The Privacy Policy of ConsumerBase (hereafter referred to as "the Company") demonstrates our deep commitment to full disclosure regarding privacy issues. Since we gather certain types of information about our subscribers, we want subscribers to fully understand the terms and conditions surrounding the capture and use of that information. This privacy statement discloses what information we gather and how we use it.

1. Information the Company Gathers and Tracks
2. Sharing of Information
3. Delete / Deactivate Policy
4. Notification of Changes
5. Security Policy

1. Information the Company Gathers and Tracks

"Subscription" occurs when an end-user registers for the Company's services, either via registration at our website, via opt-in or opt-out co-registration at a marketing partner's website, or via an opt-out permission pass / opt-out mailing. The Company collects personally identifiable information about our subscribers, based on: information gathered at the time of registration, subscriber interaction and response to subsequent electronic mailings and website use, information provided by marketing partners, and information appended from data aggregators. Information collected may include, but is not necessarily limited to: name, email address, postal address, gender, birth date, telephone number, activity, interests, and other demographic information. This information enables us to better tailor our content to subscribers' needs and to help our clients to promote and sell their products and services.

The Company gathers subscriber information using some or all of the following processes:

Cookies: The Company minimizes the use of cookies to only those necessary to properly route subscribers, and customize the subscriber's experience. The Company provides links to advertiser and partner websites. These sites may choose to use cookies to better promote their products and services.

Usage Tracking: The Company tracks information related to the electronic mailings and web pages viewed by subscribers, as well as the hyperlinks clicked by subscribers, while viewing our emails or visiting our websites.

Log Files: Log files are used to track and monitor subscriber usage.

 Subscriber Feedback/Inquiries: Subscribers have the ability to contact the Company to provide us with their feedback. The Company uses this information to respond to the subscriber and analyze customer service issues.

2. Sharing of Information

All information provided to the Company about a subscriber, as well as any additional information we may lawfully collect regarding a subscriber, may be used to support our services and data sharing with marketing companies, advertising agencies, compilers, and data companies. The Company does not control the practices of our advertisers or third party marketers, who may further disseminate personally identifiable information, including demographic and lifestyle data.

Subscription status, unsubscribe request activity, and personally identifiable information is made publicly available for the purpose of checking subscription status and for investigating subscription issues.

Company emails and websites contain links to external websites. Subscribers will be taken to external websites if they click on these links. The subscriber's information may be passed from the Companyís database to the external website, and/or external database, for the convenience of the subscriber (e.g. subscriber information may be used to pre-fill a form at a destination website). The Company is not responsible for the privacy practices or content of any external website owner. We encourage all subscribers to review the privacy policy of any website they visit.

3. Delete/Deactivate Policy

Subscribers may unsubscribe to our electronic mailings at any time by following the instructions contained within our electronic mailings, or by unsubscribing via the Company's website.

Currently, the Company does not offer subscribers a means by which to completely delete personal information from our databases. Instead, subscription status is set to "unsubscribed" to suppress inclusion from future Company electronic mailings.

The Company's unsubscribe process impacts only the future delivery of electronic mailings disseminated by the Company on its own behalf. Former Company subscribers may still be shared with third parties for use in offline marketing, data appends, including email appends and email directory lookup services.

Company subscribers should also note that unsubscribing from Company electronic mailings will not automatically unsubscribe the subscriber's information from any third-party associates and licensees of the data. Since third-party associates and licensee partners maintain separate databases from the Company, subscribers will need to unsubscribe from each source individually, if desired. This allows the end-user the freedom to pick and choose which subscriptions to maintain and which to discontinue.

4. Notification of Changes

The Company's privacy policy and use of personally identifiable information is subject to change at any time without notice. The current version of our Privacy Policy will be posted at ConsumerBase.com.

5. Security Policy

The Company has created security guidelines to protect the loss or alteration of company database information.

Last updated: December 2003