Reply! Privacy Policy

Thank you for visiting Reply! Inc.'s ("Reply!") Internet web site ("Site") located at the URL www.reply.com. This Privacy Policy details certain policies implemented throughout Reply! governing Reply!'s use of personally identifiable information about users of our Site and users of services available on this Site (the "Services"). For purposes of this Privacy Policy, the terms "Leads", "Clicks", "Lead Sellers", and "Publishers" are the same as those defined in the Reply! Lead Buyer Agreement, the Reply! Lead Seller Agreement, the Reply! Publisher Agreement, and the Reply! Click Buyer Agreement.

Privacy Policy Updates

Due to the Internet's rapidly evolving nature, Reply! may need to update this Privacy Policy from time to time. If so, Reply! will post its updated Privacy Policy on our Site located at www.reply.com and if you are registered directly with us, we will send you a notice at the email associated with you in our systems, so you are always aware of what personally identifiable information we may collect and how we may use this information. If any modification is unacceptable to you, you shall cease using this Site and the Services. If you do not cease using this Site and the Services, you will be conclusively deemed to have accepted the change regardless of whether you have reviewed the change. Therefore, you should check the Privacy Policy on this Site periodically for updates and changes.

Information Collection and Use

You can generally visit our Site without revealing any personally identifiable information about yourself. However, in certain sections of this Site and when you use our Services, we may invite you to contact us with questions or comments or request information, provide us with feedback, sell and purchase Leads and complete a registration form. Due to the nature of some of these activities, we may collect personally identifiable information, such as your name, contact data such as your address, email address, phone number, fax number, username, password, credit card number or other financial payment account information, and other contact information that you voluntarily transmit with your communication to us. We may use your personally identifiable information to contact you to register you to use our Services, deliver certain Services, provide notices regarding Services you have purchased, provide notices regarding Services you might want to purchase in the future, verify your authority to enter our Site and to use our Services, and improve the content and general administration of the Site and our Services. We may also receive personally identifiable information of third parties through the Lead Sellers or Publishers that have collected the personally identifiable information through an online Lead form for transmittal and sale to buyers on this Site. Each Lead Seller or Publisher has agreed that they have complied with all applicable laws regarding their collection and sale of the Leads or Clicks and that they have the right to sell the Leads or Clicks. However, Reply! cannot ensure that the privacy practices of the Sellers conform with this Privacy Policy. Reply! will use the personally identifiable information of third parties contained in Leads and Clicks to generate aggregate product demand trends as explained in the Aggregate Information Section below.

Children's Privacy

Reply! recognizes the privacy interests of children and we encourage parents and guardians to take an active role in their children's online activities and interests. This Site and the Services are not intended for children under the age of 13. Reply! does not target its Services or this Site to children under 13. Reply! does not knowingly collect personally identifiable information from children under the age of 13.

Cookies

We may use small text files called cookies to, among other things, improve overall Site experience. A cookie is a piece of data stored on the user's hard drive containing information about the user. Cookies generally do not permit us to personally identify you. Data related to these cookies may be shared with third-party service providers.

Aggregate Information

We may track the total number of visitors to our Site, the number of visitors to each page of our Site, browser type, IP addresses and characteristics of Leads sold and bought on the Site through the Services. Reply! and our third-party service providers may maintain and analyze this personally identifiable information to determine aggregate trends and statistics, but such information will be disclosed in aggregate form only and it will not contain personally identifiable information. We may use such aggregate information to analyze market trends, administer the Site, track users' movement, and gather broad demographic and demand-related information for presentation in an aggregate form both internally and externally.

Disclosure

We may provide your personally identifiable information, the data generated by cookies, and the aggregate information described above to parent, subsidiary and affiliate entities within our corporate family and to third-party partner entities not within our corporate family that we may engage to assist us in providing our Services. For example, we may provide your personally identifiable information to a credit card processing company to process your payment or to a Lead validation company to confirm the validity of your contact information. We may provide the aggregate information about trends regarding the Leads or Clicks sold and bought on the Site through the Services to third-party companies but such information will not personally identify you or any of the third parties that are the subject of a Lead or Click. We will disclose your personally identifiable information if we reasonably believe we are required to do so by law, regulation or other government authority. We will not sell your personally identifiable information to any company or organization except we may transfer your personally identifiable information to a successor entity upon a merger, consolidation or other corporate reorganization in which Reply! participates or to a purchaser of all or substantially all of Reply!'s assets to which this Site relates.

Security

We may employ procedural and technological security measures that are reasonably designed to help protect your personally identifiable information from loss, unauthorized access, disclosure, alteration or destruction. Reply! may use encryption, secure socket layer, firewalls, password protection and other security measures to help prevent unauthorized access to your personally identifiable information.

Correction/Updating Personally Identifiable Information

Reply! provides you with the ability to review, correct and delete any of the personally identifiable information that you have provided to us. If you wish to review or correct any information you have provided to us, you may access your account online or contact us at Legal@reply.com. If you have any questions regarding this Privacy Policy please contact us via email at Legal@reply.com.

Last updated: November 17, 2008