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ClearPath Security, LLC
 Privacy Statement
 Last Updated: January 2006
We are committed to protecting your privacy. This Privacy Statement only applies to this site and governs data collection and usage by us; it does not apply to other online or offline sites, products or services. Please read this entire Privacy Statement and also any supplementary information that may be listed on specific pages within the ClearPath Security, LLC Web sites for additional details about particular ClearPath Security, LLC Websites/Services that you may use.

We encourage you to review the privacy statements of Web sites you choose to link to from us so that you can understand how those Web sites collect, use and share your information. We are not responsible for the privacy statements or other content on Web sites that may be linked to from our Web site.

ClearPath Security, LLC is the sole owner of the information we gather on/from our Web Sites/Services. ClearPath Security, LLC will only share your information with outside parties in ways that are described in this privacy statement. ClearPath Security, LLC abides by the safe harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of data from the European Union. Upon reading this Privacy Statement, you will know:

1) What personally identifiable information of you or third party personally identifiable information is collected from you through the ClearPath Security, LLC Web sites.

2) The organization collecting the information.

3) How the information is used.

4) With whom the information may be shared.

5) What choices are available to you regarding collection, use and distribution of the information.

6) The kind of security procedures that are in place to protect the loss, misuse or alteration of information under ClearPath Security, LLC's control.

7) How you can access and correct any inaccuracies in the information collected about you.

In accordance with the Gramm-Leach-Bliley Act of 1999, annual privacy notices for customers receiving Financial Services will be provided through the continual posting of the current version of this privacy statement in a clear and conspicuous manner on this Web site. By using our Financial Services, you acknowledge receipt of this statement and agree to receive subsequent privacy notices in this manner on an on-going basis.

1) Collection of your Personal Information

On some web pages we may collect personal information, such as your e-mail address, name, home or work address or telephone number. We may also collect demographic information, such as your ZIP code, age, gender, preferences, interests and favorites. Information collected by us may be combined with information obtained from our business partners and other companies.

We may also collect certain information about your computer hardware and software. This information may include: your IP address, browser type, domain names, access times and referring Web site addresses. This information is used by us for the operation of the Web site, to maintain quality of our online services, and to provide general statistics regarding use of our systems.

We keep track of the pages you visit within our Web site in order to determine what services are the most popular. This data is also used to deliver customized content.

You may occasionally see a message informing you of a critical performance error in your browser, a ClearPath Security, LLC Website/Service. This message may ask you to send data to ClearPath Security, LLC If you agree, the software will automatically collect and send the data needed to help ClearPath Security, LLC determine what caused the error. Before you choose to send your data to ClearPath Security, LLC, you have the opportunity to review that data. If you choose to send the data, in some cases your personal information may also be sent to ClearPath Security, LLC.

As part of providing you with online Financial Tools for managing your personal finances, we may request that you furnish personal information such as estimated account balances in order to provide you with online analysis, reports and other requested financial information. We will not attempt to obtain any of your personally identifiable financial information such as account numbers, credit card numbers, or stock and bond portfolio identification numbers. The financial information you provide to the ClearPath Security, LLC's Financial Tools will not be transmitted, reviewed, made available, nor retained by any of our servers or personnel; the information will only be used by financial analysis and reporting tools that are executed within your browser and secured by you.

When you subscribe to one of our Newsletters, we request your e-mail address. We use your e-mail address to send you the newsletter(s) you have requested. You may subscribe and unsubscribe to our Newsletters by going to newsletters in our knowledge base. In addition, each newsletter you receive will have instructions on how to unsubscribe prominently mentioned in it.

2) Organization Collecting the Information

ClearPath Security, LLC and our operational service partners collect and use your personal information to operate the ClearPath Security, LLC's Web sites/Services.

3) Use of your Personal Information

We use your personal information to inform you of other products or services available from ClearPath Security, LLC and our affiliates. We may also contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered.

We do not sell, rent or lease our customer lists to third parties. We may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your personal information (e-mail, name, address, telephone number) is not transferred to the third party. ClearPath Security, LLC does not use or disclose sensitive personal information, such as race, religion, or political affiliations, without your explicit consent.

4) Sharing of your Personal Information

Certain ClearPath Security, LLC services may be co-branded and offered in conjunction with another company. If you register for or use such services, both ClearPath Security, LLC and the other company may receive information collected in conjunction with the co-branded services. In such cases, either a joint privacy statement or a link to the other company's privacy statement will be provided, which will provide you with information about how the other company will use the information and how you can contact the other company with requests to access the information or other inquiries.

We occasionally hire other companies to provide limited services on our behalf, such as handling the processing and delivery of mailings, providing customer support, processing transactions, or performing statistical analysis of our services. We will only provide those companies the personal information they need to deliver the service. They are required to maintain the confidentiality of your information and are prohibited from using that information for any other purpose.

ClearPath Security, LLC may access and/or disclose your personal information if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on ClearPath Security, LLC or the site; (b) protect and defend the rights or property of ClearPath Security, LLC, including its family of Web sites and Services; or (c) act under exigent circumstances to protect the personal safety of users of ClearPath Security, LLC services or members of the public.

Personal information collected on this site may be stored and processed in the United States or any other country in which ClearPath Security, LLC or its affiliates, subsidiaries or agents maintain facilities, and by using this site, you consent to any such transfer of information outside of your country. ClearPath Security, LLC abides by the safe harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of data from the European Union.

5) Control of your Personal Information

ClearPath Security, LLC offers its customers choices for the collection, use and sharing of personal information. You may proactively make choices about the use and sharing of your personal information. You may choose not to receive marketing material from ClearPath Security, LLC or on behalf of external third party business partners.

You may also stop the delivery of future promotional e-mail from ClearPath Security, LLC by following the specific instructions in the e-mail you receive. The instructions explain how to stop receiving such e-mails.

There are some ClearPath Security, LLC services that send out periodic e-mails informing you of technical service issues, product surveys, new feature announcements and news about ClearPath Security, LLC's products and services. You will not be able to unsubscribe to these mailings, as they are considered a part of the service you have chosen.

6) Security of your Personal Information

ClearPath Security, LLC is committed to protecting the security of your personal information. We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. For example, we store the personal information you provide on computer systems with limited access, that are located in controlled facilities. When we transmit highly confidential information over the Internet, we protect it through the use of encryption, such as the Secure Socket Layer (SSL) protocol.

Use of Cookies
ClearPath Security, LLC uses "cookies" to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a Web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. For example, if you personalize ClearPath Security, LLC's pages, or register with ClearPath Security, LLC sites or services, a cookie helps ClearPath Security, LLC to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to ClearPath Security, LLC, the information you previously provided can be retrieved, so you can easily use the ClearPath Security, LLC features that you customized.

You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the features of the ClearPath Security, LLC's Web sites/Services.

Use of Web Beacons
ClearPath Security, LLC Web pages may contain electronic images known as Web beacons - sometimes called single-pixel gifs - that allow ClearPath Security, LLC to count users who have visited those pages and to deliver co-branded services. ClearPath Security, LLC may include web beacons in promotional e-mail messages or ClearPath Security, LLC Newsletters in order to count how many messages have been opened and acted upon. Web beacons are not used to access your personal information on the ClearPath Security, LLC network of sites and services; they are a technique we use to compile aggregated statistics about ClearPath Security, LLC's Web site usage.

Web beacons collect only a limited set of information including a cookie number, time and date of a page view, and a description of the page on which the Web beacon resides. ClearPath Security, LLC Web pages may also contain Web beacons placed there by third parties to help determine the effectiveness of our Websites/Services.

No Third Party Ad Networks
We do not use online banner advertisements and we do not allow any other companies, called third-party ad servers or ad networks, to display advertisements on any of our Web pages. We do not allow ad networks to place any cookies, temporary or persistent, on your computer. We do not allow any ad networks to recognize your computer or compile information about you, your computer, or others who use your computer.

7) Access and Corrections to your Personal Information

Reasonable access to personally identifiable information will be provided within 30 days at no cost to you. If access cannot be provided within that timeframe, ClearPath Security, LLC will provide you with a date when the information will be provided.

Enforcement of this Privacy Statement

If you have questions regarding this privacy statement, you should contact us via e-mail.

Changes to this Statement

We will occasionally update this Privacy Statement to reflect company and customer feedback. When we post changes to this Statement, we will place the date of the change(s) after the Privacy Statement link on the front page of the ClearPath Security, LLC Website. We encourage you to periodically review this Privacy Statement to stay informed of how we are protecting your information.

Contact Information

We welcome your comments regarding this Privacy Statement. If you believe that we have not adhered to this Privacy Statement, please contact us by telephone, e-mail, or postal mail.

2004 ClearPath Security, LLC All rights reserved.



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