privacy policy

We have developed this policy because we want you to feel confident about the privacy and security of your personal information.
This Policy applies to all transactions in the Company‘s securities, including common stock, options and warrants to purchase common stock and any other securities the Company may issue from time to time, such as preferred stock, warrants and convertible debentures, as well as to derivative securities relating to the Company‘s stock, whether or not issued by the Company, such as exchange–traded options. It applies to all officers and directors of the Company, all other employees of the Company and its subsidiaries, all secretaries and assistants supporting such directors, officers and employees, and consultants or contractors to the Company or its subsidiaries who have or may have access to Material Nonpublic Information (as defined below) regarding the Company and members of the immediate family or household of any such person. This group of people is sometimes referred to in this Policy as “Insiders.” This Policy also applies to any person who receives Material Nonpublic Information from any Insider. Any person who possesses Material Nonpublic Information regarding the Company is an Insider for so long as such information is not publicly known.

We may ask you for information to enable us to provide a service to you and we collect this information by telephone, written correspondence or via a website. We may ask you for information including your name, private/business address, contact telephone numbers and email address. We may also ask you for other information that relates to the service you are using or ordering. For example, we may need your credit card number to charge you for certain services.

When you (or someone using your telephone line) make a telephone call or send a fax that uses our telephone network or connect to the world wide web, we keep a record of that call (including the number called) to enable to charge for it. We also receive from other operators information about calls made over our network, where we need that information for connecting and billing purposes.

If someone abuses or damages the telephone network, for example by making offensive or nuisance calls, we may keep information relating to that abuse.

We have information about your use of our services (such as the amount of time you spend on–line), which we use to manage our network, and for billing. We may also use this information for marketing products and services but we will give the option to opt out of receiving this material.

If you enter into any of our competitions or promotions, we may ask for information about you, which will be made clear at the time you enter. We will also inform you of the purposes for which the information you provide may be used.

We may ask you from time to time about what use you make of the services we provide, what other services you would like us to provide in the future, and for other information, such as lifestyle data.

We collect information from visitors to our websites to help us to make improvements to the websites and to the services we make available. We know, for instance, how many visitors there are to each website, when they visited, for how long and to which areas of our website they went. We may share this information with our advertisers and to other companies which offer their goods or services on our websites. It helps to show these organizations how effective our websites are as sales channels for their products. You or any other individual cannot be identified from the information we share as the data is aggregated and anonymised.

We do not use this information to identify individuals visiting our website; or analyze your visits to any other websites (except that we do track you if you go to websites carrying our banner, but we do not identify personal details while we do this); or track any Internet searches which you may make while on our website.

STATEMENT OF POLICY

General Policy

It is the policy of the Company to prohibit the unauthorized disclosure of any nonpublic information acquired in the workplace and the misuse of Material Nonpublic Information in securities trading.
Specific Policies

1. Trading on Material Nonpublic Information. With certain exceptions, no officer or director of the Company, no employee of the Company or its subsidiaries and no consultant or contractor to the Company or any of its subsidiaries and no members of the immediate family or household of any such person, shall engage in any transaction involving a purchase or sale of the Company‘s securities, including any offer to purchase or offer to sell, during any period commencing with the date that he or she possesses Material Nonpublic Information concerning the Company.

2. Tipping. No Insider shall disclose (“tip”) Material Nonpublic Information to any other person (including family members) where such information may be used by such person to his or her profit by trading in the securities of companies to which such information relates, nor shall such Insider or related person make recommendations or express opinions on the basis of Material Nonpublic Information as to trading in the Company‘s securities.

3. Confidentiality of Nonpublic Information. Nonpublic information relating to the Company is the property of the Company and the unauthorized disclosure of such information is forbidden.

4. Duty to Report Inappropriate and Irregular Conduct. All employees, and particularly managers and/or supervisors, have a responsibility for maintaining financial integrity within the company, consistent with generally accepted accounting principles and both federal and state securities laws. Any employee, who becomes aware of any incidents involving financial or accounting manipulation or irregularities, whether by witnessing the incident or being told of it, must report it to their immediate supervisor and to the Company‘s Audit Committee. In certain instances, employees are allowed to participate in federal or state proceedings. For a more complete understanding of this issue, employees should consult their employee manual and or seek the advice of counsel. Our general corporate and securities counsel is Janete Bueno, attention: Janete Bueno
(34) 928 267 467, email: ku.oc.moceletavon@lagel We may change our privacy policy from time to time. New policies will be published on our web sites.
Our privacy policy also applies to information collected when you use any of our websites.
You do not have to register to access most of our websites. However, if you provide information via the “contact us” or any of the other interactive features, you indicate your consent to our use of your personal data in the manner described in this privacy policy. If you do register on one of our websites, we may ask you to provide personal details such as name, address, e–mail address, telephone number and, where appropriate, our account number. We also ask you to choose a password, and to complete a password security question and answer, in case you forget your password for any reason. Once you have registered on one of our websites, we may keep a record of your use of any of the services made available via that particular website. (Please see “When does use cookies” below for more information on how we do this). If you choose not to register with us and only browse our websites, we may gather information to help make your visit to our website more satisfying. However, this information will not identify you personally. (Please see “When does use cookies” below for more information on how we do this). If you do not wish to register, you will still be able to use and order some of the services offered via our websites. We will only ask you to provide such information as necessary to enable us to carry out the transaction in question. We will not use that information for any other purpose. You should note that some services are only available if you register on the website first. If you have registered for any of the services available through our websites you may choose to cancel that registration at any time. You can do this in one of two ways: return to the original registration page and following the instructions for cancelling the registration; or send an e–mail to us by completing the feedback form Please ensure you inform us of the service which you wish to cancel.
If you do either of these, your personal details will be deleted from our website database.
If you have registered you have direct control over information in your personal profile on our website. You can access and change this information at any time by using the “Update your profile” link.

Over and above what does to safeguard your privacy and security on–line, there are a number of things you can do to protect yourself from Internet fraud:
Choose a password (letters and digits) you can remember but others will not guess, change it regularly and, if you do write it down, keep it somewhere safe and secure.
When you have finished your session on our website, make sure you prevent your details being seen by anyone that you do not wish to see them. So, if you have registered and logged in, remember to log off.
Clear any cache so there is no record of any transactions left on screen – both Netscape and Internet Explorer let you do this.
We also recommend you then close your browser so any history of the session is cleared. As an extra precaution, your session on .com will time out if you have not used the site for 30 minutes.
We collect information from visitors to our websites to help us to make improvements to the websites and to the services we make available. We know, for instance, how many visitors there are to each website, when they visited, for how long and to which areas of our website they went. We may share this information with our advertisers and to other companies which offer their goods or services on our websites. It helps to show these organizations how effective our websites are as sales channels for their products. You or any other individual cannot be identified from the information we share as the data is aggregated and anonymised.
We do not use this information to identify individuals visiting our website; or analyze your visits to any other websites (except that we do track you if you go to websites carrying our banner, but we do not identify personal details while we do this); or track any Internet searches which you may make while on our website.

When do we use cookies?

A “cookie” is a text file which is allocated by our server to your personal computer (PC) when you visit our website. If you want to know more about cookies please go to www. which explains how cookies work and how you can manage their use. We use “cookies” to collect information from visitors to our websites and registered customers.
Our servers use two different types of cookies. The first type is known as a “session–based” cookie and is allocated to your PC only for the duration of your visit to our website. It helps you to move around the website faster. This cookie automatically expires when you close down your browser.
The second type of cookie known as a “persistent” cookie is allocated to your PC only if you agree by selecting the “Remember me” function. This cookie, if chosen, will remain on your PC for a period of time.

This cookie allows us to:

welcome you as an individual when you log on to our website;
limit how often you see particular advertisements or announcements on our website;
identify your defaults if you have set up a customized homepage
provide you with relevant self–help information;
track where you have come from if you have come to our website from another website;
track how many times you visit a page or advertisement.

We do not store information regarding your telephone number, account or payment details in the cookie, and this information cannot be accessed using it. BT‘s cookies do not collect any information regarding the use of your PC or your Internet browsing in any way.
Please note that as the cookie is based on your PC, we will not find it if you visit our websites using a different PC to the one you registered on.
Third party Internet sites that you can link to from websites are not covered by our privacy policy, so we urge you to be careful when you enter any personal information online. A ccepts no responsibility or liability for these sites.
Other companies which advertise or offer their products or services on our website may also allocate cookies to your PC. The types of cookies they use and how they use the information generated by them will be governed by their own privacy policies and not ours.

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