OTC VILLAGE PRIVACY POLICY

Effective Date: September 1, 2006

Thank you for visiting the website located at www.otcvillage.com (the "Site"). The Site is an Internet property of OTCVillage, LLC ("OTCVillage™," "we," "us"). OTCVillage™ has created this privacy policy (the "Privacy Policy") in order to disclose our information gathering and dissemination practices. We understand the importance that Internet users place on privacy and have designed our Site with this in mind. The Site fosters an environment that allows investors, companies and end-user visitors to access and disseminate information and other analysis and research regarding a wide range of businesses, products and services. While the Site remains available to end-user visitors without any registration requirements ("Non-Registered Users"), in order to utilize some of the Site's enhanced features, interested parties must either: 1) register as an investor ("Registered Investor") on the Site, which enables end-users to access the various Registered Investor-based services as described in the OTCVillage™ Registered Investor Agreement ("Registered Investor Agreement"); 2) register as a member company ("Member Company") of the Site, which enables corporate entities to utilize a host of services made available to Member Companies through the Site as described in the OTCVillage™ Member Company Agreement ("Member Company Agreement" and, together with the Registered Investor Agreement, the "Agreements"); and/or 3) register as a contestant ("Contestant" and, together with the Registered Investors and Member Companies, "Registered Users") in one of our sweepstakes, promotional offers or contests (the "Contests"). In order to complete these Agreements and/or enter the Contests, applicants must supply certain personally identifiable information. None of the information that we gather can be used by the public to identify specific individuals.  We are an optional service. We collect credit card, address, bank and/or other personal information only from those individuals/entities that choose to participate. Because we offer a variety of services to distinct users, our Privacy Policy contains two (2) separate sets of terms and conditions: one for our Non-Registered Users and one for our Registered Users.

If you are a resident of the State of California and would like to opt-out from the disclosure of your personal information to any third-party for marketing purposes, please Click Here. Please be advised that where California State residents opt-out from permitting their personal information to be shared, such individuals may still receive selected offers directly from us, in accordance with the law.

I. Non-Registered Users

Information Collected/Tracked by OTCVillage™

As a general rule, OTCVillage™ does not request or collect any personally identifiable information directly from Non-Registered Users. We gather Non-Registered Users' server, IP address and browser-type related information as part of the general administration of the Site ("Site Data"). This Site Data is comprised of the demographic, usage and/or other characteristics of Site visitors as a group without any associated personally identifiable information. When a Non-Registered Users visits the Site, we send a cookie and/or gif file ("Cookie") to assign an anonymous, unique identifier to the applicable Non-Registered User's Internet browser. A Cookie is a piece of data stored on your hard drive containing non-personally identifiable information about you. Cookies have many benefits to enhance your experience at the Site. To find out more about Cookies, please visit www.cookiecentral.com. To disable and reject certain Cookies, Click Here. Even in the case where a user rejects a Cookie, he or she may still use the Site. OTCVillage™ reserves the right to retain Cookie data indefinitely.

Use of Information Obtained by OTCVillage™

As a general rule, OTCVillage™ does not collect or share any personally identifiable information that it obtains from Non-Registered Users. OTCVillage™ reserves the right to release current or past Site Data: (a) in the event that we believe that the Site is being or has been used in violation of this Privacy Policy, the OTCVillage™ Website Terms and Conditions ("Terms and Conditions"), either of the Agreements or to commit unlawful acts; (b) if the information is subpoenaed; or (c) if OTCVillage™ is sold or acquired. While OTCVillage™ strongly encourages clients, affiliates and partners to adopt responsible approaches to online marketing, OTCVillage™ is not responsible for the information practices of its clients, affiliates and/or partners. The collection, use and disclosure of information by clients, affiliates and/or partners is subject to their respective privacy policies, which may differ from the Privacy Policy. OTCVillage™ reserves the right to use all Site Data associated with Non-Registered Users to investigate fraudulent or other claims made against OTCVillage™.

Changes in our Privacy Policy

If we change our Privacy Policy, we will prominently post a link to those changes on our Site's Homepage so that our Non-Registered Users are always aware of what information we collect, how we use it and under what circumstances, if any, we disclose it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify Non-Registered Users by way of an e-mail. The Non-Registered User's continued use of the Site after posting of the Privacy Policy change on the Site, or receipt of a Privacy Policy change notification e-mail, as applicable, constitutes an affirmative acknowledgement and acceptance by the Non-Registered User of the modified Privacy Policy.

Security

OTCVillage™ takes every precaution to protect our Non-Registered Users' information. OTCVillage™ regularly reviews, at least once per year, its Non-Registered User information security practices to identify security threats or opportunities for improvement. When Non-Registered Users submit sensitive information via the Site, we endeavor to keep the information protected both online and off-line. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot ensure or warrant the security of any information that you transmit to us, and you do so at your own risk. All Site Data and other information is restricted in our offices. Only employees who need the Site Data and other information to perform a specific job are granted access to it. All such employees are contractually bound to adhere to our security protocols, which they must verify that they have read and understand. The practices for handling sensitive information are disseminated to all of our employees. In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your personal information. You will be notified via e-mail in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage and to engage in remedial measures. If you have any questions about the security related to the Site, please Contact Us.

Limitation of Liability, Third Party Information & Language

YOU UNDERSTAND AND AGREE THAT ANY DISPUTE OVER PRIVACY IS SUBJECT TO THIS PRIVACY POLICY AND THE TERMS AND CONDITIONS. YOU AGREE THAT OTCVILLAGE'S™ LIABILITY FOR ANY BREACH OF THIS PRIVACY POLICY SHALL BE LIMITED TO $300, TO THE EXTENT SUCH CLAIM IS NOT OTHERWISE BARRED BY THE TERMS AND CONDITIONS.

II. Registered Users

Information Collected/Tracked by OTCVillage™

OTCVillage™ gathers two types of information: information that Registered Users submit to us and information that is not directly submitted by Registered Users.

Information Submitted to OTCVillage™

To accomplish our goal of bringing Registered Investors and Member Companies together, and to administer the Contests, we must gather personal information from all Registered Investors, Member Companies and Contestants through the applicable OTCVillage™ sign up and registration process, which may or may not require submission of the following information: e-mail address, first name, last name, date of birth, credit card number, corporate contact information, a user-specified password, mailing address, zip code and telephone number.

Information not Directly Submitted by Registered Users to OTCVillage™

We gather Registered Users' server, IP address, browser-type, clicks, impressions and other traffic and/or consumer action related information in connection with the general administration of the Site ("Site Data"). OTCVillage™ reserves the right to transfer and/or sell Site Data about Registered Users for lawful purposes. The Site Data is comprised of the demographic, usage and/or other characteristics of Registered Users as a group. By submitting your personal information to, and/or using, the Site, you agree to allow OTCVillage™ to transfer and/or sell such aggregate data to third parties.

When a Registered User visits the Site, we send a cookie and/or gif file ("Cookie") to assign an anonymous, unique identifier to the applicable Registered User's Internet browser. A Cookie is a piece of data stored on your hard drive containing non-personally identifiable information about you. Cookies have many benefits to enhance your experience at the Site. To find out more about Cookies, please visit www.cookiecentral.com. To disable and reject certain Cookies, Click Here. Even in the case where a user rejects a Cookie, he or she may still use the Site. OTCVillage™ reserves the right to retain Cookie data indefinitely. Use of Information Obtained by OTCVillage™

Sharing of the Information Gathered/Tracked by the Site

Any personal information that you submit at the Site remains your property. However, by submitting that information to us, you grant to us the right to use your personal information, subject to applicable state and federal law, in the ways set forth herein. Other than as set forth herein to the contrary, all personally identifiable information that OTCVillage™ collects from Registered Users is intended for administrative needs (e.g., billing, communication of account information), for which purpose such data is required.

OTCVillage™ may use e-mail addresses of Registered Investors and Contestants in its own proprietary database ("OTCVillage™ Database"). OTCVillage™ reserves the right to contact individuals in the OTCVillage™ Database via e-mail with research, analysis, company profiles, offers and other information that OTCVillage™ deems might be of interest to such individuals.

Upon request, and in OTCVillage's™ sole discretion, OTCVillage™ may contact individuals in the OTCVillage™ Database via e-mail on behalf of certain Member Companies ("Company E-mail") for the sole and exclusive purpose of enabling such Member Companies to provide such individuals with information, analysis, research and other information about such Member Companies that may be of interest to applicable Registered Investors or Contestants; provided, however, that OTCVillage™ will not share the e-mail addresses contained in the OTCVillage™ Database with such Member Companies. The Company E-mail contain(s) comments, opinions, analyses, information and other content that are provided directly by Member Companies. OTCVillage™ shall have no obligations and incur no liabilities to Registered Members or Contestants in connection with any such analyses, research, information or opinion appearing within the Company E-mails. OTCVillage™ does not represent or warrant that the comments, opinions, analyses, information and other content posted in the Company E-mails is accurate, complete or appropriate.

The collection, use and disclosure of information by Member Companies, clients, affiliates and partners of OTCVillage™ is subject to their respective privacy policies, which may differ from this Privacy Policy. While OTCVillage™ strongly encourages Member Companies to adopt responsible approaches to online communication, marketing and other practices, OTCVillage™ is not responsible for the conduct of Member Companies or their partners.

Except as may be otherwise agreed between OTCVillage™ and a Registered User, and as otherwise set forth herein to the contrary, all personally identifiable information provided by individual Registered Users will be kept in strict confidence by OTCVillage™ and will be treated with the same level of confidentiality that it treats other proprietary information and trade secrets. OTCVillage™ will never sell, rent, exchange or barter any personally identifiable Registered User information to or with any third party for financial gain or marketing purposes.

Notwithstanding the foregoing, OTCVillage™ may sell, or otherwise transfer, Member Company names, and the names of Member Companies' chief financial officers and other publicly available Member Company contact information, to certain third party partners of OTCVillage™. OTCVillage™ may share personally identifiable information in connection with its affiliated entities or in connection with the sale, merger, consolidation, change in control, transfer of substantial assets or reorganization or liquidation of OTCVillage™. OTCVillage™ may release account and any other personally identifiable information when we believe release is appropriate to respond to a subpoena or otherwise comply with the law; enforce or apply this Privacy Policy, the Agreements, the Terms and Conditions and other agreements; and/or to protect the rights, property or safety of OTCVillage™ or others. This includes exchanging information with other companies and organizations for fraud protection.

To the extent that OTCVillage™ collects your credit card-specific information, if ever, we will use the information to process and complete any transaction that you request. By submitting your credit card information to us, you authorize OTCVillage™ to periodically verify that your credit card account continues to be a valid and active one by charging, and thereafter immediately crediting, a small sum to the card. Such verification may be conducted through a third-party and, in that case, OTCVillage™ would share your specific credit card information with this third-party for verification purposes. Apart from said uses, we will not share your credit card information with any third-parties without your prior informed consent. Notwithstanding the foregoing, OTCVillage™ reserves the right to share with third-parties the fact that we have credit card information on file for specific users, but we will not share your specific credit card information with third-parties without your prior informed consent.

Correcting/Updating or Removing Information

OTCVillage™ provides Registered Users with several options for modifying or removing their information from our database. Please visit the MyOTCVillage page or Contact Us for an explanation.

Changes in Our Privacy Policy

If we change our Privacy Policy, we will prominently post a link to those changes on our Site's homepage so that our Registered Users are always aware of what information we collect, how we use it and under what circumstances, if any, we disclose it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify Registered Users by way of an e-mail. The Registered User's continued use of the applicable OTCVillage™ service, Site and/or continued receipt of OTCVillage™ e-mails after posting of the Privacy Policy change on the Site, or receipt of a Privacy Policy change notification e-mail, as applicable, constitutes an affirmative acknowledgement and acceptance by the Registered User of the modified Privacy Policy.

Security

OTCVillage™ takes every precaution to protect our Registered Users' information. OTCVillage™ regularly reviews, at least once per year, its Registered User information security practices to identify security threats or opportunities for improvement. When Registered Users submit sensitive information via the Site, we endeavor to keep this information protected both online and off-line. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot ensure or warrant the security of any information that you transmit to us, and you do so at your own risk. When we ask Registered Users to enter sensitive information (such as a credit card number), and when such information is stored and/or transmitted, that information is encrypted and is protected with SSL encryption software. While we use SSL encryption to protect sensitive information online, we also do everything in our power to protect Registered User information off-line. All of our Registered Users' information, not just the sensitive information mentioned above, is restricted in our offices. Only employees who need the information to perform a specific job (for example a billing clerk or a customer service representative) are granted access to personally identifiable information. All such employees are contractually bound to adhere to our security protocols, which they must verify that they have read and understand. The practices for handling sensitive information are disseminated to all of our employees. In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your personal information. You will be notified via e-mail in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage and to engage in remedial measures.

If you have any questions about the security related to the Site, please Contact Us.

E-mail Choice/Opt-out

Registered Users who no longer wish to receive our notification e-mails or newsletters may opt-out of receiving these communications by following the instructions contained in all e-mail communications that they receive from us.

Limitation Of Liability, Third Party Information & Language

YOU UNDERSTAND AND AGREE THAT ANY DISPUTE OVER PRIVACY IS SUBJECT TO THIS PRIVACY POLICY AND THE TERMS AND CONDITIONS AND/OR YOUR REGISTERED INVESTOR AGREEMENT OR MEMBER COMPANY AGREEMENT, AS APPLICABLE. YOU AGREE THAT OTCVILLAGE'S™ LIABILITY FOR ANY BREACH OF THIS PRIVACY POLICY SHALL BE LIMITED TO THE GREATER OF THE VALUE OF THE TOTAL FEES YOU PAID TO OTCVILLAGE™ OR $300, TO THE EXTENT SUCH CLAIM IS NOT OTHERWISE BARRED BY THE TERMS AND CONDITIONS AND/OR YOUR REGISTERED INVESTOR AGREEMENT OR MEMBER COMPANY AGREEMENT, AS APPLICABLE. You also agree that you have provided notice to, and obtained consent from, any and all third party individuals whose personal information you supply to OTCVillage™.

III. General Provisions

Links

The Site contains links to other websites. Please be aware that OTCVillage™ is not responsible for the privacy practices of other websites. We encourage our Registered and Non-Registered Users to be aware when they leave the Site and to read the privacy policies of each and every website that collects personally identifiable information. This Privacy Policy applies solely to information collected by the Site.

Children's Privacy

OTCVillage™ is very sensitive to the issue of children's privacy and, therefore, we endeavor to protect the privacy of children using the Internet. The Site, products and services are not developed for or directed at children. Visitors under eighteen (18) years of age are not eligible to do business with us and we do not knowingly solicit or collect personal information from any person that we actually know is under the age of eighteen (18). OTCVillage™ encourages parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children. If you believe that your child has provided OTCVillage™ with any personally identifiable information, please e-mail info@otcvillage.com to have this information removed.

Contacting the Site

If you have any questions about this Privacy Policy, the practices of the Site, or your dealings with the Site, please Contact Us.