Privacy Statement Effective as of March 01, 2010

AngelPoints, Inc. (“AngelPoints” or the “Company”) is committed to protecting the privacy of your information. This Privacy Statement describes AngelPoints’ information practices.

AngelPoints abides by the U.S.-EU Safe Harbor Framework and adheres to the Safe Harbor Privacy Principles and the 15 FAQs that make up the U.S.-EU Safe Harbor Framework as set forth by the U.S. Department of Commerce at: http://www.export.gov/safeharbor. For more information on the EU Safe Harbor Framework, please visithttp://www.export.gov/safeharbor/.

If you have any questions about this Privacy Statement, please contact AngelPoints at information(at symbol)angelpoints.com.

1. Personal Information Collected

AngelPoints offers a variety of services that are collectively referred to as the “Service.” AngelPoints collects information from individuals who visit the Company’s Web sites (“Visitors”) and clients subscribing to the Service by contract (“Clients”).

When expressing an interest in obtaining additional information about the Service or registering to use the Service, AngelPoints requires you to provide the Company with contact information, such as name, company name, address, phone number, and email address (“Required Contact Information”). When purchasing the Service, AngelPoints requires you to provide the Company with financial qualification and billing information, such as billing name and address, credit card number, and the number of employees within the organization that will be using the Service (“Billing Information”). AngelPoints may also ask you to provide additional information, such as company annual revenues, number of employees, or industry (“Optional Information”). Required Contact Information, Billing Information, and Optional Information are referred to collectively as “Data About AngelPoints Clients.”

As you navigate the Company’s Web sites, AngelPoints may also collect information through the use of commonly-used information-gathering tools, such as cookies and Web beacons (“Web Site Navigational Information”). Web Site Navigational Information includes standard information from your Web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on the Company’s Web sites (such as the Web pages viewed and the links clicked).
2. Use of Information Collected 
The Company uses Data About AngelPoints Clients to perform the services requested. For example, if you fill out a “Contact Us” Web form, the Company will use the information provided to contact you about your interest in the Service.

The Company may also use Data About AngelPoints Clients for marketing purposes. For example, the Company may use information you provide to contact you to further discuss your interest in AngelPoints, the Service, and to send you information regarding the Company and its partners, such as information about promotions or events.

AngelPoints uses Web Site Navigational Information to operate and improve the Company’s Web sites. The Company may also use Web Site Navigational Information in combination with Data About AngelPoints Clients to provide personalized information about the Company.

3. Web Site Navigational Information

AngelPoints uses commonly-used information-gathering tools, such as cookies and Web beacons, to collect information as you navigate the Company’s Web sites (“Web Site Navigational Information”) . This section describes the types of Web Site Navigational Information the Company may collect and how the Company may use this information.

Cookies

AngelPoints uses cookies to make interactions with the Company’s Web sites easy and meaningful. When you visit one of the Company’s Web sites, AngelPoints’ servers send a cookie to your computer. Standing alone, cookies do not personally identify you. They merely recognize your Web browser. Unless you choose to identify yourself to AngelPoints, either by responding to a promotional offer, opening an account, or filling out a Web form (such as a “Contact Us”), you remain anonymous to the Company.

There are two types of cookies: session-based and persistent-based. Session cookies exist only during one session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you close your browser or turn off your computer.

If you have chosen to identify yourself to AngelPoints, the Company uses session cookies containing information to allow the Company to uniquely identify you. Each time you log into the Service, a session cookie containing a unique identifier that is associated with your account is placed in your browser. These session cookies allow the Company to uniquely identify you when you are logged into the Service and to process your online requests. Session cookies are required to use the Service.

AngelPoints uses persistent cookies to identify browsers that have previously visited the Company’s Web sites. If you disable your Web browser’s ability to accept cookies, you will be able to navigate the Company’s Web sites, but you will not be able to successfully use the Service.

AngelPoints may use information from session and persistent cookies in combination with Data About AngelPoints Clients to provide you with information about the Company and the Service.

Web Beacons

AngelPoints uses Web beacons alone or in conjunction with cookies to compile information about Clients and Visitors’ usage of the Company’s Web sites and interaction with emails from the Company. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular Web site tied to the Web beacon, and a description of a Web site tied to the Web beacon. For example, AngelPoints may place Web beacons in marketing emails that notify the Company when you click on a link in the email that directs you to one of the Company’s Web sites. AngelPoints uses Web beacons to operate and improve the Company’s Web sites and email communications. AngelPoints may use information from Web beacons in combination with Data About AngelPoints Clients to provide you with information about the Company and the Service.

IP Addresses

When you visit AngelPoints’ Web sites, the Company collects your Internet Protocol (“IP”) addresses to track and aggregate non-personally identifiable information. For example, AngelPoints uses IP addresses to monitor the regions from which Clients and Visitors navigate the Company’s Web sites.

Third Party Cookies

From time-to-time, AngelPoints engages third parties to track and analyze non-personally identifiable usage and volume statistical information from individuals who visit the Company’s Web sites. AngelPoints may also use other third-party cookies to track the performance of Company advertisements. The information provided to third parties does not include personal information, but this information may be re-associated with personal information after the Company receives it. This Privacy Statement does not cover the use of third party cookies.

4. Sharing of Information Collected

AngelPoints may share Data About AngelPoints Clients with the Company’s agents so that these agents can contact Clients and Visitors who have provided contact information on our behalf. AngelPoints may also share Data About AngelPoints Clients with the Company’s agents to ensure the quality of information provided. AngelPoints does not share, sell, rent, or trade personally identifiable information with third parties for their promotional purposes.

AngelPoints reserves the right to disclose personally identifiable information of the Company’s Clients or Visitors if required by law or if the Company reasonably believes that disclosure is necessary to protect the Company’s rights and/or to comply with a judicial proceeding, court order, or legal process.
5. Communications Preferences
AngelPoints offers Clients and Visitors who provide contact information a means to choose how the Company uses the information provided. You may manage your receipt of marketing and non-Service related communications by emailing unsubscribe(at symbol)angelpoints.com or by clicking on the “unsubscribe” link located on the bottom of the Company’s marketing emails. Additionally, you may send a request specifying your communications preferences to information(at symbol)angelpoints.com. Clients cannot opt out of receiving Service emails related to their account with AngelPoints or the Service.

6. Correcting and Updating Your Information

Requests to access, change, or delete your information will be handled within 30 days.
7. Client Data
AngelPoints Clients use the Service to host data and information (“Client Data”). AngelPoints will not review, share, distribute, or reference any such Client Data except as provided in the AngelPoints Contracts and Subscription Agreements, or as may be required by law. Individual records of Client Data may be viewed or accessed only for the purpose of resolving a problem, support issues, or as may be required by law. Clients are responsible for maintaining the security and confidentiality of their AngelPoints usernames and passwords.

8. Security

AngelPoints uses robust security measures to protect Client Data from unauthorized access, maintain data accuracy, and help ensure the appropriate use of Client Data. Secure Socket Layer (“SSL”) technology protects Client Data using both server authentication and data encryption. These technologies help ensure that Client Data is safe, secure, and only available to the Client to whom the information belongs and those to whom the Client has granted access. AngelPoints also implements an advanced security method based on dynamic data and encoded session identifications, and the Company hosts its Service Web sites in a secure server environment that uses firewalls and other advanced technology to prevent interference or access from outside intruders. AngelPoints also offers enhanced security features within the Service that permit Clients to configure security settings to the level they deem necessary.

9. Changes to this Privacy Statement

AngelPoints reserves the right to change this Privacy Statement.

10. Contacting Us

Questions regarding this Privacy Statement or the information practices of the Company’s Web sites should be directed to AngelPoints Privacy by emailing information(at symbol)angelpoints.com or by mailing AngelPoints Privacy, 30 Liberty Ship, Suite 3150, Sausalito, CA 94965.