xaR International Privacy Policy

Welcome to xaR International, Inc. Please carefully read our privacy policy to understand how we will treat the information you provide while visiting this Web Site. This privacy policy applies to xaRÔ and its domestic subsidiaries and affiliates. We have built our reputation on our commitment to deliver reliable information to our customers (both businesses and consumers) and to protect the privacy and confidentiality of personal information about consumers. We also protect the sensitive information about businesses. Safeguarding the privacy and security of information, both online and offline is a top priority for xaR. This privacy policy applies xaR's commitment to privacy in an online setting and applies to both individual consumers and certain business organizations that use xaR’s Web Site. xaR reserves the right to change this privacy policy at any time. Please check the policy each time you use our Web Site for the most current information.

Collection and Use of Information

Internet Information - When you visit this Web Site, we may collect general Internet data, including your domain name (e.g. AOL, Earthlink, etc.), the web page from which you entered our site, which of our web pages you visited, and how long you spend on each page. To collect this information, when you visit our Web Site, a "cookie" may be set on your computer. Cookies contain a small amount of information that allows our web servers to recognize you whenever you visit. We use the information we collect to study how this site is used, so that we may improve and enhance your experience on our Web Site. We do not provide this information to outside parties other than for such reasons. No personal information is stored in cookies.

Information You Provide - This xaR privacy policy applies to all information we receive online from you and about you in connection with an online transaction or request. When you provide information through this Web Site, we may use it for various reasons, such as with our identity awareness, wellness and insight “Identity Solutions” products. Based on the nature of your transaction with us, you may provide to us certain personally identifiable consumer information, such as first and last name; home address, billing address, or other physical address; an email address (so we may contact you); a telephone number; a social security number; or certain other information, such as date of birth, employment information, and certain credit card and loan account information (collectively, "Personally Identifiable Consumer Information"). In general, we will use the information collected from you for the purpose for which you provided such information. We will not release your Personally Identifiable Consumer Information to third parties except: (1) as necessary for us to process your transaction or (2) as permitted by law. These third parties are not allowed to use Personally Identifiable Consumer Information except for the purpose of providing these services. We may use information you provide to update our databases. However, access to information on xaR’s databases is limited to permissible purposes as requested by you.

Information From Others - We may also collect information about your transactions with us, our affiliates, or others, such as the products and services you ordered. In connection with requests for Identity Solutions products, for example, we access your xaR individual file information or your xaR business organization file. In connection with verifying your identity as an individual we may also collect from outside sources personally identifiable information about you, such as name, address, driver's license information, and e-mail addresses. Also, in connection with verifying the identity of you as a business organization we may collect from outside sources business organization identifiable information, such as name, address, and e-mail address.

How We Use The Information We Collect

We use the information we collect about you to handle the requests you make to us. If you as an individual request an individual file disclosure, the information we collect from you is only used to handle those requests and possibly update your xaR individual file.

When you subscribe to xaR Identity Solutions we also use the information we collect about you. Once you have become subscriber to xaR Identity Solutions, we use the information when you ask xaR to provide you: 1) the Identity Solutions products and services you requested; 2) support for these Identity Solutions products and services; and 3) information about your Identity Solutions products.

Additionally, as legally permitted, we may use the information we collect for your Identity Solutions subscription and other requests, including postal address and/or e-mail address, to send you promotions for Identity Solutions products and services.

To Whom We May Disclose The Information We Collect

We may disclose any information collected from you or about you through the xaR Web Site to which this privacy policy applies as required by law or legal process.

We take reasonable precautions to be sure that nonaffiliated third parties and affiliates, to whom we disclose personally identifiable information or business organization identifiable information, as described below, are aware of our privacy policy and fair information principles and will treat the information in a similarly responsible manner. Our contracts and written agreement with nonaffiliated third parties that receive information from us about you as an individual, who has not opted out of this disclosure, prevent further transfer of the information.

xaR is not, however, responsible for the privacy practices or content of link sites listed on our web pages. The owners of these pages are responsible for them.

When you become a subscriber of Identity Solutions and purchase products or services directly from xaR, we may disclose any of the information we collect from or about you, as described above, to the following types of non-affiliated third parties (companies that are not owned or controlled by us) for various business purposes, including marketing and joint business efforts for related and unrelated products and services, such as:

· Financial services providers, such as banks and mortgage lenders;

· Non-financial companies such as retailers, direct marketers, and publishers;

· Companies that perform marketing services on our behalf and other financial institutions with which we have joint marketing agreements; and

· Others, as permitted by law.

We may also disclose any of the information we collect, as described above, to affiliates, which are companies that are related to us by common ownership or affiliated with us by common control.

We may disclose any of the information, as described above, to the types of affiliates and non-affiliated third parties, described above, whether you as an individual or you as a business organization make a one-time purchase of an Identity Solutions product or you as an individual or you as a business organization have an ongoing or prior subscription to Identity Solutions.

Access to Your Information

When you provide information on our Web Site, you should ensure that the information is accurate. In accordance with applicable federal and state Fair Credit Reporting law you as and individual have access to your individual information file either online or by requesting it by mail or telephone through xaR. You as an individual can make a request online for reinvestigation of information in your xaR individual file which you dispute.

If you have become a subscriber of Identity Solutions, you also have the ability to access to your Identity Solutions products online. Additionally, if you have an ongoing subscription to Identity Solutions products, you may have access to all of your registration information that is available online.

xaR Information Values

We take reasonable steps to:

· Give you, as a visitor to this Web Site, clear notice of:

- when we are requesting information from you;

- the types of information we request from you;

- the general purposes for which that information will be used or disclosed; and

- the categories of users to whom we provide the information;

· Offer you as an individual the ability to opt out of certain uses of the information we collect about you online;

· Maintain accurate records, provide you access to the personally identifiable information or business organization identifiable information that is retrievable online, or that is contained in your individual file or your business organization file, and provide you a fair procedure to update and correct such information; and

· Provide information to you about:

- the information we collect about you;

- the information we ask you to provide;

- the information we receive from others;

- how we use the information we collect about you; and

- to whom we disclose the information we collect about you;

· You can make decisions about the information we collect:

- opting out of our providing information about you to third parties;

- opting out at our Identity Solutions; and

- opting out of our Identity Solutions promotional offers;

We interact with consumer groups, regulators, industry associations and others to develop practices that build consumer trust; We acquire information from reputable sources and take reasonable precautions to ensure and maintain the accuracy of that information; We employ quality control procedures that help identify inaccurate or out-of-date information and minimize the addition of such information to our databases; We periodically audit the information within our databases to maximize its accuracy and correctness; We frequently update the information in our databases to ensure it is as current as possible;

We comply with all laws and applicable self-regulatory guidelines; We acquire information with assurance that it has been obtained legally and can be provided to us for use and disclosure; We comply with all contractual restrictions placed on information provided to xaR; We educate consumers, clients and employees about our business and our Information Values;

Accountability For Information Use

xaR is held accountable for its information use by consumer privacy expectations and by laws and industry codes established by government entities and industry organizations around the world.

Among the laws and industry self-regulatory codes with which xaR complies in the United States are:

· The federal Fair Credit Reporting Act

· The Gramm-Leach-Bliley Act

· The Children's Online Privacy Protection Act

· CAN SPAM Act

· Health Insurance Portability & Accountability Act

xaR is not, however, responsible for the privacy practices or content of link sites listed on our web pages. The owners of these pages are responsible for them.

Your Choice to Opt Out

Opting Out of Our Providing Information About You To Third Parties -

If, in connection with your subscription to Identity Solutions products or services that you as an individual request or obtain, you as an individual prefer that we not disclose to non-affiliated third parties any personally identifiable information that we collect about you as an individual, you may choose to opt out of such disclosures; that is, you as an individual may direct us not to make these disclosures.

Opting Out of Our Identity Solutions Promotional Offers –

As legally permitted, Identity Solutions may send you promotional offers by e-mail. You may opt out of further promotional offers electronically by clicking on the "unsubscribe" button in the e-mail.

Security

xaR recognizes the importance of secure online transactions, and we maintain physical, administrative, and technical safeguards to protect your personally identifiable information, your business organization identifiable information, and the other information we collect about you, as described above.

We safeguard the privacy of information you provide us through online forms. For online requests and Identity Solutions product orders and service requests, we use programs that encrypt the information you provide on the form before transmission to xaR. Information you provide to us online, including personally identifiable information and business organization identifiable information, is transmitted to us through a secured socket layer (SSL) transmission. The information is decrypted only upon receipt by xaR.

Except as stated in the "To Whom We May Disclose The Information We Collect" section above, we restrict access to personally identifiable information and business organization identifiable information that is collected about you to only those who have a need to know that information in connection with the purposes for which it is collected and used.

Additionally, we have security protocols and measures in place to protect the personally identifiable information, business organization identifiable information and other information we maintain about you from unauthorized access or alteration. These measures include internal and external firewalls, physical security and technological security measures, and encryption of certain data.

You also have a role in protecting the security of information about you. For example, you should guard your password to the Identity Solutions Subscription Center and not permit unauthorized use of your account for Identity Solutions products. Additionally, you should close your browser when have finished viewing your information on the xaR web site to protect the privacy of your individual or business organization information.

Policy Regarding Children

We define children as individuals under the age of 16. Our Web Site is not intended for the use of children and we do not intend to collect information about children through our Web Site. We comply with the Children's Online Privacy Protection Act and do not knowingly solicit or collect information from children.

Other privacy resources

For more information about privacy, visit these Web sites:

· The Federal Trade Commission

· The Coalition for Sensible Public Record Access

· The Direct Marketing Association

· Email Service Provider Consortium

· Network Advertising Initiative

· Anti-Phishing Working Group

If you have questions or comments about xaR's privacy policy and practices, please e-mail us at privacy@xarinternational.com or write to, xaR International, Inc., 404 Wyman Street, Waltham, MA 02451 USA, Attention: Legal.

Effective Date: December 11, 2006