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RISKMETRICS® GROUP, INC
RISKGRADES™ MEASUREMENT SERVICE
PRIVACY AND INFORMATION SECURITY POLICY

RiskMetrics Group, Inc. ("The RiskMetrics Group") is committed to protecting your online privacy with respect to the personally identifiable information that The RiskMetrics Group may obtain from you when you register for and use the measurement services offered by The RiskMetrics Group at http://www.riskgrades.com. Our Privacy Policy answers frequently asked questions about your online privacy, including what personally identifiable information we may obtain from you and how it will be used and protected. The RiskMetrics Group may from time to time change this Privacy Policy, so please check back periodically.

WHAT PERSONALLY IDENTIFIABLE INFORMATION DO WE OBTAIN FROM YOU? WHEN DO WE OBTAIN SUCH INFORMATION?

If, upon visiting our site, your use is limited to obtaining risk analysis of individual stocks, we will not require that you provide us with any personally identifiable information.

If, however, you seek to obtain risk analysis for a portfolio of stocks, we will ask that you provide us with certain personal information (apart from a listing of your portfolio of stocks), including your name, password, e-mail address, and zip code as well as certain optional information.

In addition, we may request personal information from you at other times. For example:

  • If you want to use the RiskRanking™ function to compare your portfolio's risk to that of other users with particular demographic characteristics, we will need information such as your gender, birthdate, income, net worth or other information as may be required to facilitate the comparison.

  • If you want to enter any sweepstakes, contests or promotions sponsored by us or by one of our business partners, we will need your name, e-mail address and other information as may be required by the rules of the specific contest.

  • If you choose to participate in a customer survey conducted by us or by one of our business partners, we may ask for your name, e-mail address and other information as may be required by the particular survey.

  • If you report a problem or submit a customer review, we will ask that you provide your name and e-mail address. Should you contact us for any reason other than to report a problem and/or submit a review, we may also keep a record and/or copy of your correspondence with us.

HOW DO WE USE YOUR INFORMATION?

Our primary use of your information is to administer, maintain and improve your experience on our web site generally as well as provide you with customized, personalization services and interactive communications.

  • Provided that you voluntarily check the "opt-in" feature on our web site, we may from time to time send you e-mails regarding our web site and special promotions. Also, we occasionally may send you e-mails about products or services that we believe may be of interest to you.

  • When you enter any sweepstakes, contests or promotions sponsored by us or by one of our business partners, we may use your e-mail address to send you status updates.

  • We use your IP address to help diagnose problems with our server and to administer the services offered on our web site. We also use your IP address to gather broad demographic information that we may share with our advertisers and sponsors, but only in the aggregate without any of your personally identifiable information.

  • We research the demographics, interests and behavior of our customers based on the information provided to us upon registration, during promotions and contests, from our server log files, from cookies and from surveys. Our research may be compiled and analyzed on an aggregate basis. We may share this aggregate data with advertisers or business partners, but only in the aggregate, without any of your personally identifiable information.

PRIVACY POLICIES OF RISKMETRICS® PARTNERS

Sponsors and other web sites that have links on the "riskgrades.com" web site may collect personally identifiable information about you. We are not responsible for the privacy policies or practices of such sites and the practices of these sites are not governed by this Privacy Policy. If you have questions about the privacy policies or practices of a third party site, you should contact the site administrator or web-master of the specific site.

DO WE SELL OR RENT YOUR PERSONALLY IDENTIFIABLE INFORMATION?

No, as a general rule, we do not sell or rent your personally identifiable information to any one. If and whenever we intend to share your personally identifiable information with a third party, you will be notified at the time of data collection or transfer, and you will always have the option of not permitting the transfer. However, we may from time to time rent or sell demographic information in the aggregate that does not contain your personally identifiable information.

WITH WHOM DO WE SHARE INFORMATION?

We generally will not disclose any of your personally identifiable information except when we have your permission to do so or under some special circumstances described below.

  • We may disclose your personal information to business partners and sponsors, but only if we have obtained your permission to make the disclosure before data collection or before transferring the data. Also, from time to time, we may offer you the opportunity to receive materials or special offers from third parties. If you want to receive this information, we may (but only with your permission) share your name and e-mail address with them.

  • Some promotions, sweepstakes and contests may be sponsored by other companies or co-sponsored by us and other companies. We may share with the sponsor some or all of the data collected during such promotion. We will notify you before the time of data collection or transfer if the data is to be shared. You can decide not to participate in the promotion if you don't want your data to be shared.

  • We also may disclose aggregate demographic and/or user information and statistics in order to describe our customer base to prospective partners, advertisers and other third parties, and for other lawful purposes.

  • We may disclose your personally identifiable information without your prior permission in special cases. For example, we may have reason to believe that disclosing the information is necessary to identify, contact or bring legal action against someone who may be violating the Terms of Service, or may be causing intentional or unintentional injury or interference to the rights or property of The RiskMetrics Group or any third party, including other customers. Also, we may disclose or access your personally identifiable information when we believe in good faith that law or regulation requires disclosure.

WHAT ARE COOKIES? HOW DO WE USE COOKIES?

Cookies enable us to customize and personalize your experience on our web site, including the products, promotions and advertisements that are offered to you. Essentially, a cookie is a small amount of data that is sent to your browser from a web server and is stored on your computer's hard drive. We use cookies for several purposes in connection with the operation of our web site.

  • Most important, we use cookies to identify you and access your information stored on our computers in order to deliver you a better and more personalized experience. For example, we use cookies to ensure that you don't see the same advertisement repeatedly and to tell you about products and services specific to your interests.

  • We also use cookies to save your password so that you don't have to re-enter it each time you visit our web site.

  • We also use cookies to estimate our customer base and customer usage patterns. Each browser accessing our web site is given a unique cookie which is then used to determine the extent of repeat visits and the customer activity during those visits. We use the historical information to help target advertisements and promotions based on customer interests and behavior, both specifically to individual customers and on an aggregate basis with respect to all customers.

  • We also may use cookies to track your progress and number of entries in some promotions, sweepstakes and contests. For example, when a promotion uses cookies, the information coded to the cookie indicates your progress through the promotion, and may be used to track entries, submissions and status of prize drawings.

  • Advertisers that place ads on our web site, and business partners that offer their own promotions, products and services through our web site, may use their own cookies. We have no control over those cookies, nor does this Privacy Policy cover how your personal information contained in those cookies may be used or protected. If you have any questions about the cookies of such third parties, or about the use of your personal information by such third parties, you should contact the site administrator or web-master of the third party site.

DO YOU HAVE CHOICES ABOUT COOKIES?

Yes, you have several choices with respect to cookies. You can modify your browser preferences to accept all cookies, to notify you when a cookie is set, or to reject all cookies. However, if you choose to reject all cookies, you will not be able to login and use personalized portfolio functionality, you may not be able to participate in promotions, or purchase any products or services, offered by us if registration is a requirement of participation or purchase.

HOW DO WE PROTECT THE SECURITY AND QUALITY OF YOUR PERSONAL INFORMATION?

To protect the security and quality of your personal information, we have implemented technical and managerial procedures to maintain accurate, current and complete information as well as to protect your personal information against loss, misuse or alteration when it is under our control. Your personally identifiable information will be stored on our secured servers. Your personal information is also password protected so that access is limited to yourself and those with whom you share your password, and The RiskMetrics Group.

WHAT ELSE SHOULD YOU KNOW ABOUT YOUR ONLINE PRIVACY?

It is important to remember that whenever you voluntarily disclose personal information on-line (for example, on message boards, in chat rooms, or through e-mail), your information can be collected and used by others. If you transmit or post personal information on-line that is accessible to others, you will not be able to control how that information is used by others including that you may receive unsolicited messages in return.

When we receive the transmitted information, we will use our best efforts to ensure the integrity and security of that information in our systems. Unfortunately, notwithstanding any of the steps taken by us, it is not possible to guarantee the security and integrity of data transmitted over the Internet. Consequently, while we take the above-described reasonable steps to protect your personal information, we cannot and do not warrant the security or integrity of any information you transmit to us when registering for our web site or otherwise. All such transmission of information is at your own risk.

Moreover, though we are committed to having our web site comply with this Privacy Policy, you are ultimately responsible for maintaining the secrecy of your passwords and your personally identifiable information. If you are careless with your password, or you decide to share your password with third parties, you must be aware of the risk that such third parties will have access to all your personally identifiable information.

© 2000 RiskMetrics Group, Inc. All rights reserved.

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