Privacy Policy ________ 1. PRIVACY STATEMENT Identex is part of the WWav Rapp Collins Group. Rapp Collins Worldwide, Inc. ("RCW" or the "Company") recognizes that privacy of information is important. Particularly, protecting the privacy of those whose personal data we store and process is an important concern to which the Company pays special attention. Therefore, this privacy statement provides an overview about the information the Company collects and stores, how the Company uses that information, and how individuals may opt out of certain uses of information we may collect and store. By visiting our site, a party consents to the information collection and use practices described in this privacy statement. This privacy statement may be modified from time to time. If we decide to change this privacy statement, we will post a new privacy statement in-house and on our Web site and change the date at the top of the privacy statement. Therefore, we encourage our staff, our clients and the public in general to check the date of our privacy statement whenever they visit the Web site for any updates or changes. Personal information collected during visits to our Web site or stored by us is processed by us according to the legal provisions valid for the countries in which our Web site is maintained. Our Web site may include, however, links to other Web sites which are not covered by this online privacy statement. These sites have their own privacy and information security policies and terms and conditions. The public is encouraged to review the privacy policy and terms and conditions sections of such Web sites for additional details. 1.1. Information RCW Collects and Stores RCW may, at various times, collect and store several types of information. Personal Information is information that identifies an individual or is directly associated with a specific person, such as an individual's name, mailing address, telephone number, e-mail address, credit card number or information about activities which can be directly linked to that person, such as his or her purchases ("Personal Information"). Our definition of Personal Information does not include "aggregate" information. Aggregate information is data about use of our services. Aggregate information helps us understand trends and clients' needs so that we can better consider new services, and tailor existing services to client desires. We may also collect and store "Non-Personal Information", which is information about a person who cannot be readily identified on an individual basis. Examples of Non- Personal Information include age range and gender. 1.1.1. Collection of Personal Information We may collect and store certain kinds of Personal Information, including Personal Information of third parties: Client Service Correspondence: We may collect and store information that identifies an individual personally when that individual submits comments, questions resumes, etc. Transactions: We may collect and store Personal Information to fulfill an order for RCW's clients' services. Such information could include name and address, credit card number and expiration date, and billing address. Services: In providing services and manipulating data provided by our clients' customers, we may collect and store Personal Information, including personal information related to Third Parties. 1.1.2. Use of Personal Information Except for marketing purposes or as otherwise disclosed in this statement, we do not sell or disclose information that identifies our clients or their customers, or makes it possible for other parties to contact them directly without their consent. We may use, sell, disclose or otherwise dispose of Personal Information we collect in the following circumstances: Inquiry. We use Personal Information provided to us by our clients and/or their customers for services rendered. We do not share this information with other parties unless such a request was specified during the inquiry by our client and/or their customers. Transaction Processing. We may use Personal Information provided by a client and/or their customers when completing a transaction. Also, we may share transactional information with entities as is necessary to process credit card payments or other purchasing or delivery systems. We may use an individual's e- mail address to communicate with the individual or notify the individual of our clients' special offers or programs. Marketing research. We may store Personal Information and use it for marketing research and marketing purposes, which may include sharing it with various suppliers that provide marketing, research or other services for us. We enter into contractual agreements with these companies prohibiting them from disclosing or using our client information other than to carry out the purposes for which the information was disclosed. Legal Requirements. We may disclose Personal Information: (a) to conform with the law, respond to claims or comply with legal process served on RCW (e.g., a lawful subpoena, warrant or court order); (b) to enforce or apply our policies or agreements (including to initiate, render, bill, and collect for amounts owed to us); (c) to protect and defend our or our clients' rights or property, our employees, visitors or the public; or (d) if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure of communications or justifies disclosure of records without delay. 1.1.3. Use of Non-Personal and Aggregate Information We may use Non-Personal and Aggregate information to better design our services and share with our marketing and advertising agencies. 1.2. Freedom of Choice If an individual would like his Personal Information to not be available to any third party, that party may contact us by sending an e-mail to privacy@rappcollins.com so we can block the applicable data accordingly. 1.3. California Privacy Rights Under California's "Shine the Light" law, California residents who provide Personal Information in obtaining services for personal, family or household use are entitled to request and obtain from us once a calendar year information about the information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of personal information and the names and addresses of those businesses with which we shared personal information for the immediately prior calendar year (e.g. requests made in 2005 will receive information regarding 2004 sharing activities). To obtain this information, a California resident may e-mail us at privacy@rappcollins.com with "Request for California Privacy Information" on the subject line and in the body of the message. We will provide the requested information to that resident at the e-mail address in response. 1.4. Children's Online Privacy Protection Act (COPPA) Our Web site is a general audience site that is not designed nor intended to collect Personal Information from children under the age of 18. RCW does not knowingly collect or maintain any Personal Information from children under the age of 18. In addition, no part of this Web site is designed with the purpose of attracting any person under age 18. To respect the privacy of children and to comply with the Children's Online Privacy Protection Act, children under the age of 18 should not provide any Personal Information on this Web site. We ask that parents supervise their children while online. 1.5. IP Address and Click-Stream Data Collection RCW may collect IP addresses and/or click-stream data for market research, for purposes of system administration and to report aggregate information. An IP address is a number that is automatically assigned to a visitor's computer whenever that visitor accesses the Internet. Our servers identify that computer by its IP address. When the visitor requests Web pages from our Web site, our servers log the IP address. Click-stream data is information collected by our servers when a visitor requests pages from our Web site. Click-stream data may include such information as the page served, the time, the source of the request, the type of browser making the request, the preceding page view, and other such Non-personal Information. When analyzed, this data helps us analyze how visitors arrive at our Web site, what type of content is most popular, what type of visitors in the aggregate are interested in particular kinds of content, and the like. 1.6. Security RCW uses commercially reasonable efforts to store and maintain Personal Information to protect it from loss, misuse, alternation or destruction by any unauthorized party. We exercise reasonable care to protect Personal Information. This includes storing the Personal Information on our servers behind a secured firewall and ensuring all transmissions to other vendors use secure encryption technology. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. So while we strive to protect Personal Information, we cannot guarantee the security of any information a client, visitor, or third party transmit to us or receive from us. This is especially true for information transmitted to us via e-mail. We have no way of protecting that information until it reaches us. Once we receive a transmission, we maintain physical, electronic, and procedural safeguards to protect Personal Information. Internally, we will limit access to Personal Information to those persons who need the information to provide services to our clients or maintain or service some of our products. These persons are limited in number and are committed to our privacy and security policies. We will review our security arrangements from time to time, as we deem appropriate. 1.7. Links to Other Sites Please be aware that we provide links to third-party sites as a service to our visitors, and that we are not responsible for the content or information collection practices of those sites. Please note that these sites' privacy policies may differ from those of RCW. We encourage our clients and the public in general to review and understand their privacy practices before providing them with information. 1.8. Privacy Statement Revisions A revised online privacy statement will only apply to data collected subsequent to its effective date on this version of our Web site. Any revisions will be posted at least 7 days prior to its effective date.