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PRIVACY POLICY

(Revision December 02, 2009)

This Privacy Statement for Spy Tec Inc. ("Privacy Statement") details the company's policies with respect to the handling of personally identifiable information ("Information") submitted by the reader of this Privacy Policy ("You") or otherwise collected by Spy Tec Inc. via the company's web site or in the course of providing services to Spy Tec Inc's customers. Spy Tec Inc. will use and disclose Information only in accordance with the terms of this Privacy Statement.

A. COLLECTION OF INFORMATION

The type of Information submitted to or collected by Spy Tec Inc. varies depending upon the nature of the activity and relationship with Spy Tec Inc..

  1. 1. BROWSING THE WEBSITE:

When You browse the company's web site, Spy Tec Inc. may collect information regarding the domain and host from which You access the Internet, the Internet Protocol address of the computer or Internet Service Provider You are using, and anonymous site statistical data. This information is collected for the purpose of assessing the effectiveness of the company's web site and for security reasons.

  1. 2. INQUIRIES:

The web site contains various forms, links to company e-mail addresses, and fax numbers that You may use to solicit information about the web site, Spy Tec Inc. services, and the company in general. When You complete and submit a form, send us an e-mail, send us a fax, or contact us by telephone, Spy Tec Inc. may store the inquiries and their contents, including any personally identifiable information You may have provided. Any personally identifiable information You submit via an inquiry is collected only with Your knowledge and active participation.

  1. 3. USE OF GATEWAY SERVICE:

When You register to use Spy Tec Inc. online processing services ("Gateway Services"), You will be required to provide personally identifiable information and to enter into a written agreement with Spy Tec Inc.. If You ordered any products or services from businesses that use our Gateway Services ("Spy Tec Inc. Customers"), You were required to submit personally identifiable information ("Order Information"). Spy Tec Inc. Customers transmit Order Information to Spy Tec Inc. for the purpose of processing Orders. Order Information is maintained in servers located within the U.S.A. and may also be maintained in servers located in Europe or Asia, depending on where the order originates or the geographic location of a Spy Tec Inc. Customer. Spy Tec Inc. may maintain Order Information for a certain period of time to comply with audits or for disaster recovery purposes.

  1. 4. NOTICE FOR EUROPEAN USERS:

The Data Protection Act puts obligations on users of personal information and sets forth principles for its use. One principle states that information must be processed fairly and lawfully.

This means that You are entitled to know how we intend to use any information You provide. You can then decide whether You want to give personal information to us. The Data Protection Act does not generally apply to data about limited companies or partnerships, but it does cover personal data relating to sole traders and partnerships. When we receive an application from a business, we may perform a search with a credit reference agency and fraud prevention agency on the individual company directors or partners. Order Information provided by You to Spy Tec Inc. Customers and any Information that You provide to Spy Tec Inc. directly will be transferred outside of the European Union to the United States. By providing personal information to Spy Tec Inc. Customers or us, You are consenting to the transfer of such information outside of the EU and to its storage and use as described herein.

B. USE AND DISCLOSURE OF INFORMATION

Usage and disclosure of Your Information varies based on Your relationship with Spy Tec Inc.. Spy Tec Inc. never sells any personally identifiable information and, except as expressly set forth below, never discloses personally identifiable information to any third parties.

  1. 1. BROWSING THE WEBSITE:

Information collected while You're browsing our web site may be used to analyze trends, administer the web site, improve site performance, gather broad demographic information, and for security purposes. Such Information may be disclosed to third parties to provide any of the aforementioned activities on behalf of Spy Tec Inc..

  1. 2. INQUIRIES:

Information collected during the course of You submitting an inquiry via online form, e-mail, fax, or telephone call may be used by Spy Tec Inc. to respond to Your inquiries or to contact You to inform You of services of Spy Tec Inc. that may be of use to You. Information collected during the course of an inquiry will not be disclosed to any third party unless such third party has been contracted by Spy Tec Inc., with obligations of confidentiality, to contact You on our behalf.

  1. 3. USE OF SPY TEC INC. SERVICES:

If You are a Spy Tec Inc. Customer, Spy Tec Inc. will use Your Information during the course of providing You with the Gateway Services. During the course of providing such services, Spy Tec Inc. may disclose Your Information to third parties that have contracted with Spy Tec Inc. to perform certain functions of the Gateway Services on our behalf ("Subcontractors"). Spy Tec Inc. may also use Your Information to contact You about other Spy Tec Inc. offerings and to inform You about general company news and industry trends, directly or through the use of third party vendors. Spy Tec Inc. may also use Your Information for internal business analyses. If You are a customer of a Spy Tec Inc. Customer, Spy Tec Inc. will use Order Information during the course of providing processing services to such Spy Tec Inc. Customer. Spy Tec Inc. may also use Order Information at an aggregate level for internal business analyses and fraud prevention. During the course of providing Gateway Services to Spy Tec Inc. Customers, Spy Tec Inc. may disclose Order Information to banks, processors, card associations, and other financial institutions that are involved in the course of processing or screening the transaction applicable to the Order Information.

  1. 4. SURVEYS AND QUESTIONNAIRES:

If You submitted an inquiry to Spy Tec Inc. or if You are a Spy Tec Inc. Customer, periodically, Spy Tec Inc. may use Your Information to contact You, directly or through a third party vendor, to complete a survey or questionnaire. Responses to any such survey or questionnaire may be used for internal business analyses and may be disclosed in aggregate form without disclosing any personally identifiable information.

  1. 5. USE OF COOKIES

Forms on our web site may use cookies. Cookies are small files of data that reside on Your computer and allow Spy Tec Inc. to recognize You as a Spy Tec Inc. Customer or a previous visitor of our web site. Spy Tec Inc. may use cookies to populate frequently used forms or to provide You with other customized viewing options for Your convenience. Spy Tec Inc. uses cookies solely to maintain personalized services throughout the web site.

  1. 6. CONFIDENTIALITY OBLIGATIONS:

All contracts entered into between Spy Tec Inc. and Spy Tec Inc. Customers, Spy Tec Inc. and Subcontractors, and Spy Tec Inc. and other third party service providers contain express provisions governing the confidential treatment of any and all personally identifiable information.

  1. 7. INVESTIGATIONS AND PROCEEDINGS:

Spy Tec Inc. may use Information to conduct internal investigations. Spy Tec Inc. may disclose Information to cooperate with an investigation by law enforcement agencies or other governmental authorities and may also disclose Information in response to a subpoena, warrant, court order, or other comparable legal processes.

C. INFORMATION SECURITY

Spy Tec Inc. is committed to privacy and security. Spy Tec Inc. is compliant with the Payment Card Industry Data Security Standard ("PCI DSS") Spy Tec Inc. has been compliant with PCI DSS since its inception in 2002. PCI DSS is the bank card industry's most stringent security standard. Examples of Spy Tec Inc's security measures include: physical, electronic, and procedural safeguards; sophisticated security monitoring tools; documented security policies; use of strong encryption for transmissions of Order Information to and from Spy Tec Inc. Customers; restricted access of personally identifiable information; and, periodic security audits by third party security experts.