I. What information do we collect?

The information we collect helps us ensure that our services are best designed to meet your needs. For each of the Smarterway Sites, we receive and store any information that you enter on any page. Typically these will be registration forms for quote requests, product purchases, contests, surveys or other promotions. If you are giving us information in order to participate in a survey, contest or other promotion, your participation is completely voluntary and you therefore have a choice whether or not to disclose this information. If some information is required and some is optional, we will identify the required information. We collect both contact and other information.

A. Contact Information

Contact information consists of the information that we can use to contact you if, for example, you win one of the contests or promotions sponsored by Smarterway and/or its affiliates and partners. This consists of your name, your e-mail address, IP address and possibly your mailing address, telephone and facsimile number.

B. Other Information

Profile data also is collected at our site. Depending on the specific Smarterway products for which a user ("User") uses, various information will be requested. We use this data to tailor the visitor's experience through our interest-focused e-mails. By obtaining this information, we can provide our Users with specific content that we think they might be interested in, according to their preferences and interests. None of this information is required in order to receive the Smarterway service. The User may include only the information he or she feels comfortable including. However, the omission of certain information may limit the value of the experience for the User. As a result, the more information we have about a User, the more valuable the Smarterway experience will be for that User.

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II. How is User information used?

A. Information that you provide

Smarterway, Inc., does not send unsolicited or "spam" e-mail. We use User information in a number of ways, including:

i. to send personalized, targeted information to the User in the form of e-mail messages and/or direct mail;

ii. to send targeted advertising that allows us to provide our service at no or little cost to the Users;

iii. to send promotions and coupons based on their interests;

iv. to contact Users for feedback and surveys;

v. to monitor and improve its internal operations, as well as to ensure that it properly performs the services requested; and

vi. to send Users other information about Smarterway and/or its products.

When you visit a Smarterway site, you may receive offers from us or our marketing partners. Our marketing partners may use this information to make offers to you in your areas of interest or other offers. Our marketing partners wishing to contact you either give their e-mail message to us and we deliver it to you, or we provide your contact information to them so they can deliver messages directly to you. It is solely at your discretion if you choose to provide additional personally identifiable information to a marketer by making a purchase, requesting additional information, or communicating directly with the company or organization after using its website. We may also use outside companies to execute the marketing campaigns on our behalf or on behalf of some of our marketing partners. We will share your e-mail name or other contact information that is necessary for these third parties to provide these services. These third parties are not allowed to use personally identifiable information except for the purposes of providing these services.

B. Automatic Information ("Cookies")

A cookie is a piece of data stored on the User's hard drive containing information about the User. Usage of a cookie is in no way linked to any personally identifiable information while on the Smarterway Sites. For instance, by setting a cookie on our site, the User would not have to log in a password more than once, thereby saving time while on our site. If a User rejects the cookie, he or she may still use our site. The only drawback to this is that the User will be limited in some areas of the Smarterway Sites. Cookies also can enable us to track and target the interests of our Users to enhance their experience on the Smarterway Sites.

You can set your browser to not accept cookies. Please be aware that by doing so certain features of the Smarterway Sites may not work. See your browser's documentation for more information on accepting cookies.

Smarterway uses cookies to collect and store certain types of information when you interact with us in order to (i) access your account information (stored on our computers) and keep track of your points or credits; and (ii) learn what you like and, hence, provide a more personalized experience.

C. Log Files

We use IP addresses to analyze trends, administer the site, track User's movements, and gather broad demographic information for aggregate use. While we collect standard log files, we do not use them for any purpose other than determining page views. We also collect pages visited within our database through cookies (as discussed above). This data is connected with User information so we can determine site usage for marketing research. IP addresses are not linked to personally identifiable information.

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III. Does Smarterway share information it collects?

A. Registration Information

As part of the registration process, we regularly offer you the option to take advantage of one or more offers from our partners. Those offers are optional and you do not have to sign-up for any offers in order to participate in the main promotional offer (although you may need to check or un-check certain boxes to do so). If you do choose to sign-up for an offer, we will share information about you with those selected partners from whom you have chosen to receive information. All offers have Terms and Conditions links that we encourage you to read.

We may employ other companies and individuals to perform functions on our behalf (e.g., fulfilling orders). They have access to the User information to perform their functions, but may not use it for other purposes. In the case of any domain registration services we provide, registration information will be shared with the administrator of the registry for the top-level domain in which you are registering, to operators and users of the Internet making "who is" queries concerning your domain name registration, to ICANN, and to escrow agents, auditors, "who is" service providers, and replacement registrars that ICANN may designate.

B. Referral Program

As part of some of our referral programs, we request contact information (like the name and e-mail address) of visitors' friends and family whom they think would like to receive an Smarterway service. The persons referred to us will receive sample Smarterway e-mails, but do not become subscribers until they confirm their interest in the service. Smarterway stores this information for the sole purpose of sending the emails regarding Smarterway services. The person referred also can un-subscribe at any time; see "What Choices Do I Have," below.

C. Links To Other Sites

This privacy statement applies solely to information collected by this Web site. Except as otherwise stated in this policy, it is against our policy to provide any customer information to third parties without the customer's prior permission. As part of our business, however, we may provide links to third party sites. We encourage all of our partners to post their privacy policies on their sites and to adhere to the same high standard as is stated here. We, however, disclaim any responsibility for the actions of these third parties. AS A RESULT, WE ENCOURAGE OUR USERS TO READ THE PRIVACY POLICIES OF THESE LINKED SITES, BECAUSE THEIR PRIVACY POLICIES MAY DIFFER FROM OURS.

D. Protection of Smarterway and Others

We may release User or account information as is necessary to comply with the law; enforce or apply our Terms and Conditions and other agreements; or to protect the rights, property, or safety of Smarterway, its subsidiaries, affiliates or partners, our Users, or others. This includes exchanging information with other companies and organizations for fraud protection.

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IV. What Choices do I have?

A. Choices In Disclosing Information

Because we want our Users to feel completely comfortable using the Smarterway services, we provide you with various opportunities to control how the information you provide to us will be used by us. We request information from our customers' registration, as well as via surveys, contests or other promotions. Your participation in these activities is completely voluntary and you, therefore, have a choice whether or not to disclose this information. Nevertheless, certain basic information is required in order to register as a User. Information requested may include contact information, and demographic information. You also may choose whether or not to get e-mails from Smarterway and whether or not to accept special offers from our partners. If you choose not to receive e-mail from Smarterway we will not send you e-mail, although it may take a short time to remove your name from our database.

Please note once an account is created, we may send you a confirmation e-mail acknowledging your new account to the address that you supplied. This e-mail will give you the option to delete your account, in case you change your mind, or you were not the one who created it in the first place. You should keep the confirmation e-mail, as it will also contain information that will help you in case you run into problems accessing our services.

B. Opting Out

To remove your User information from our mailing list(s), so as not to receive future communications from us or to no longer receive our service, please send a request to: consumeradvocate@smarterwayinc.com. If you have submitted personal information under more than one e-mail account, you must make this request from each account that you have used. Smarterway will use commercially reasonable efforts to delete records from our mailing list when we receive requests to do so. Because of possible retention of a residual copy in a system backup file, however, we cannot guarantee deletion in every instance. If we decide to change this privacy statement, we will post those changes on this Web site so our Users are always aware of what information we collect and how we use it.

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V. How secure is my information?

The information we receive from or about you is stored on systems designed to prevent the loss, misuse, unauthorized access, disclosure, alteration or destruction of that information. In addition, certain of the Smarterway Sites encrypt your transmission of sensitive information to it (e.g., credit card numbers, account passwords) in the interest of heightened privacy protection and information integrity. Financial information is stored in a secure location that is accessible only by designated staff and used only for the purposes for which you provide the information.

While we strive to protect your personal information, Smarterway cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk. In addition, Smarterway and third party Internet sites and services accessible through Smarterway or parties whom we inform you are collecting data in connection with contests, games, promotions, etc., have separate privacy and data collection practices, independent of us. Smarterway has no responsibility or liability for these independent policies or actions. You are solely responsible for maintaining the secrecy of your passwords and/or any account information. Please be careful and responsible whenever you are online.

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VI. Public Forums and Comments

The Smarterway Sites may make forums such as message boards available to its Users for entertainment or educational purposes only. Smarterway does not collect any User data through such forums and message boards. Nonetheless, please keep in mind that whenever you voluntarily disclose personal information online - for example on message boards, through e-mail, or in chat areas - such information can be collected and used by others. Such third party conduct is not within the control of Smarterway. As a result, you should exercise caution when deciding to disclose your personal information in these forums.

All feedback or comments submitted are the property of Smarterway and we may use this information for our own marketing purposes or to contact you for further feedback on the site.

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VII. Other Conditions of Use, Revisions

If you choose to visit one of the Smarterway Sites, your consent to the information practices described herein and your visit and any dispute over privacy is subject to the terms and conditions of this Privacy Policy and the Terms and Conditions for the individual site (including limitations on damages, and arbitration of disputes). You agree that Smarterway's liability for any breach of this privacy policy shall be limited to the value of the transactions or services provided to you by Smarterway to the extent that such a claim is not otherwise barred 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 Smarterway with regard to: (a) the purposes for such third party's personal have been collected; (b) the intended recipients or categories of recipients of the third party's personal data; (c) which of the third party's data are obligatory and which data, if any, are voluntary; and (d) how the third party can access and, if necessary, rectify the data held about them.

You further acknowledge that Smarterway (i) is a United States corporation; and (ii) operates in the United States. You agree (i) to permit Smarterway to transmit and use your User information anywhere necessary, including across international boundaries, to affect the services and transactions provided by this Site; and (ii) that such use by Smarterway shall be subject to the terms and conditions stated in this Privacy Statement and our Terms and Conditions.

Smarterway or its successors and assigns may amend the terms and conditions of the Privacy Policy at any time, or substitute a different agreement by posting a revised version on the Smarterway Sites. Please refer to our site periodically for updates. Amendments shall become effective upon posting. As we continue to develop our business, we might sell or buy certain assets. In such transactions, customer information generally is one of the transferred business assets. If Smarterway or its assets are acquired, customer information will of course be one of the transferred assets.

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VIII. Contact Us

If you have any questions, comments or concerns regarding our privacy policy and/or practices, please contact us as follows: