PRIVACY POLICY

Introduction

This statement discloses the privacy practices for Position Technologies, Inc. ("PTI"), which owns and operates the following sites on the World Wide Web: positiontech.com, positionpro.com and submitdirector.com. When signing up for any of our services, you will be asked to provide information about you. This information is collected to ensure that we receive payment for using our services and also so that we can communicate with you when necessary. It is extremely important that you understand that any information that identifies you will never be shared with anyone without your consent. Our privacy statement as set forth below is written so that you can understand exactly what we do and don't do with your information. While we will never share information that may be used to identify you, we do expect our policy statement will change as new ways to protect your confidentiality and new uses for information emerge. To that end, we value your comments about our privacy statement and invite you to e-mail us with suggestions and concerns.

Special Terms for Customer Subscribing To The Overture Site Match Program through PTI

The terms that permit PTI to support the Overture Site Match Program dictate that Overture shall be a co-owner of all Customer Information collected that relates to the Site Match Program. Accordingly, you specifically consent to and permit the sharing of such Customer data between PTI and Overture. The terms of PTI's Privacy Policy will otherwise apply to all Customer Information and any data shared with Overture shall be governed by Overture's Privacy Policy, a copy of which may viewed by clicking on the following link: <http://www.content.overture.com/d/USm/legal/privacy.jhtml>. Note that while PTI ensures its Customers that it will handle Customer Information in accordance with its stated Privacy Policy, PTI has no control over the terms of the Overture Privacy Policy and is not in any way responsibility for ensuring that Overture abides by the terms of its own Privacy Policy or otherwise handles Customer Information in an appropriate manner.

Overview

Position Technologies, Inc. (PTI) is committed to safeguarding your privacy on-line. PTI will use the information it collects to communicate with you and to administer to your account. At no time will PTI disclose any information that it collects from you without your approval including Credit card information or other personal financial information that may be gathered by PTI during the course of your account activity to any third party. The sole use of this information is for PTI to receive payment for the services. PTI is the sole owner of the information collected on this site for all Programs other than the Overture Site Match Program. We will not sell, share, or rent this information to others in ways different from what is disclosed in this statement. Note that if you sign up for service from one of our Partnership programs, you hereby authorize and consent that we may share with the Partner the following information concerning you: e-mail address, name, title, entity, address and phone number (collectively "Contact Information"). No financial information will be shared. Further, all of our Partners have privacy policies that protect against the disclosure of personally identifiable parties to third persons. This Policy may change from time to time and any and all changes will be posted on our Web page in this section. Please read this policy carefully and review it periodically to keep informed of any changes.

What information is collected?

Only two types of information are collected: Contact Information and Financial Information. As stated above, the purpose of collecting this information is to allow PTI to administer to your account and provide better service to you.

• Personal Financial Information

None of a user's personal financial information (such as a credit card number and expiration date) is ever distributed, sold or rented to any party for secondary purposes. The personal financial information of our Subscribers is used only for internal administrative purposes (i.e. appropriate billing).

• Contact Information

We collect personal information that may include names, address, phone number, e-mail address, billing address, etc. This Contact Information is never sold, rented or distributed to third parties for secondary purposes and is used for administrative purposes (such as billing or contacting you regarding the services we provide). We will share Contact Information we collect only with those of our Partners with whom you have an account or whose services you have consented to use. We require that all our Partners have their own Privacy Policy in place.

Where do we collect information from you?

We collect information from:

• Registration and Account Set Up

  When you sign up for services from PTI, you will be asked to provide certain basic Contact Information. After this is entered you, we will establish your account. You will be given the opportunity to provide additional Contact Information once your account is established. In addition, Financial Information will be collected to process payment for the services we provide.

• Customer Service

  If you contact PTI either via e-mail, telephone or letter, we may keep a record of the correspondence.

How is this information used?

The information we collect is used to contact you regarding our services and to ensure that we get paid for providing services to you.

Who is collecting information?

Only PTI is collecting information while you are on our Web sites or using our services. Our Web sites may also provide links to third parties and their Web sites. We are not responsible for third party Web sites and how that Web site may handle the collection or distribution of information gathered at those sites. We recommend that you review the privacy policy of any Web site you decide to visit. We do not control, are not responsible for, nor are we recommending the usage of any other Web site. The links provided on our Web sites are there because a person or entity has paid or contracted for the right to have a link.

With whom is your information shared?

We will never share any Personal Financial Information, except in the very limited circumstances when we have your consent or when we are required to disclose pursuant to a court order or if requested by a law enforcement agency or other legal requirement. As stated above, we will share Contact Information with those of our Partners with whom you have an account or whose services you have consented to use. Further, we share information collected from cookies with our partners to track sales and site visits and to develop information about web usage. In the course of sharing this information, we do not share any personally identifiable information. A more specific explanation of our use of cookies is found below.

Does PTI monitor e-mails or other communications?

We do not monitor in advance user's communications, e-mails or other content distributed through the Internet. By using our service you acknowledge that PTI is unlikely to be aware of violations of law or other misconduct occurring over the Internet. As a user of our service, you bear full responsibility for the material received and sent via e-mail. We may have the capability to review these communications while in use and be required to disclose personal or other information when required by law, court order, governmental agency or law enforcement authority.

How may you update information?

We allow you to update all of your Contact Information at any time by completing a change form on the positiontech.com Web site or by simply e-mailing us at the following address: support@positiontech.com. You may only change your e-mail address by e-mailing us from the new location and verifying the change.

Does PTI use any filtering software?

No.

Does PTI allow users under the age of 18?

No. We believe that it is especially important to protect minor's privacy on line and encourages parents and guardians to spend time online with their children to participate and monitor their Internet activity. If you are under 18, we recommend that you get your parent's permission before disclosing any information about yourself. PTI will not knowingly allow anyone under the age of 18 without the written permission from a parent or guardian. The parent of a child under 18 can review and have deleted their child's account.

Cookies

Upon visiting a PTI website or site of one of our Partners, a cookie is sent to your computer that uniquely identifies your browser. A "cookie" is a small file containing a string of characters that is sent to your computer when you visit a website. We use cookies to improve the quality of our service, to better understand how people interact wit us and our Partners. We do this by storing user preferences in cookies and by tracking user trends and activity of how people search and purchase on-line. Most browsers are initially set up to accept cookies. You can reset your browser to refuse cookies or notify you when a cookie is being setn. If you reject a cookie from us, you may still use our site with the understanding that we cannot guraantee that all features or services will function properly.

Referral program

We may offer a referral program in the future. If a user or subscriber elects to use our referral service for informing a friend about our site, we ask them for the friend's name and email address. We will automatically send the friend an email inviting them to visit the site. We store this information for the purpose of communicating our products and services. The referred individual may contact us at (e-mail address) or (telephone number) to request the removal of this information from our database. Presently, we only use cookies for administration of the site, such as remembering logins. None of our business partners use cookies on our site.

Newsletters and Subscriber communications e-mails

We may from time to time send e-mails to our Subscribers regarding our services. Also, we plan to develop a periodic electronic newsletter that we will send to all of our interested Subscribers. Out of respect for the privacy of our Subscribers, the receipt of such communications is handled on an op-in basis. Subscribers are given the opportunity to 'opt-in' to receiving these types of communications on our Web sites.

Security

Our Web sites take every precaution to protect our users' information. When users submit sensitive information via the Website, the information is protected both online and off-line. Because PTI uses some of the most sophisticated commercially available security software, it is extremely unlikely that any personal information that you transmit to us will be misappropriated. When our registration/order form asks users to enter sensitive information (such as credit card number and/or social security number), that information is encrypted and is protected with the some of the best encryption software in the industry - Verisign 56bit and 128 Bit encryption. While we use this encryption software to protect sensitive information online, we also do everything in our power to protect user-information off-line. All of our users' information, not just the sensitive information mentioned above, is restricted in our offices. Only employees and consultants who need the information to perform a specific job (for example, our billing clerk or a customer service representative) are granted access to personally identifiable information. Additionally, the servers that we store personally identifiable information on are kept in a secure environment, along with other proprietary information at our data center. Only authorized personnel are physically allowed into the data center or access to the internal proprietary information. Subscribers should not share their password or access code with others or place that information where other may gain access. You are responsible for making sure that this information is kept confidential.

PLEASE NOTE: Internet data transmission is not always 100% secure and we cannot warrant that information you transmit utilizing PTI's services is always 100% secure. Because security is important to PTI and our users, PTI pledges to take all reasonable measures to ensure the security of our services and system.

Notification of changes

If we decide to change our privacy policy, we will post those changes on our Web page at www.positionpro.com and at this location so our users are always aware of what information we collect, how we use it, and under circumstances, if any, we disclose it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify users by posting those changes at this site.

Customer satisfaction

PTI is committed to quality customer service and satisfaction. We are constantly reviewing our programs, traffic patterns and customer feedback to improve and enhance your experience with PTI. You can give us your comments by e-mailing us at support@positiontech.com or contacting our customer service line at 630-232-0446.

Acceptance of these terms

This Privacy Policy is incorporated into and subject to the terms and conditions of PTI's Services Agreement. Use of PTI's services is subject to those terms and conditions, which constitute a legal agreement between you and PTI. Each time you use PTI's services you signify that you have read, understood and agree to be bound by the Services Agreement, which incorporates the Privacy Policy. If you do not agree to the terms of this Policy or any other terms of the Services Agreement, please do not provide us with any information and do not use PTI's services. Your continued use of PTI's services in light of changes to this statement will signify your acceptance of the changes. Please review the terms of our Services Agreement, and if you do not agree to them, do not use our services, as you do not have our permission to do so.

Please also read our Services Agreement.

Questions regarding Privacy Policy

Questions regarding Position Technology Inc.'s Privacy Policy can be directed to our Customer Service Department at support@positiontech.com.