I. INFORMATION WE COLLECT: LEAD ORIGINATORS AND LEAD BUYERS

A. Personally Identifiable Information.

LeadPoint (UK) Limited ("LeadPoint", "we" or "us") collects personally identifiable information from all Lead Originators and Lead Buyers (collectively "Clients" or "you") wishing to work with us. The collection of this information is a part of our normal business practices. This Privacy Policy explains the steps we take to ensure information about you is kept secure and confidential. Clients or their representatives, will be asked to provide personally identifiable information through the host sign up and registration process on our LeadPoint website. Examples of personally identifiable information that may be requested include, but are not limited to name, address, phone number, email address, credit card number, etc. LeadPoint will never request or collect sensitive personal data from a Client including medical/health conditions; racial or ethnic origin; political, religious or philosophical beliefs or affiliations; trade union membership or sex life.

B. Non-Personally Identifiable Information.

LeadPoint may use cookies and log files to optimise and personalise the Clients' experience and allow LeadPoint to monitor site traffic patterns. In particular, section III below sets out further details of LeadPoint's use of cookies.

II. INFORMATION SHARING

All personally identifiable information that LeadPoint collects from Clients is principally intended for administration purposes (e.g., accounting and pay-out), for which purposes such information is required by LeadPoint. Your personal information may also be checked against third party databases, including the postcode and address database maintained by Royal Mail Group plc. Your personal information submitted to us by you may be transferred confidentially to another company in our group in the USA for these administrative purposes. We will ensure that appropriate and adequate security measures are in place to keep your personal data confidential and secure.

LeadPoint may receive personally identifiable information of third parties that Clients have collected for transmittal to other Clients. Each Client has agreed that it has provided notice to, and obtained appropriate consents from, any third party individuals whose personal data it supplies to LeadPoint with regard to: (a) the purposes for which such third party's personal data has been collected; (b) the intended recipients or categories of recipients of the third party's personal data; (c) which data such third parties are obliged to submit and which data, if any, is voluntary; and (d) how the third party can access and, if necessary, validate and correct the data held about them. LeadPoint may transmit such third party personally identifiable information to the intended recipients or categories of recipients as requested by such third party.

While LeadPoint strongly encourages Clients to adopt responsible approaches to online marketing, LeadPoint is not responsible for the information practices of Clients or their partners. The collection, use, and disclosure of information by Clients and partners are subject to their respective privacy policies, which may differ from LeadPoint's policy.

Periodically LeadPoint may use Clients' personally identifiable information to communicate via email newsletters or other avenues to offer information and to assist in business related activities. In the event that a Client wishes not to have their personally identifiable information used for these purposes, they may elect to opt-out from future communications. For more information on opting-out please see the "Client Choice And Access" section below.

Except as may be agreed between LeadPoint and a Client, all personally identifiable information provided by individual Clients will be kept in strict confidence by LeadPoint and will be treated with the same level of respect and care that they treat other proprietary information. LeadPoint will never sell, rent or otherwise transfer any personally identifiable Client information to any third party for financial gain or marketing purposes except with the Client's consent. LeadPoint may, from time to time, provide such information to certain of its third-party providers in providing outsourced administrative or management services to LeadPoint such as billing, delivery and payouts. Any such third-party services provider has agreed to protect the confidentiality of information provided by LeadPoint.

LeadPoint may release account and any other personal information when we believe release is appropriate to respond to a subpoena or otherwise comply with the law or protect the rights, property, or safety of LeadPoint or others. This includes exchanging information with other companies and organisations for the prevention or detection of fraud or crime.

III. CLIENT CHOICE AND ACCESS

When a Client registers for services with LeadPoint, personally identifiable information is required as a part of doing business. LeadPoint's primary intent in collecting personally identifiable information is for administrative purposes including accounting and payouts. However, LeadPoint may periodically use personally identifiable information for marketing and communication purposes targeted to our Clients. Clients wishing not to receive such communications from LeadPoint may do so by "opting-out" during the registration and application procedure process. A Client may change their "opt" status at any time during their tenure with LeadPoint by accessing their online account.

When a Client logs on any browser-based LeadPoint reporting system, a "Cookie" is placed within their computer. The purpose of the Cookie is to allow LeadPoint to validate the identity of the Client and maintain the security and privacy of the Client's account data. This Cookie is required to log into LeadPoint's reporting systems. If you chose to disable our Cookie, we will not be able to provide our service to you.

IV. SECURITY

LeadPoint employs industry standard security measures to ensure the security of all data. Any data that is stored on LeadPoint's servers is treated as proprietary and confidential and is not available to the public. LeadPoint has an internal security policy with respect to the confidentiality of Client data, allowing access only to those employees or third parties who have a need to know such information. LeadPoint routinely evaluates its data security practices to identify security threats or opportunities for improvement.

No transmission of data over the Internet is guaranteed to be completely secure. It may be possible for third parties not under the control of LeadPoint to intercept or access transmissions or private communications unlawfully. While we strive to protect your personally identifiable information, LeadPoint cannot ensure or warrant the security of any information you transmit to us. You acknowledge and assume this risk when communicating with LeadPoint.

V. CONSENT AND CHANGES

LeadPoint may find it necessary or be legally required to update this Privacy Policy from time to time. When we do, we will post those changes on this page and update the effective date so that you are always aware of the information we collect, how we use it, and under what circumstances we may disclose it. Any changes will become effective 30 days following the date of posting, unless otherwise stated. Except as otherwise required by law, modifications to this Privacy Policy will not affect the privacy of data collected by LeadPoint prior to the effective date of the policy change.

VI. LIMITATION OF LIABILITY, THIRD PARTY INFORMATION & LANGUAGE

YOU UNDERSTAND AND AGREE THAT ANY DISPUTE OVER PRIVACY IS SUBJECT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND OUR TERMS OF USE (INCLUDING LIMITATIONS ON LIABILITY, AND DISPUTE RESOLUTION). YOU AGREE THAT LEADPOINT'S LIABILITY FOR ANY BREACH OF THIS PRIVACY POLICY SHALL BE LIMITED TO THE VALUE OF THE TRANSACTIONS OR SERVICES PROVIDED TO YOU BY LEADPOINT TO THE EXTENT SUCH CLAIM IS NOT OTHERWISE EXCLUDED BY OUR TERMS AND CONDITIONS. You also agree that you have provided notice to, and obtained consent from, any third party individuals whose personal data you supply to LeadPoint with regard to: (a) the purposes for which such third party's personal data has been collected; (b) the intended recipients or categories of recipients of the third party's personal data; (c) which data the third parties are obliged to submit and which data, if any, is voluntary; and (d) how the third party can access and, if necessary, correct the data held about them.

VII. CONTACT US

For more information or if you have questions or concerns regarding the LeadPoint Privacy Policy, please send an email to UK Legal or you can send correspondence to the following address: Privacy, LeadPoint (UK) Limited, 643 Watford Way, Apex Corner, Mill Hill, London, NW7 3JR.

Revised and republished November 2005