ClearMarkets Web Site Internet Privacy Statement (Updated 6/5/09)
This Privacy Policy (the "Statement") outlines the ClearMarkets ("our," "us," "we," or the "Company") policy for our customers, our former customers, and for visitors to our Web Site (the "Site"). From time to time, ClearMarkets may use customer information for new, unanticipated uses not previously disclosed in our Statement. If our information practices change at some time in the future ClearMarkets will post the policy changes to our Web site to notify you of these changes, and provide the ability to opt out of these new uses. If you are concerned about how your information is used, check back at our Web site periodically. ClearMarkets provides information tailored to the unique needs of our customers. As part of our goal to provide excellent service to our visitors and customers, we respect your concerns about privacy. Therefore, we have constructed the Site in compliance with the on-line Privacy Alliance (OPA) guidelines. This Statement outlines whether and how the Site collects and uses information. It contains numerous general and technical details about the steps we take to respect your privacy concerns. If after reviewing this Statement you have any questions or privacy concerns please contact us at Privacy@ClearMarket.com.

Links to Other Sites
The Site may contain links to other sites. Please be aware that we are not responsible for the content or privacy practices of other sites to which we link. Users should also be aware that, when you voluntarily disclose personal information in public forums, such information may be collected by others and may result in receiving unsolicited messages. We strongly encourage you to be aware that when you leave our site you should read the privacy statements of each and every site that collects personally identifiable information.

Security
We treat the information you provide to us as confidential information; it is, accordingly, subject to our company's security procedures and policies regarding protection and use of confidential information. When ClearMarkets asks you for sensitive data, it is transferred over a Secured Sockets Layer ("SSL") line, provided you are using a SSL enabled browser such as Microsoft Internet Explorer or Netscape Navigator. We also use SSL on other select pages where you would enter personally identifiable information. This ensures that your information is encrypted as it travels over the Internet. This secure mode is enabled before any such information is transmitted from your computer. You will know you are in secure mode when the padlock or key icon in the lower right-hand or left-hand corner of the computer screen appears in the locked position. In addition, when accessing a secure server, the first characters of the site address will change from "http" to "https." After information reaches the Site, it is stored on a secure server that resides behind firewalls designed to block unauthorized access from outside of the Site. If you are interested in learning more about our security measures please contact us at the address above.

Requests from Law Enforcement
If required by law, ClearMarkets may provide any and all information we have about you to law enforcement or other government agencies, pursuant to a subpoena, warrant, or other order by a court of competent jurisdiction. In all cases, ClearMarkets will require written documentation of the request, proof of the identity of the law enforcement official making the request, and ClearMarkets will take steps to authenticate the validity of the request. Any law enforcement or government agency request submitted with less than a court-issued order will be evaluated on a case-by-case basis according to the need and urgency, as well as the particular law enforcement agency making the request.

Use of Information
The ClearMarkets Website generally uses information to:
- contact you;
- fulfill requests for services;
- market/promote the site; and
- better understand how visitors use our website and how ClearMarkets can enhance your experience, its contents and functionality to meet your needs and personal interests. ClearMarkets will also log the webpage visitors were on before visiting us, and use that data to formulate statistical models.
ClearMarkets may, on occasion, make information collected on the Site available to subsidiaries and affiliated companies that are part of the ClearMarkets family of companies. ClearMarkets may also share or sell, as allowed by law, information to other companies who we believe may have products and services of interest to you. If you would like to opt-out of receiving information from us or these other sources please follow the "Opt-out" instructions below. ClearMarkets may also share this information about our visitors, customers or former customers to nonqualified companies that perform marketing services on our behalf or with whom we have joint marketing agreements, including financial service providers such as companies engaged in banking, mortgage lending, consumer finance, securities and insurance, and non-financial companies such as envelope stuffers and other fulfillment service providers.

Choice/ Opt-out, Data Quality, and Personal Information
The Site will take reasonable steps to ensure that the information and data is complete, accurate, and timely for the desired purposes. If your personally identifiable information, such as your email address, changes, is inaccurate, or if you no longer desire the services, you should contact ClearMarkets to correct or update the information.

From time to time, ClearMarkets may send users e-mail, e-mail newsletters, or website news updates alerting you to new features, products, promotions, or services pertaining to the website. Users who no longer wish to receive materials from us may opt-out of receiving these communications by choosing a "do not contact" option or by contacting us at the address above. ClearMarkets will gladly comply with all requests for removal.

Opt Out Procedure: In compliance with the Can-Spam Act of 2003, on each email transmitted by the Site, there are instructions for opting out of receiving future emails. Such instructions may include, without limitation: (a) clicking a link on the email which sends a reply to the sender's server instructing the server of the sender's desire to opt out of future emails, or (b) instructions for mailing a written request to be removed from future emails. All requests to opt out of future emails will be respected.

Notification of Changes
In the future, ClearMarkets may need to change the privacy statement for the Site. All changes will be made here so that you will always know what information we gather, how ClearMarkets might use that information and whether we may share it with anyone. This statement was last updated March 23, 2009.

Contact Information
Should the User have any questions about this Privacy Policy, or if User otherwise needs to contact the Company regarding User's personally identifiable information, contact the Company by sending an e-mail. Please provide the Company with User's name, mailing address, telephone number and e-mail address so ClearMarkets can service the User more quickly. Please send an e-mail to: Privacy@ClearMarket.com. Upon request, we offer visitors the ability to have inaccuracies corrected in contact information. No agent or employee of ClearMarkets is authorized to waive any provisions of our Company policies and procedures. If you need assistance with this site or with any service or information provided through it, or if you need to communicate with us, telephone us at 1-800-XXX-XXXX. You agree that ClearMarkets may record the conversations our agents or employees have with you. We do this from time to time to monitor the quality of service and accuracy of information our agents and employees give to you and to ensure that your instructions are followed. If you feel that the Site is not following its stated information policy, you may contact ClearMarkets, state or local chapters of the Better Business Bureau, state or local consumer protection offices, or the Federal Trade Commission by phone at 1-877-FTC-HELP (1-877-382-4357) or electronically at http://www.ftc.gov/ftc/complaint.htm.