1. Effective date of the policy
   August 1, 2009

2. Scope of the policy
   At CompliancePoint, we know you care about your personal privacy and about the terms and conditions that govern your use of this Website (this "Site"). Because we are dedicated to serving your needs and respecting your preferences, we have adopted the policies and practices described in this Privacy Policy and Conditions of Use.  This policy applies equally to the following domain:
   
   www.compliancepoint.com

3. General Legal Notice and Disclaimer
   Access to the publicly available information contained on this Website is provided by CompliancePoint to its customers and non-customers. References herein to any legal summary, product, process or service do not constitute or imply endorsement or recommendation by CompliancePoint. While we make every effort to present accurate and reliable information on this site, CompliancePoint does not approve or certify such information nor does it guarantee the accuracy, completeness, efficacy, timeliness or correct sequencing of such information. Use of such information is voluntary and reliance on it should only be undertaken after an independent review of its applicability, accuracy, completeness, efficacy and timeliness with regard to each user’s specific needs. CompliancePoint (including its employees and agents) is not responsible for, and expressly disclaims all liability for, damages of any kind arising out of use, reference to or reliance on the information available through this Site. CompliancePoint makes no approvals, recommendations, endorsements, guarantees or warranties, including, but not limited to, any express or implied warranties of merchantability or fitness for any particular use or purpose of products or services named on this Site.

4. The information we gather (both active and passive)
   CompliancePoint collects several categories of information about and on behalf of customers and prospective customers in order to administer accounts and provide services. This data includes Non-Public Personal Information (NPPI) as well as sensitive information. 
    

1. Personally identifiable information
   CompliancePoint collects personal information on its Websites when users fill out information request forms. 

2. Use of cookies and Web beacons
   CompliancePoint does not use Web beacons or clear gifs on any of our Websites.  We automatically collect and store; the name of the domain and host from which you access the Internet; the Internet protocol (IP) address of the computer you are using; the browser software you use and your operating system; the date and time you access our sites; and the Internet address of the site from which you linked directly to our sites.
   
   We use this information only as anonymous aggregate data to determine the number of visitors to different sections of our sites, to ensure the sites are working properly, and to help us make our sites more useful. We do not use it to track or record information about individuals. Generally, we delete this information after one year.
   
   A "cookie" is a small text file that a Website can place on your computer's hard drive in order, for example, to collect information about your activities on the site or to make it possible for you to use an online "shopping cart" to keep track of items you wish to purchase. The cookie transmits this information back to the Website's computer which, generally speaking, is the only computer that can read it. Many consumers do not know that "cookies" are being placed on their computers when they visit Websites. If you want to know when this happens, or to prevent it from happening, you can set your browser to warn you when a Website attempts to place a "cookie" on your computer.
   
   The only persistent cookies that CompliancePoint uses are Google Analytics code. These are first-party cookies. Google Analytics collects, tracks and analyzes site statistics. These cookies do not collect any personally identifiable information and are only used for the statistical collection of data such as page hits. Google Analytics also utilize session cookies to anonymously collect a visitor’s IP address and the date and time of the visit. Session cookies are temporary files that are erased when you close all browsers. We use these session cookies for site management purposes. Accepting session cookies on our sites is voluntary; you may still use the site if you decline cookies.

5. How we use the information we gather
   In general, we collect information about our customers to enable us to provide a service, administer customer accounts, deliver customer benefits (e.g., our newsletters) and to provide information on regulatory updates.

6. Information sharing policy
   CompliancePoint does not sell your private profile or customer-owned information to third parties. We may share your information with affiliates or other third parties, or service providers to process information on our behalf or provide a service to us, such as fulfilling a direct mail piece to our customers; however, CompliancePoint requires that these third parties comply with CompliancePoint’s privacy policies when processing this information. We may share anonymous, aggregated information about all our users with third parties.

7. How will changes to sharing policy be handled
   You will be notified by e-mail (if we have valid e-mail information) and postings on our Websites should CompliancePoint decide to change our policy regarding sharing your information. 

8. Procedures for customers to update or correct erroneous information The Terms require that you ensure that information provided by you is accurate and up-to-date. If you wish to modify or update any information previously provided to CompliancePoint please contact us by
   e-mail at support@PossibleNOW.com or by contacting customer service by telephone at: (800) 585-4888.

9. Customer choice
   CompliancePoint respects our customer’s right to privacy and choice.  Our company provides services only to businesses, not consumers.  However, in keeping with industry best practices, we offer our business to business customers a choice about how they want us to communicate marketing information to them. 

• E-mail opt out procedures
  CompliancePoint 's marketing e-mails contain an "unsubscribe" link at the bottom of the page.  Clicking the unsubscribe link will allow you to opt out from future e-mails from CompliancePoint. You may also reply to the e-mails and type the words "REMOVE ME" in the subject line before sending.  Your e-mail address will be removed from further e-mailings of marketing materials.

10. Links and third parties
    This Website may contain links to other sites. Please be aware that we are not responsible for the content or privacy practices of those sites. We encourage you to read the privacy statements of each site that collects information from you. CompliancePoint’s Privacy Policy applies solely to information collected by CompliancePoint on CompliancePoint.com. You will know when you are leaving our site as a new browser window will open.

11. How do we protect our customers' information
    To help protect the privacy and security of personally identifiable information you transmit through use of this Site, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personally identifiable information to those employees who need to know that information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees' privacy responsibilities.

12. Collection of data regarding children under the age of 13
    Because of the nature of our business, our services are not provided to minors. We do not knowingly attempt to solicit or receive any information from children.

13. How Privacy Policy updates will be communicated
    Substantial changes to our privacy or data sharing policy will be communicated to you through notices contained in our periodic transactional e-mail correspondence.

14. How to contact or register a dispute
    Should you wish to register a dispute with CompliancePoint regarding our Privacy Policy please contact us by e-mail at support@PossibleNOW.com or by contacting customer service by telephone at:
    (800) 585-4888.  You may also mail us at the following address:

15. Questions or comments
    If you have any questions regarding this Policy or any concerns about the privacy practices of CompliancePoint, please contact us by email at support@PossibleNOW.com.

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