LeadGenesys Privacy Policy

Our Principles. LeadGenesys takes privacy very seriously and adheres to industry best practice privacy principles with respect to the data collection practices at our Web sites, including the site that you are now visiting and the site that each of our clients uses to access the data we collect on the client's behalf pursuant to the client's instructions. Our fundamental privacy principles incorporate the guidelines suggested by the Federal Trade Commission for web sites that collect personally identifying information - Notice, Choice, Access, and Security - which are discussed below:

• Notice.LeadGenesys is committed to making our data collection practices readily available to you so that you can make informed decisions about your activities at our Web sites.
• Choice. LeadGenesys provides you with the opportunity to elect not to participate in our data collection activities or to participate only as an Anonymous Visitor.
• Access. We provide all visitors to our Web sites with the opportunity to review, modify, and delete any personally identifiable information that has previously been provided.

What We Collect and How We Use It. When you visit this Web site, we collect certain non-personally-identifiable information such as your IP address, what pages you visited, and the time that you visited. We will also collect any personally identifiable information that you may send to us or provide to us on our forms (such as Resume Submission, Request for Information or Newsletter Subscription). We use this information in connection with fulfilling your request, for our own marketing purposes, or to consider your application for employment. We may also provide this information to our marketing partners so that you may receive marketing information from them, but only if you affirmatively request that we do so. Finally, we may forward to our vendors information that you provide to us, but only for the limited purpose of providing a service to us, such as fulfilling on our behalf a request for information about LeadGenesys.

The LeadGenesys system will gather information such as what kind of browser a visitor is on, what operating system they are using, their IP address, and their clickstream information (for example, which pages they have viewed and how long they have been there). Note that information is only gathered while the visitor is on the website in question -- in this case www.leadgenesys.com. LeadGenesys monitors how a visitor arrives at the website, but cannot and will not gather information about other sites the visitor has been on.

When our client users access their data via our secure Web interface, we collect information about the way they use our Services, such as their IP address, the type of browser they are using, and the numbers and durations of site visits. We also collect user ID, username, and password. We use the information that we collect to improve the way that we provide our Services, to relay administrative information, and to verify login information.

LeadGenesys uses pixel tags and other methods to gather information about the emails we send to our registered users and recipients of emails sent by our registered users to others. Pixel tags are tiny graphic files that are included in our HTML-encoded email messages. When such a message is opened in an HTML-capable email program, the recipient's computer will access LeadGenesys' servers to retrieve the pixel tag file, allowing LeadGenesys to record and store information such as email address, date and time the recipient viewed the email message, if the recipient's email program is capable of receiving HTML, and other logging information. LeadGenesys uses this information to optimize delivery of future messages to specific recipients and to provide information to registered users with respect to emails they send through the LeadGenesys System.

LeadGenesys uses a third party for credit card processing. This intermediary is solely a link in the distribution chain, and is not permitted to store, retain, or use the information provided except for the sole purpose of credit card processing.

PRIVACY POLICY FOR OUR PROVISION OF SERVICES

Our Relationships with Our Clients. LeadGenesys serves as an agent for each of our clients, in that we provide our Services solely for the benefit of the client. Each of our clients uses our Services to understand more about the visitors to its Web sites and their interaction with marketing mediums; in this way, our clients can provide more relevant marketing materials and Web environments. We may upon a client's request collect personally identifiable information for that client, such as visitor email address. In each client agreement, we promise that we will not make use of any data that we collect on the client's behalf except as necessary to provide our services to that client. We do not aggregate, sell, transfer, or otherwise disclose it to anyone but the client, or pursuant to the client's instructions. We do, however, reserve a limited right to disclose any data we collect if required by law or valid order of a court or other governmental authority.

Our Clients' Use of Our Services. We ask each of our clients to abide by all applicable laws, rules and regulations, as we promise our clients that we will do ourselves. We also recommend that each client obtain all necessary consents from visitors to its Web site(s), post an online privacy policy that provides each visitor with notice of its data collection and use practices (including the client's use of the Services), and provide a link to an "opt-out" Web page so that any visitor may easily choose to disable our ability to collect his/her data via our Services.

LeadGenesys uses the collected information to set up accounts for customers and their respective companies. We may also use the information to contact customers to further discuss their interest in LeadGenesys, our products and services and to send information on LeadGenesys, our partners, and notices of promotions and upcoming events, if the customer or visitor has so opted to receive these communications. LeadGenesys customers will automatically be subscribed to our email newsletter as part of the set up process. All customers have the opportunity to choose to opt out from receiving our newsletter. Customer information will not be shared or distributed.

LeadGenesys customers will be asked to provide an email address when registering for usage of LeadGenesys products and services. This is used to send notification of product updates and service and support information. Customers can choose to opt out of receiving these notifications. Again, customer information will not be shared or distributed.

Client Legacy and Other Data. Certain of our Services enable each of our clients to combine data that we collect on the client's behalf with legacy data that the client has collected and with data that the client has obtained from other sources. For example, the LeadGenesys Platform allows any of our clients to store data that it collected prior to its relationship with us and combine it with the data that we collect on its behalf. Also, any client may view and combine data that we collect on its behalf with data that has been collected by a LeadGenesys' business partner.

Your Choice. LeadGenesys proactively gives you comprehensive control over information being collected about you as a Web site visitor. Since its inception, LeadGenesys has been a proponent of consumer online privacy and provided the mechanism for online visitors to opt out of having their data collected when they browse at our clients' Web sites. As noted above, LeadGenesys strongly encourages all of its clients to disclose their consumer data collection practices and to adopt the opt-out standard provided by LeadGenesys.

DISCLOSURE OF DATA

LeadGenesys will only disclose your Data (as defined collectively above under the topic What We Collect and How We Use It ), the contents of your private communications, or the contact information of your recipients if required to do so by law, or as otherwise stated in this Statement, or in the good faith belief that such action is necessary to: (1) conform to the edicts of the law or comply with legal process served on LeadGenesys; (2) protect and defend the rights or property of LeadGenesys and others, including among other things to enforce our Terms of Service; (3) act under exigent circumstances to protect the personal safety of its members or the public; (4) to correct technical problems and malfunctions in how we provide our service to you and to technically process your information; (5) to take precautions against liability; (6) to respond to claims that information you have submitted to LeadGenesys has violated the rights or interests of a third party; or (7) as permitted by law or to provide information to law enforcement agencies. Also, certain technical processing of email messages and their content that are required for: (1) sending and receiving messages; (2) conform to connecting networks' technical requirements; (3) conform to the limitations of the Service; or (4 other similar technical connecting requirements.

As we continue to develop our business, we may sell certain of our assets. In such transactions, visitor information likely will be one of the transferred business assets. Also, in the event that LeadGenesys, Inc., or substantially all of its assets is acquired, our visitor information may be an asset that is reviewed and transferred. Such a transaction will be disclosed per the "Notification of Changes" guidelines below. Also, as with the data we collect on behalf of our clients, we reserve a limited right to disclose any data we collect at our sites if required by law or valid order of a court or other governmental authority.

GENERAL GUIDELINES

Our Technology. LeadGenesys uses "cookies" and "Web Beacons" in connection with collecting data at its Web sites and in providing Services to our clients. A cookie is a small text file containing a random and unique alphanumeric identifier that we transfer to your computer's hard drive through your Web browser (unless you set your browser to reject cookies) that enables our systems to recognize your browser. We do not store any personally identifiable information in cookies. A Web Beacon (also known as a "clear GIF", "pixel tag", "data tag" or "image tag") is a mechanism by which a small section of code that our clients place on their website pages executes an image request to our data collection servers. Our Web Beacons facilitate the transfer of data by requesting and delivering the transparent graphic GIF image from LeadGenesys to our client's website pages.

Data Security. LeadGenesys has taken proactive measures to protect against the loss, misuse, or alteration of data that is under our control. Every step has been taken with the view to ensuring maximum security for data transfer and storage. Our infrastructure employs leading technology solutions for end-to-end security, which protects data at each point of transfer: from receipt to storage to reporting. We employ redundant systems (i.e., multiple back-up systems) for reduced chance of data loss, and for up-to-date and accurate information. We also employ internal policies and procedures limiting our employees' and vendors' access to client data and other client confidential information, so that access is permitted only to fulfill our contractual agreements with our clients and consistent with this Privacy Statement.

If You Contact Us. We answer the email we receive by sending an email response to the sender. We also store the email we receive for archival purposes and for our own marketing purposes if we feel that it is consistent with the nature of the inquiry. We will not use return email addresses for any other purpose unless you give us permission to do so.

Notification of Changes. If we decide to change our privacy policy, we will post those changes to this privacy statement, the homepage, and other places we deem appropriate so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If, however, we are going to use users' personally identifiable information in a manner different from that stated at the time of collection we will notify users by posting a notice on our Web site for 30 days.

VISITOR OPT OUT

Update Your Information. We provide all visitors to our Web sites with the opportunity to review and modify any personally identifiable information that has previously been provided. You can send an email to , or call us at (415) 392-0333.

Unsubscribe from Our Mailing List. You may at any time ask us to remove you from any mailing list on which you previously asked us to include you by emailing , or by calling us at (415) 392-0333.

Other Web Sites. This privacy statement applies solely to information collected by this Web site, which contains links to other sites. Please be aware that we are not responsible for the privacy practices of these other sites. We encourage our visitors to be aware when they leave our site and to read the privacy statements of each and every Web site that they visit.

European Union Safe Harbor Compliance Statement

European data-privacy laws protect Personal Information that is transferred from the European Union to the United States. The U.S. and E.U. have entered into a "Safe Harbor" that allows U.S. entities receiving Personal Information from the E.U. to satisfy those obligations. The provisions of this Policy satisfy the Safe Harbor Principles. LeadGenesys has certified that compliance with the United States Department of Commerce. Because, as explained above, we simply use the Personal Information provided to us to deliver messages and provide related services for our customers, under the Safe Harbor our customers remain responsible for that Personal Information with respect to the individuals concerned. Any additional Personal Information we collect as a result of our Services is provided only to the customer for whom it is collected. LeadGenesys' compliance with this Policy is subject to the ultimate authority of the United States Federal Trade Commission, to which complaints that are not adequately resolved through the procedure set forth in paragraph 12 above also may be directed.

For more information you can contact LeadGenesys at:

LeadGenesys, Inc.
Pacific Stock Exchange Building
155 Sansome Street, 6th Floor
San Francisco, CA 94104