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Web site operators should consider developing and posting a privacy policy addressing issues concerningthe collection of online information about Web site users. The following sample Web site privacy policy addresses how user information is collected, the use of such information and security. ***** XYZ (“Company”) is committed to protecting the privacy of our customer’s personal information. This statement applies with respect to the information that we collect from the Company Web site, located at XYZ.com. Amendments to this statement will be posted at this URL and will be effective when posted. Your continued use of this site following the posting of any amendment, modification or change shall constitute your acceptance thereof. I. INFORMATION COLLECTED We collect non-personally identifiable information about you in a number of ways, including tracking your activities through your IP address, computer settings or most-recently visited URL. We may also ask you to provide certain non-personally identifiable information about yourself, such as your age, household income, buying preferences, etc. We do not collect any personally identifiable information about you unless you voluntarily submit such information to us, by, for example, filling out a survey or registration form. The types of information that may be requested include your name, address, e-mail address, and telephone number. II. USE OF INFORMATION In general, we will only use the information you provide to us for the purpose for which such information was provided. We may also use this information to deliver to you information about our company and promotional material from some of our partners, trend analysis, pattern detection, and site administration. Your information may also be used to contact you when necessary and may be shared with other companies that may want to contact you with offers consistent with your stated preferences. Users may opt-out of receiving future mailings from Company and other entities by following the instructions set forth in the opt-out section below. Non-personal demographic and profile data is used to tailor your experience at our site, showing you content we think you might be interested in. This information may also be shared with advertisers on an aggregate non-personal basis. III. USE OF IP ADDRESSES We use your IP address to help diagnose problems with our server, and to administer our Web site. IV. USE OF COOKIES When you view our Web site we might store some information on your computer. This information will be in the form of a “cookie” or similar file. Cookies are small pieces of information stored on your hard drive, not on our site. Cookies do not spy on you or otherwise invade your privacy, and they cannot invade your hard drive and steal information. Rather, they help you navigate a Web site as easily as possible. We use cookies to deliver content specific to your interests and to prevent you from reentering all your registration data at each connection. We use an outside advertisement server company to display ads on our site. These ads may contain cookies. The advertisement server company may collect cookies received with outside banner ads. We do not have access to information that would confirm the use of cookies by the advertisement server company. V. SECURITY Our site has industry standard security measures in place to protect the loss, misuse and alteration of the information under our control. While there is no such thing as “perfect security” on the Internet, we will take all reasonable steps to insure the safety of your personal information. VI. OTHER WEB SITES; LINKS Our Web site contains links to other Web sites. XYZ is not responsible for the privacy practices or the content of such Web sites. VII. CORRECT; UPDATE XYZ allows its users the option to change or modify information previously provided. This may be done through the following methods: (1) e-mail the information to ______ (2) visit the Customer Service section of the site and follow the appropriate instructions. Unfortunately, to the extent that such information is also stored in other databases, we cannot always ensure that such corrections or deletions will reach the other databases. We will use all reasonable efforts to ensure that your information is removed from or corrected in our records. VIII. CHOICE; OPT OUT You may opt-out of receiving communications from our partners, and from us, by the following means: (1) send an e-mail to __________ (2) visit the Customer Service section of the site and follow the appropriate instructions. IX. PUBLIC FORUMS This site makes chat rooms, forums, message boards, and/or news groups available to its users. Please remember that any information that is disclosed in these areas becomes public information and you should exercise caution when deciding to disclose your personal information. Contacting us: If you have any questions about this privacy statement, the practices of this site, or your dealings with this Web site, you can contact us at ___________. ***** This sample form is intended to serve solely as an exemplar and may need to be modified to conform to the legal requirements of your jurisdiction. It in no way constitutes legal advice. Julian S. Millstein, Jeffrey D. Neuburger and Jeffrey P. Weingart are partners with the law firm of Brown Raysman Millstein Felder & Steiner in New York. For information on purchasing the book, “Doing Business on the Internet: Forms and Analysis,” please go to www.lawcatalog.com.

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