LOYAL3® Privacy Policy

January 11, 2012

LOYAL3 offers and supports web & social media sites ("sites") that allow companies (each a "company") to connect directly to customers to enroll in a Customer Stock Ownership Plan™ or CSOP™ and other CSOP-related products. We are committed to protecting the personal and financial information of our customers, including persons inquiring about potential services (“customers" or “you"). In the course of providing financial products and services to you, we need to collect (from you and other sources) and maintain certain nonpublic personal information. This Privacy Policy informs you what nonpublic personal information we collect, what we do with it, and how we protect it.

Your Privacy

We do not disclose nonpublic personal information about our customers to non-affiliated third parties, except as specifically described below. Please read the following information about how we handle your information.

Who is LOYAL3?

This Privacy Policy covers the following affiliated companies in the LOYAL3 family of companies: LOYAL3 Labs, Inc. and a broker-dealer. These entities are collectively referred to as “LOYAL3," "we," "us," and "our" throughout this statement.

Website

We collect your IP address, browser type, and operating system on each visit to all pages on these sites. This information is used only for internal statistical tracking purposes and is never shared with other entities outside LOYAL3, including affiliates as described below, unless required by law or as otherwise disclosed within this policy. Your name and other information are not collected unless you specifically provide it.

Email and Other Electronic Delivery

LOYAL3 does not send unsolicited bulk e-mail messages, or "Spam." We do communicate using electronic channels, such as email, with our consumers but only for important transactional or other information related to individual LOYAL3 accounts. Companies may use our electronic platform to send investors in their CSOP investor-related information and consumer information.

What types of nonpublic personal information does LOYAL3 collect?

By enrolling in a CSOP, you provide personal information, including your name, address, email address, date of birth, and Social Security number, as well as bank account and/or credit/debit card information. We will also obtain information regarding your transactions and activities in a CSOP. In addition to information provided by you, we may also obtain personal information from the companies that make stock offers to you using our technology and services (the “Service"), as well as from consumer reporting agencies and third-party information providers.

How do we share your information?

We share your information to provide the Service related to your participation in a CSOP, to fulfill your requests for certain offers, rewards, products and services, and as otherwise explained in this Privacy Policy or required or permitted by law. We will never sell your personally identifiable information; nor will we share it with any party for marketing purposes other than with a company in whose CSOP you have enrolled. We also will not share the following information with anyone, including the company in whose CSOP you have enrolled: password, occupation, employer, employer’s address, bank/checking information, Social Security number, annual income, bank account cash, and total net worth.

How do you restrict promotional messages?

You may affirmatively choose to receive marketing messages from the broker-dealer. (You will never receive marketing messages from LOYAL3 Labs, Inc.) If you do not choose to do so, you will still receive messages that are required to provide services you requested, purely operational communications -- or as required or permitted by law. LOYAL3 will not provide access to any of your personal information to any other companies offering CSOPs other than those in which you are a shareholder.

Social Media

LOYAL3 provides a social media platform to easily facilitate your sharing of your actions or experience through your chosen social media provider, such as Facebook or Twitter. LOYAL3 is dedicated to providing you choice and control in what you share through these platforms. You are responsible for understanding the features and your settings on Facebook, Twitter, and other social media providers, which may necessitate your investigation into the privacy policies and practices of those providers, and we strongly encourage you to undertake such investigation before using those features on LOYAL3.

How do we track activity and site usage?

When you visit the sites, we may collect technical and navigational information, such as computer browser type, Internet protocol address, pages visited, and average length of time spent on our the sites.

This is accomplished through the use of "cookies." We use cookies to:

• Allow you to avoid having to re-enter information and to aid in navigation between pages of our site.
• Help us recognize you as a unique user when you return to our website.
• Remember what kinds of information you have shown interest in while on our website.
• Collect and compile anonymous, aggregated information for statistical and evaluation purposes to help us understand how users use the sites and help us improve its structure.

No personal information is stored in our cookies. You may be able to disable cookies by changing your browser settings, but our website’s functionality and your experience may be diminished as a result. For more information about cookies and how to disable them please visit http://www.allaboutcookies.org/.

Web beacons are images embedded in a Web page or email for the purpose of measuring and analyzing site usage and activity. LOYAL3, or third-party service providers acting on our behalf, may use web beacons and/or cookies to help us to analyze site usage and improve the Service. We do not share any personally identifiable information about you with these third-party service providers, and they do not collect such information on our behalf.

We may also record the time of actions taken on the sites for regulatory or other control purposes.

Security Practices

We are committed to your security. At LOYAL3, we value our relationship with our customers and place the highest importance on respecting and protecting your private data. We want you to feel comfortable and confident when using our products and services and with entrusting your personal and financial information with us. With these principles as our guide, we continually enhance our systems and processes as online services evolve. Because no single solution can ensure online security, we employ a layered security approach with industry-leading solutions.

Your Communications with us are secure.

Communications between your computer and LOYAL3 are encrypted using Secure Sockets Layer (SSL) technology. SSL enables client and server applications to communicate in a way that is designed to prevent eavesdropping, tampering, and message forgery.

To support this technology, you need a recent version of an SSL-capable, 128-bit browser, such as Internet Explorer 7 or 8, Firefox or Safari. These browsers will activate SSL automatically whenever you log onto the LOYAL3 website. To ensure that SSL encryption is protecting your private communications, look for a small picture of a padlock on the browser frame. Another indicator is the URL prefix “https.”

Ways you can help keep your information secure.

When you log onto a site, you are authenticated by your user name and password. You will be asked for other identifying information for any contact with LOYAL3 when you are not logged onto the site, but you will never be asked for your password.

We strongly recommend that you change your password frequently. Your password must be at least 6 characters in length. You are responsible for maintaining the security of your password and must not provide it to any third party. If you believe that it has been stolen or made known to others, you must promptly update your password on our site. We are not responsible if someone else accesses your CSOP account through information they have obtained from you or through your violation of this Policy and your account agreement with the broker-dealer.

How can customers access and update their nonpublic personal information that we collect?

You can access and update certain nonpublic personal information that we collect from you by logging into your LOYAL3 account.

Changes to the Privacy Policy.

LOYAL3 reserves the right to modify this policy at any time and will post the revised policy on our website and where you log in to your account.

Please contact us with any questions.
Questions regarding this Privacy Policy should be directed to LOYAL3 by email to support@LOYAL3.com.

State Laws: If your address is in Vermont, we will automatically limit information sharing.

Link to California Notice for California residents.

© 2011 LOYAL3 Holdings, Inc.