ESP DATA SOLUTIONS, INC. PRIVACY POLICY

ESP DATA SOLUTIONS, INC. is committed to safeguarding your privacy on its Web site located at www.vinlink.com. This ESP DATA SOLUTIONS, INC. Privacy Policy does not apply to products or services provided, or information obtained, other than through the Web site. Please read the following policy to understand how your information will be treated. This policy may change from time to time so please check back periodically. If there is a material change in the collection, use, or disclosure practices to which you have previously agreed, we will attempt to send you a notice via e-mail if you have provided us with an e-mail address. Please keep in mind that some of the services mentioned specifically in this policy may not be available on the site at this time. If you have questions concerning this policy, please contact us at support@espdata.com. This Privacy Policy is effective as of December 1996.

What information does ESP DATA SOLUTIONS, INC. collect from me?

ESP DATA SOLUTIONS, INC. collects information in several ways. For example, some personal information is gathered when you register as a customer using our account interface. During registration, we ask for your ESP DATA SOLUTIONS, INC. Account Number and your e mail address. Once you register, you are no longer anonymous to ESP DATA SOLUTIONS, INC. and are able to take full advantage of our services. In addition to registration, we may ask you for information at other times, such as when you report a problem with our site or services, or contact the company via the corporate e-mail address. If you contact ESP DATA SOLUTIONS, INC., we may keep a record of that correspondence.

If you believe that any inaccurate or inappropriate information has been obtained or disseminated through your use of this Web site, you should contact a representative of ESP DATA SOLUTIONS, INC. at support@espdata.com.

What are cookies and how does ESP DATA SOLUTIONS, INC. use them?

As part of offering and providing customizable and personalized services, many Web sites use cookies to store and sometimes track information about you. A cookie is a small amount of data that is sent to your browser from a Web server and stored on your computer's hard drive. We use cookies to allow faster and easier access to your account information, monitor traffic on the site and measure traffic patterns to improve functionality. ESP DATA SOLUTIONS, INC. Web pages may in the future contain electronic images known as Web beacons (sometimes called clear giffs or Web bugs) or other advanced technologies that are useful in the provision of services to you. We may use such devices to verify compliance with our terms and conditions of use or with any promotions on the site.

How does ESP DATA SOLUTIONS, INC. use the information?

ESP DATA SOLUTIONS, INC.' primary goal in collecting information is to improve the site and provide the user with the best possible experience on the site. For example, by using the information collected, we are able to provide you with an easy to use and readily available forum to access your ESP DATA SOLUTIONS, INC. account information. We will also use your personal information to notify you of other products or services available from ESP DATA SOLUTIONS, INC. and its affiliates.

Only ESP DATA SOLUTIONS, INC. and its affiliates will have access to individuals' account information. We also may do research on our users' demographics and behavior based on the information provided to us upon registration, gathered from transaction activity, from our server log files or from surveys. This research may be compiled, analyzed or sold on an aggregated basis, which does not include information identifying individual users. ESP DATA SOLUTIONS, INC. also may share this aggregated data with business partners or other third parties.

Who is collecting information?

When you are on a ESP DATA SOLUTIONS, INC. site and are asked for personal information, you are sharing that information with ESP DATA SOLUTIONS, INC. and its affiliates and service providers. If personal data is to be collected and/or maintained by any company other than ESP DATA SOLUTIONS, INC. or its affiliates, we will attempt to notify you on the Web site or in an updated version of this Privacy Policy. If you do not want your data to be shared, you can choose not to allow the transfer by not using that particular service.

Please be aware that other Web sites to which we link may collect personally identifiable information about you when you visit those sites. The information practices of other Web sites linked to our Web sites are not covered by this Privacy Policy.

With whom does ESP DATA SOLUTIONS, INC. share my information?

We will not disclose any of your personally identifiable information except when we have your permission or under special circumstances, such as when we believe in good faith that the law requires it or under the circumstances described below. The following describes some of the ways that your information may be disclosed.

Data in the Aggregate: We may disclose “blinded” aggregated data and user statistics to prospective partners and other third parties, and for other lawful purposes. Blinded data is data which does not identify an individual person.

Other: We also may disclose account information in special cases when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating ESP DATA SOLUTIONS, INC.' Terms and Conditions of Use, or may otherwise be causing injury to or interference with (either intentionally or unintentionally) ESP DATA SOLUTIONS, INC.' rights or property, other ESP DATA SOLUTIONS, INC. Web site users or customers, or anyone else that could be harmed by such activities. We may disclose or access account information when we believe in good faith that the law requires it and for administrative and other purposes that we deem necessary to maintain, service and improve our products and services.

We occasionally hire other companies to provide limited services on our behalf, including packaging and mailing, answering customer questions about products or services, sending postal mail, providing investor information and processing data. We will only provide those companies the information they need to deliver the service, and they are prohibited from using that information for any other purpose.

As we continue to develop our business, we may buy or sell businesses or assets. In such transactions, confidential customer information generally is one of the transferred business assets. In the event of a transaction involving the sale of some or all of ESP DATA SOLUTIONS, INC.’ businesses, customer and site visitor information may be one of the transferred assets.

How can I control my personal information?

ESP DATA SOLUTIONS, INC. offers its customers choices for the collection, use and sharing of personal information. You may contact us at support@espdata.com if you wish to view, edit or delete your personal information from our database, and we will use commercially reasonable efforts to accommodate your request.

How does ESP DATA SOLUTIONS, INC. protect financial-related information?

Keeping your personal financial information private is vitally important to us. As a matter of policy and long time business practice, ESP DATA SOLUTIONS, INC. does not sell information provided by its customers. Any user statistics that we may provide to prospective partners regarding financial matters are provided in the aggregate only and do not include any personally identifiable information about any individual user. We will transfer your credit card number, bank account number or other personal information to the appropriate credit card company or bank in order to process any online payments.

What security precautions are in place to protect the loss, misuse or alteration of my information?

Your ESP DATA SOLUTIONS, INC. Account Information and ESP DATA SOLUTIONS, INC. Profile are password-protected so you have access to this personal information. We use encryption technology for credit card numbers, bank account numbers, passwords and registration information. Remember to sign out of your ESP DATA SOLUTIONS, INC. account and close your browser window when you have finished your work. This is to ensure that others cannot access your account by using your computer when you are away from it. Because of the global nature of the Internet, when you give us information, that information may be sent electronically to servers outside of the country where you originally entered the information. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. Except as discussed above or otherwise designated, this site does not use security encryption measures. Therefore, information that you disclose by use of this site (as with any site that is non-secure), by posting a message or using e mail, potentially could be collected and used by others. This may result in unsolicited messages from third parties or use of such information by third parties for their own purposes, legal or illegal. As a result, while we strive to protect your personal information, ESP DATA SOLUTIONS, INC. cannot ensure or warrant the security of any information you transmit to us or from our services, and you do so at your own risk. Once we receive your transmission, we use commercially reasonable efforts to ensure its security on our systems.

Choice/Opt-out

Our website provides users the opportunity to opt-out of receiving communications from us at the point where we request information about you. Where indicated just click on "I choose not to receive future communications" when completing a survey or other form.

To ensure that you will not receive recurring marketing information from us unless you choose to, we will provide you with simple instructions on each marketing email from ESP DATA SOLUTIONS, INC. for you to let us know that you have chosen to stop receiving such emails from us.

What else should I know about my privacy?

Please keep in mind that whenever you voluntarily disclose information online, that information is accessible to other customers and users. Ultimately, you are solely responsible for maintaining the secrecy of your passwords and/or any account information. Please be careful and responsible whenever you are online.

When you or we end your customer relationship with us, we will treat the information we have about you as if you were still our customer.