This Privacy Policy was last updated: December 17, 2007.

Vindicia, Inc. Privacy Policy

Preamble

Vindicia, Inc. ("Vindicia") is committed to protecting the privacy of your personal information. This Privacy Policy details certain policies implemented throughout our company governing Vindicia's use of personally identifiable information about users of our Internet website located at the URL: Vindicia.com (the "Site") and about individuals Vindicia receives from Vindicia's merchant customers using Vindicia's services and/or products (collectively, services and products are: "Service" or "Services"). Where the Privacy Policy differs depending on whether you are using the Site(s) or the Services, that difference will be noted in this Privacy Policy.

Privacy Policy Updates

Due to the Internet's rapidly evolving nature, Vindicia may need to update this Privacy Policy from time to time. If so, Vindicia will post a notice of the change and the updated Privacy Policy on our Site located at http://www.vindicia.com/company/PrivacyPolicy.html. We may also send registered users of the Site(s) email notifications notifying such users of any changes to the Privacy Policy. If any change is unacceptable to you, you shall cease using this Site(s) and the Services. If you do not cease using this Site(s) and the Services, you will be deemed to have accepted the change.

Information Collection

Through the Site:

You can generally visit the Site without revealing any personally identifiable information about yourself. However, in certain sections of the Site, we may invite you to contact us for information or questions, inquire about a job or apply for a job.

We may track the total number of visitors to our Site(s), the number of visitors to each page of our Site(s), your IP address, your browser type and the number of External Web Site (defined below) pages you have visited ("Aggregate Data").

Through the Services:

When our merchant customers use our Services, the merchant may provide us with personally identifiable information about you, such as your name, address, email, phone number, and financial information such as your credit history, credit card numbers and bank account numbers. Our merchant customers may also provide us with information about the transactions you have entered into with our merchant customers.

Use of Information

We may use your personally identifiable information you submit to the Site(s) to contact you to deliver certain services or information you have requested, verify your authority to enter our Site(s), improve the content and general administration of the Site(s), services and Services, provide you with notices regarding goods, services and/or Services that you have purchased or may wish to purchase in the future and for targeted advertising.

Vindicia uses the information Vindicia receives from our merchant customers through their use of the Services to provide our Services for them, for example, to bill on their behalf, dispute a chargeback and make a transaction risk determination. Such information about the transactions that you have made will be correlated with your personally identifiable information in a transaction history that Vindicia stores.

The aggregate information extracted from the Aggregate Data will be maintained, used and disclosed in aggregate form only and will not contain personally identifiable information. We may use such aggregate information extracted from the Aggregate Data to analyze trends, improve the services and Services we provide to our customers, administer the Site(s) and gather broad demographic information for aggregate use.

Disclosure of Information

We may provide your personally identifiable information and/or the aggregate information to vendors and service agencies that we may engage to assist us in providing our Services and services to you. We also may provide a transaction risk score that we generate based on your transactions with other merchants as well as an explanation of your score in general to our other merchant customers in Vindicia's network. Such third parties will be restricted from further distributing your personally identifiable information and must enter to a written confidentiality agreement with us. We will also disclose your personally identifiable information if we are required to do so by law, regulation (including a charegback dispute process) or other government authority or otherwise in cooperation with an investigation of a governmental authority or to protect the safety of users of our Site(s), services and our Services. We will not sell your personally identifiable information to any company or organization except we may transfer your personally identifiable information to a successor entity upon a merger, consolidation or other corporate reorganization in which Vindicia participates or to a purchaser of all or substantially all of Vindicia's assets to which the Site(s) relate.

Children's Privacy

Vindicia recognizes the privacy interests of children and we encourage parents and guardians to take an active role in their children's online activities and interests. The Site(s) are not intended for children under the age of 13. Vindicia does not target its Services or the Site(s) to children under 13. Vindicia does not knowingly collect personally identifiable information from children under the age of 13.

Cookies

We may use small text files called cookies to improve overall Service and Site(s) experience. A cookie is a piece of data stored on the user's hard drive containing information about the user. Cookies generally do not permit us to personally identify you.

Links to Third Party Sites

The Site(s) may provide links to other Web sites or resources over which Vindicia does not have control ("External Web Sites"). Such links do not constitute an endorsement by Vindicia of those External Web Sites. You acknowledge that Vindicia is providing these links to you only as a convenience, and further agree that Vindicia is not responsible for the content of such External Web Sites. Your use of External Web Sites is subject to the terms of use and privacy policies located on the linked to External Web Sites.

Safe Harbor

Vindicia follows the Safe Harbor Principles published by the United States Department of Commerce (the "Principles") with respect to the transfer of personal data from the European Union to the United States of America. This Privacy Policy details certain policies implemented throughout Vindicia implementing the Principles and governing Vindicia's use of personally identifiable information provided to Vindicia via this Internet web site (the "Site") or otherwise. If there is any conflict between the policies in this Privacy Policy and the Principles, the Principles will govern.

Security

We employ procedural and technological measures that are reasonably designed to help protect your personally identifiable information from loss, unauthorized access, disclosure, alteration or destruction. Vindicia uses encryption, secure sockets layer, firewalls, password protection and take other physical security measures and place internal restrictions on who within Vindicia may access your data to help prevent unauthorized access to your personally identifiable information.

Reviewing and Deleting Personally Identifiable Information Collected Through the Site(s)

Vindicia provides you with the ability to review and delete your personally identifiable information that we have received if it is inaccurate; provided, however, that Vindicia will retain a copy in its files of all personally identifiable information, even if corrected, in order to resolve disputes. If you wish to review or delete the foregoing information, you may contact our General Counsel at: 650-522-4480 or at privacy@vindicia.com.

If you have any questions regarding this Privacy Policy please contact us via email at: privacy@vindicia.com.

This Privacy Policy is effective as of: December 17, 2007.