed of special offers, promotions, new products, and other buying opportunities (collectively referred to as "Offers" below) with business clients who wish to identify and contact consumers and who are most likely to be interested in what our clients have to offer. 'Consumers' may include individuals at their home addresses, or business contacts at their place of employment. V12 Group is concerned about consumers' privacy and respects the wishes of those consumers who don't wish to learn about such Offers. The purpose of this Privacy Policy is to give notice of:

• The types of information that V12 Group collects and how we collect it
• How the information is used directly by V12 Group
• What information V12 Group shares with selected third parties and when
• Security of the information collected
• How consumers can gain access to personally identifiable information about themselves and request deletion of that data from V12 Group's records.

V12 Group's Privacy Policy complies with the CAN-SPAM Act, the federal Children's Online Privacy Protection Act, the California Privacy Protection Act, and the Direct Marketing Association (DMA) Privacy Promise. We are members of DMA and the Association for Interactive Marketing.

This policy applies only to privacy policies at the V12 Group sites. Third party sites, including sites with which V12 Group is affiliated, may have different privacy policies. V12 Group is not responsible for the privacy policies of any site other than the V12 Group sites.

What type of information does V12 Group collect and how do we collect it?

Consumer Marketing Database

V12 Group brings together data from various sources to help identify consumers who are more likely to respond favorably to the Offers of its business clients. This includes "Personally Identifying Information," such as first and last names, email addresses, and physical location addresses that V12 Group and our partners collect directly from consumers. V12 Group then correlates that information with other data, such as demographic information, interests, hobbies and purchasing preferences, obtained from multiple sources, which is maintained in personally identifiable form in combination with those consumer names and/or addresses. (All such categories of personally identifiable information and other information maintained in personally identifiable form are referred to below as "Categories.") V12 Group does not include in its database such sensitive information as medical records, social security numbers, credit card numbers or credit history.

V12 Group knowingly collects personally identifiable information only about consumers who have voluntarily given information about themselves by registering at a website (referred to here as "Registration Data"); and have been given clear and conspicuous notice that their electronic mail address or postal mail address or both could be transferred to third parties for the purpose of initiating commercial mail messages by electronic or postal delivery; and have chosen to accept those messages by affirmatively "opting in" or by electing not to "opt out" or by agreeing to accept those messages as a condition of participating in a website. Some of this Registration Data comes to V12 Group from its own online relationships with consumers. Much of the Registration Data comes from other businesses who collect it through their own direct consumer relationships or who accumulate Registration Data that was collected from consumers by others; in each case, they must satisfy V12 Group that the information they supply for the V12 Group database meets these three criteria.

V12 Group then validates in three different ways that the consumers represented in its databases have chosen to accept third party Offers. The first check occurs when V12 Group receives Registration Data from other businesses relating to consumers who are not in the active V12 Group database; V12 Group sends these consumers an email giving them an opportunity to avoid receiving third party Offers by opting out of the V12 Group database. A second check occurs when V12 Group periodically sends all consumers in its active database an email giving them an opportunity to avoid third party Offers by opting out of the V12 Group database. A third check occurs each time an Offer is sent to consumers; with each Offer, consumers are given the opportunity to opt out of receiving further Offers from the same source, or to opt out of the V12 Group database, or to do both.

V12 Group does not knowingly collect personally identifiable information either directly or from third party sources relating to anyone under age 13 and takes reasonable steps to avoid including such information in the V12 Group database.

Business to Business Marketing Database

Our Business to Business Marketing database is a multi-sourced, aggregated file that includes information from the following sources:

• Telephone Directories
• Annual Reports, SEC Filings
• Free Magazines/Newspaper Subscription Offers
• Email Campaigns with offers
• Tradeshow Attendee Lists
• Business Card Collection at over 5000 tradeshows Globally
• Governmental records and filings
• Public Record Information
• Nationwide utility transaction reports
• Phone surveys with every business
• Web-based Registrations and/or offers
• Business trade magazine subscription offers

We also collect information on our website and other branded websites, where from time to time we act as an agent to collect data for some of our partners. When filling out subscription or information request forms, visitors are required to fill out personal data that includes name, job title, company name, address, telephone, fax, email and various other industry questions.

Our sites and partner sites collect opt-in email addresses which may be used for periodic email messages announcing additions to website and/or promoting 3rd party entities. Users have a choice to opt-in for none, one, or both types of periodic email messages. Users who opt-in to receive our announcements only will never have their email addresses sold, shared, or rented. Users that opt-in to receive 3rd party promotional messages will receive them from us, our affiliates and our business partners. In all cases, email list subscribers are given the opportunity to opt-out on each mailing in compliance with the Can Spam Act of 2003 and DMA best practices.

How is the Data directly used by V12 Group?

V12 Group takes Registration Data and combines it with data from other third party sources to create enhanced profiles of the consumers and companies represented in its databases. These profiles may include consumer/household characteristics described above such as demographic information, geographic location, hobbies and purchasing preferences, or business characteristics such as SIC codes, Contact Titles, Geographic location, or other firmographic information.

When a V12 Group business client so requests in connection with a particular Offer, V12 Group analyzes the profiles in its databases to identify consumers and business contacts with characteristics that make them seem more likely to react favorably to the Offer.

V12 Group uses the results of these analyses to send Offers by email to the attention of those consumers and businesses on behalf of its business clients. V12 Group only discloses personally-identifiable data to its business clients for use in connection with Offers approved by V12 Group. By contract, we limit use of the data to the Offer that was approved and forbid any other use. After the data has been used in connection with the Offer, we require that it be permanently erased from client files and databases.

How is the Data used by Clients, Partners and Third Parties?

V12 Group uses the identifiable Consumer and Business information we collect to offer clients a wide variety of information products and services. These products and services include (but are not limited to) lists, customer profiles, models, data enhancements, and turn key marketing programs. V12 Group also licenses our databases to authorized resellers and third parties for marketing purposes. Authorized resellers and third party clients must agree contractually that they operate in compliance with the Can Spam Act of 2003 and DMA best practices.

V12 Group will also disclose information in response to a legal subpoena or other legal process, or if reasonably necessary to protect the property, rights, or safety of V12 Group, it's clients, or the public.

Security of V12 Data

V12 Group takes reasonable and appropriate measures to protect against unauthorized access, alteration, destruction or disclosure of data in the V12 Group databases.

Internally, we restrict employee access to personally identifiable information in our databases on a "need to know" basis and strictly forbid any use of data that is inconsistent with this Privacy Policy.

While we use SSL encryption to protect sensitive information online, we also do everything in our power to protect user information offline. All user information, not just the sensitive information mentioned above, is restricted in our offices. Only employees who need the information to perform a specific job (e.g. billing clerks or customer service representatives) are granted access to personally identifiable information, and then only through password protected screen savers. Furthermore, all employees are kept up-to-date on our security and privacy practices. When new policies are added, our employees are notified and/or reminded about the importance we place on privacy and what they can do to ensure our customers' information is protected. Finally, the servers on which we store personally identifiable information are kept in a secure environment.

We will use all legal procedures at our disposal if any of these rules are violated.

Use of Cookies

From time to time, a cookie may be sent from one of V12 Group's websites to a user's hard drive. Cookies remember information about the user to be recalled at a later time. Cookies are commonly used to customize pages for you based on your browser type or other preferences or information you may have provided through the website.

If a user chooses not to accept cookies they may still use our sites, however cookies enable us to track and target the interests or preferences of our users to enhance their experience while on our site.

Some of our business partners may also use cookies on our site (i.e. advertisers), however we have no access to or control over these cookies.

Use of Log Files

IP addresses are used to analyze trends, administer the website, track user movement, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.

V12 Website Use

By visiting our website, you agree to our use, retention, and disclosure of your information as described in this policy.

How can consumers gain access to personally identifiable information about themselves and request deletion of that data from V12 Group's records?

Anyone can gain access to personally identifiable information in the V12 Group databases relating to him or her for the purpose of checking its accuracy, updating the information, or for any other lawful purpose.

Deletion from the V12 Group Email Databases

As noted above, V12 Group periodically sends an email to all consumers and business contacts in its active databases giving them an opportunity to avoid receiving third party Offers by opting out of the V12 Group databases. This occurs approximately twice per year. Email addresses for business contacts are SMTP Verified Quarterly or upon each rebuild of the marketing database.

Each time an Offer is sent to consumers or business contacts, they are given the opportunity to opt out of receiving further Offers from the same source, or to opt out of V12 Group's databases, or to do both.

Once a consumer or business contact's email address is removed from the active V12 Group databases by one of these means, we will not make any further use of personally identifiable information about the consumer, and will not subsequently give such information to our business clients for their use, in connection with Offers. Also, once removed, your email address will not be added back to our active databases without your specific permission; we will permanently note your election to opt out in a file separate from our active database and as new data comes in, we will cross-match it with the separate file. Any further information about you that comes to us through our own efforts or a third party source will be kept out of our active database.

V12 Group
141 West Front Street,
Suite 410
Red Bank, NJ 07701

1-866-842-1001

Changes to this Privacy Policy

We may change this policy from time to time. We may do so on our own initiative, or in response to new legislation, or for other reasons such as a transfer of ownership of V12 Group, Inc. to a different company with a different privacy policy.

Should this policy be amended, the amended policy will be posted in the Privacy Policy location at the V12 Group site.

For any questions, please contact:
V12 Group
141 West Front Street,
Suite 410
Red Bank, NJ 07701

1-866-842-1001