PRIVACY PRACTICE STATEMENT

Effective Date: September 2009
Privacy Practice Statement:

Predictive Compliance LLC (“PCL”) believes that understanding what our customers want regarding products and services is very important and valuable to PCL; and information is an important part of building an interesting, valuable and useful on-line environment. PCL wants to contribute to providing a safe and secure environment for you if you choose to become an interactive user of our website (“Site”). PCL has designed its Site with this belief in mind, and has created this page so that you can have easy access to PCL’s stated privacy practice. At any time, however, PCL may change its privacy practice and privacy practice statement. In the event PCL does so, PCL will post these changes here promptly.
Your California Privacy Rights:
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our customers who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to:
Predictive Compliance LLC
1040 Blake St. Suite 105 A
Denver, CO 80202
Contents:
What information does PCL collect on-line?
What sort of information will PCL not collect?
How does PCL use the information it collects?
“Cookies” or Web Beacons — what are they and how does PCL use them?
How does PCL use e-mail?
What information may PCL share with others?
What information will PCL not share with others (with special attention to children)?
Choices for your Site Interaction.
How to contact PCL with questions or comments.
What information does PCL collect on-line?
When you visit PCL’s Site, PCL may ask you to provide information by filling out and submitting an on-line form. This requested information may include your name, phone number(s), e-mail address, and mailing address. For privacy purposes all information relating to our customers is stored in a highly secure server that is not accessible via the Internet and will not be shared with any third parties. You can always choose whether or not to disclose any or all of the information requested; however, certain information may be required in order to be able to respond to your request. If you do not want to disclose any requested information over the Site you may contact PCL’s customer service center at 801-994-6455 to complete your order or request information.
Additionally, PCL automatically gathers certain usage information regarding the number and timing of visitors to the Site and the number and type of customers that access and obtain PCL’s products. PCL only uses and analyzes such information in the aggregate, not at the individual level. Therefore, any individual, personal information, such as your name and e-mail address, are not included in this analysis.
Information we collect:
We may elect to do one or more of the following with respect to the information we collect:
• We collect the information you give us in order to provide you products and services, inform you about our products and fulfill your orders and service requests.
• We use cookies and other Internet technologies, including web beacons, to manage our Site and e-mail programs, to offer you personalized experiences and to help us manage our Site.
• When you access our Site, we use your IP address for internal purposes and to customize your browsing experience. We also utilize your IP address for security purposes and to protect your information.
What sort of information will PCL not collect?
The only information PCL may collect is information that you voluntarily provide to PCL, which may include your acceptance of “cookies” or web beacons.
“Cookies” or Web Beacons — if PCL sends you cookies, what are they and how does PCL use them? What are Web Beacons and how does PCL use them?
Cookies are small pieces of text that store information specific to your browsing session with PCL. A cookie does not contain code or any other malicious data. We utilize this recurring information to customize your browser experience while you are utilizing PCL resources, and it ensures the proper credentials are being used to secure your information from unwanted viewers. The majority of information PCL retrieves from your cookies is contained in “Session Cookies” and is not permanently stored or remembered.
A Web Beacon is an embedded object that is usually attached to an image or framing object. In many cases, this embedded code pulls an image or other object from a third party site and is generally used in user tracking.
PCL does not utilize “third party” cookies or “web beacons.” All data is solely used at PCL for your security and browsing customization.
How does PCL use the information it collects?
PCL may use the information it collects to improve its Site, enhance PCL’s existing product offerings, and to introduce new product offerings.
How we use personal information:
PCL may elect to do one or more of the following:
• We use personal information to deliver the services and support, or to carry out the transactions you have requested.
• We use the information collected to send communications to you, such as product safety information, your transactions status (for example, order confirmations), information about products and services available from PCL and its corporate affiliates, promotional offers, and surveys.
• We use the information to customize, analyze, and improve our products, services (including our Site), technologies, communications and relationship with you.
• We use the information to enforce our conditions of sale, Site terms and/or separate contracts (if applicable) with you.
• We use information to prevent fraud and other prohibited or illegal activities.
How does PCL use e-mail?
PCL encourages you to e-mail PCL with your questions or comments. PCL reads every e-mail it receives. If you request to have your e-mail address added to our mailing list, PCL will periodically send new information to you. If you want your e-mail address removed from the list at any time, just instruct us to do so by e-mail.
What information may PCL share with others?
PCL will not share, sell or trade e-mail addresses, which are personal to you, and that are collected as part of a survey, with others. Except to verify credit card information to complete your product transaction, PCL will not use or release to others any credit card or financial information for any purpose. For privacy purposes, all information relating to our customers is stored on a highly secure server that is not accessible via the Internet and will not be shared with any third parties.
Protecting personal information: We understand the importance of ensuring that your personal information is secure and protected. We use a variety of security technologies and procedures to help protect personal information from unauthorized access, use, and disclosure.
Disclosing personal information:
• We share your personal information with corporate affiliates to carry out transactions you request or to make our business or that of our corporate affiliates more responsive to your needs.
• We may share your personal information with business partners that help PCL carry out transactions you request or that help PCL to customize, analyze and/or improve our communications or relationship with you, and then only with business partners who share PCL's commitment to protecting your personal information.
• We may disclose your personal information in connection with law enforcement, fraud prevention, or other legal action as required by law or regulation, or if PCL reasonably believes it is necessary to protect PCL, its customers or the public.
• Except as described above, we will not disclose your personal information to other third parties unless you have provided consent.
Special attention to children:
PCL takes special care to protect the safety and privacy of young people accessing and using our products. PCL does not specifically collect information about children and believes that children should get their parents’ consent before giving out any personal information. PCL encourages you to participate in and supervise your child’s Internet experience.
Choices for your Site interactions:
• You may instruct PCL to stop sending you certain promotional materials (e.g., e-mail messages, catalogues) by contacting PCL by e-mail, telephone or through the contact form on the web site.
• You may choose to view or edit your personal information, which has been stored online, by visiting the my account section of the Site. For the security of your account, you will be required to sign in with your login ID and password.
• You may contact PCL to determine the types of personal information that we process and to correct or update your personal information.
How to contact PCL with questions or comments:
PCL is always happy to answer your questions and listen to your comments, and PCL offers several options for you to contact us.
By E-Mail:
jsavit@predictivecompliance.com

By Phone:
Phone: 801-994-6455

By Mail:
Predictive Compliance LLC
1940 Blake St. Suite 105 A
Denver, CO 80202