I.         Collection of Information.

A.        Survey Information. Koradel Capital, LLC d.b.a. Koradel Capital Management (KCM) collects information from individuals when such individuals voluntarily complete product surveys, order forms, surveys, or otherwise send an email through KCM's referral technology or submit information via an online forms which may or may not be accompanied by a pre-checked or non pre-checked checkbox indicating that such individuals consent to receiving marketing communications from KCM or registration pages either online or offline, or by means of online or offline surveys, order forms, or registration pages operated by third parties (each, a Survey). (As used herein, online means using the Internet, including the websites and related technologies, and offline means by methods other than online, including in person, via postal mail, telephones, and other similar means.) In the Surveys, KCM or a third party may ask individuals to provide various information to KCM, which may include their name, email address, street address, zip code, telephone numbers, birth date, gender, salary range, education level, marital status, occupation, employment information, personal and online interests, and such other information as may be requested from time to time (collectively, Survey Information). Completing the Surveys is completely voluntary, and individuals are under no obligation to provide Survey Information to KCM or any third party, but individuals may receive incentives from KCM or a third party in exchange for providing Survey Information to KCM.

 B.        Other Information. Other occasions when KCM obtains information from individuals include when such individuals (i) seek to redeem an incentive offered by KCM or a third party, (ii) request assistance through KCM's customer service department, and (iii) voluntarily subscribe to a KCM service or newsletter (collectively, Other Information).

II.        Cookies, Web Beacons, and Other Information Collected Using Technology. KCM may use cookie technology to associate certain Internet-related information about individuals with information about such individuals in our database. Additionally, KCM may use other new and evolving sources of information in the future (together, Technology Information).

A.        Cookies. A cookie is a small amount of data stored on the hard drive of the individual's computer that allows KCM to identify the individual with his or her corresponding data that resides in KCM's database. You may read more about cookies at http://www.cookiecentral.com/.

B.        Web Beacons. Web beacons are graphic images, often transparent and no larger than 1 pixel x 1 pixel, that are placed on a Web site or in an e-mail. Web beacons are used to monitor the behavior of the user visiting the Web site or opening the e-mail. When the HTML code for the Web beacon points to a site to retrieve the image, it simultaneously can pass along information such as the IP address of the computer that retrieved the image, the time the Web beacon was viewed and for how long, the type of browser that retrieved the image and previously set cookie values. KCM, or third parties acting on KCM's behalf, may utilize Web beacons on Web pages or in email for any legally permissible purpose.

 C.        General Behavior Tracking. KCM may track online behaviors (Behaviors) through its own technologies, including its desktop software products, in order to increase the effectiveness of the advertisements it delivers. Examples of such Behaviors may include advertisement responses, websites that individuals visit, and products that individuals purchase. Individuals can prevent the tracking of Behaviors by globally unsubscribing from KCM's marketing materials. As described in Section II-A, KCM reserves the right to use such technologies for any purpose permitted by law.

 D.        Information Automatically Collected. For site maintenance, optimization, security and other legally permissible purposes, KCM's servers (or third party servers) may collect certain information about website visitors automatically. Such information may include such visitors' IP address, browser type, date, time and duration of visit and particular pages viewed, and such other information as is permitted by law.

 E.        New Technology. The use of technology on the Internet is rapidly evolving, as is KCM's use of new technology. As previously stated, KCM reserves the right to change this policy at any time without any additional notice to the user. As a result, KCM strongly encourages individuals to revisit this privacy policy from time to time for any updates regarding its use of technology. Use of any of KCM websites constitutes acknowledgement and acceptance of KCM's Privacy Policy and KCM's right to modify such Privacy Policy without additional notice.

 F.         Outside Information. KCM may receive Outside Information about individuals. For purposes hereof, Outside Information shall include: (i) any non-personally identifiable information received about individuals from a third party or from other sources of information outside of KCM including information located in public databases; provided however, that “Outside Information” shall not include any information which allows KCM to directly or indirectly personally identify any end user, and (ii) any information received in connection with any merger, acquisition, reorganization, change in capital structure, sale of all or substantially all of the assets of any KCM division or website databases (Outside Information).

 G.        Individual Information. As used herein, Individual Information means Survey Information, Other Information, Technology Information, and Outside Information, and any other information KCM gathers or receives about individuals.

 H.        No Information Collected from Children. KCM will never knowingly or intentionally collect any personal information about children under the age of 13. If KCM obtains actual knowledge that it has collected personal information about a child under the age of 13, that information will be immediately deleted from its database. Because it does not knowingly or intentionally collect such information, to the best of KCM's knowledge and belief, KCM has no such information to use or to disclose to a third party. KCM has designed this policy in order to comply with the Children's Online Privacy Protection Act.

 I.         Credit Card Information. KCM may in certain cases collect credit card numbers and related information, such as the expiration date of the card (Credit Card Information) when an individual places an order from KCM. When the Credit Card Information is submitted to KCM, such information is encrypted and is protected with SSL encryption software. KCM will use the Credit Card Information for purposes of processing and completing the purchase transaction, and the Credit Card Information will be disclosed to third parties only as necessary to complete the purchase transaction.

II.        Use of Individual Information.

A.        Discretion to Use Information. KCM MAY USE INDIVIDUAL INFORMATION FOR ANY LEGALLY PERMISSIBLE PURPOSE IN KCM'S SOLE DISCRETION. The following paragraphs in Section II describe how KCM currently uses Individual Information, but KCM may change or broaden its use at any time as permitted by law. As noted below, KCM may update this policy from time to time. KCM may use Individual Information to provide promotional offers to individuals by means of email advertising, telephone marketing, direct mail marketing, and online banner advertising, among other uses.

 B.        Email. KCM uses Individual Information to provide promotional offers by email to individuals who have permitted use of their email address for this purpose. KCM may maintain separate email lists for different purposes. If email recipients wish to end their email subscription, they need to follow the instructions at the end of each email message to unsubscribe.

 C.        Targeted Advertising. KCM uses Individual Information to target advertising to individuals. When individuals use the Internet, KCM uses such persons' Individual Information to show advertising for products and services in which those users have expressed an interest, whether directly or indirectly.

 D.        Direct Mail and Telemarketing. KCM may use Individual Information to advertise or provide promotional offers, directly or indirectly, to individuals using direct mail marketing or telemarketing using telephones, as permitted by law.

 E.        Storage of Individual Information. KCM stores Individual Information in a database on KCM computers. KCM computers have security measures (such as firewalls) in place to reasonably protect against the loss, misuse or alteration of the information under KCM's control. Notwithstanding such measures, KCM cannot guarantee that its security measures will prevent KCM computers from being illegally accessed, and the Individual Information on them stolen or altered.

 F.         Rights of Third Party Affiliates. KCM may extend any of its rights under this Agreement to third parties performing services on its behalf.

III.      Dissemination of Individual Information.

A.        Sale to Third Parties. KCM may sell or transfer Individual Information to third parties in connection with any merger, acquisition, reorganization, change in capital structure, sale of all or substantially all of the assets of any KCM division or website, or any activity specified in Section III-B, III-C, or III-D below.

 B.        Order Fulfillment. KCM will transfer Individual Information to third parties as necessary to provide a product or service that an individual orders from such third party while using one of KCM's websites or when responding to offers provided by KCM.

 C.        Legal Process. KCM may disclose Individual Information to respond to subpoenas, search warrants, court orders, or other legal process.

 D.        Summary Data. KCM may sell or transfer non-individualized information, such as summary or aggregated anonymous information about all persons or sub-groups of persons.

IV.       Privacy Practices of Third Parties

A.        Advertiser Cookies and Web Beacons. Advertising agencies, KCM’s internal advertising efforts, and other companies (collectively, Advertisers) who place advertisements on KCM's websites and on the Internet generally may use their own cookies, web beacons, and other technology to collect information about individuals. KCM does not control Advertisers' use of such technology and KCM has no responsibility for the use of such technology to gather information about individuals.

 B.        Links. KCM's websites and email messages may contain hypertext links to the websites of one or more third parties. KCM is not responsible for the privacy practices or the content of such other websites.

 C.        Affiliated Companies. KCM may disclose, transfer and sell Individual Information to an entity which becomes affiliated with KCM through formation, merger or acquisition, in KCM's discretion.

V.        Unsubscribe from E-peddler.com Lists. KCM maintains multiple newsletter and email marketing lists. To unsubscribe from one or more of such lists, click the link included in the footer of any message delivered by KCM and follow the instructions provided.

VI.       More Information. For more information about protecting your privacy, you may wish to visit http://www.privacyalliance.org/ or http://www.privacylaw.net/. If you have questions about this policy, please contact us at info@e-peddler.com.

KCM RESERVES THE RIGHT TO UPDATE THIS POLICY FROM TIME TO TIME, SO YOU SHOULD REVIEW THIS WEB PAGE PERIODICALLY.