TELECOM ASSET MANAGEMENT, LLC

PRIVACY POLICY

Please note that by using this Site, you are accepting the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, you may not use the Site.

What is the purpose of this Privacy Policy?

Telecom Asset Management, LLC (“TAM”) has created this privacy policy in order to demonstrate our commitment to privacy. We recognize that when you provide us with information about yourself that you trust us to act in a responsible manner with that information, and we’re committed to make sure we earn that trust.

This privacy policy following discloses our information gathering and dissemination practices for the TAM website (the “Site”). Please read this privacy policy for details on TAM’s privacy practices relating to this Site.

What information do we collect from users and how is it used?

TAM is the sole owner of the information collected on this Site. We will not sell, share, or rent this information to others in ways different from what is disclosed in this policy.

TAM collects information from our users at several different points on our Site.

Registration

Before you can post content on the Site, access certain content on the site or certain features of the site, or participate in discussion groups on the Site, we may ask that you register with TAM and provide to us your Username, E-mail address, Password, First and Last Name and other contact information and personal details. We request this information in order to verify compliance with the Terms of Service and federal, state and local laws and for identification purposes.

Correspondence

If you correspond with us via e-mail, we may gather the information in a file specific to you.

URL and IP address

Like many other websites, TAM collects information about users’ utilization and navigation of our Site. This information helps us to design our Site to better suit our users’ needs. For example, our Site will track the URL that you visited before you came to our Site, the URL to which you next go and your Internet Protocol (IP) address. We use your IP address to help diagnose problems with our server and to administer our Site. Your IP address also is used to help identify you and to gather broad demographic information.

Cookies

Cookies are pieces of information that a website transfers to a user’s hard drive for record-keeping purposes while visiting a Site. Like most major websites, TAM uses cookies on certain pages of our Site. Cookies make using the Internet easier by, among other things, saving your username and preferences for you. For example, a cookie lets the Site remember that you’ve registered, which allows us to speed up your future activities at our Site, and which allows you to enter your ID less frequently while visiting our Site. We may also use cookies to deliver content specific to your interests. Our cookies do not contain any content specific information. Our cookies do not contain any personally identifying information although cookies may enable us to relate your use of our Site to personally identifying information that you previously submitted. For example, it enables us to enhance personalization on the Site, such as calling you by name when you return to our Site. If your browser is set to reject cookies, or if your browser notifies you that you are about to receive a cookie and you reject it, t hen your use of the Site may not be as efficient or as enjoyable as it would be if the cookie were enabled .

We only collect personally identifiable information (“Personal Information”) that you provide to us. While we may gather market data from other resources, the scope of our knowledge about Personal Information based upon your use of our Site is entirely up to you. The information you give us allows us to improve our marketing and promotional efforts, to statistically analyze Site usage, to improve our content and product offerings and to customize our Site’s content, layout and services. However, for these purposes, we only use your information on an aggregated basis without the use of any information that personally identifies you.

To whom does TAM disclose Personal Information?

As a general rule, TAM will not share, rent, sell or otherwise disclose any of your Personal Information except when we have your permission. However, TAM may disclose Personal Information in the following ways:

• We may disclose your Personal Information to our third party contractors who perform services for TAM in order to provide services through the Site or to complete or confirm a transaction you conduct through the Site. These contractors are permitted to use the personal data only for the purposes of such services or transaction.
• We may gather aggregated data about you and disclose the results of such aggregated information for marketing or promotional purposes (for instance, 40% of our users are living in the US). In these situations, we do not disclose to these entities any information that could be used to personally identify you. Certain information, such as your password, is not disclosed to marketing advertisers in aggregate at all.
• TAM may disclose the information obtained from you through this Site as part of a merger, acquisition or other sale or transfer of its assets or business.
• Moreover, we may be legally obligated to disclose information to the government or to third parties under certain circumstances, such as in connection with illegal activity on our Site or to respond to subpoena, court order or other legal process. TAM reserves the right to release Personal Information to law enforcement or other government officials, as TAM, in our sole and absolute discretion, deems necessary or appropriate.

Please be aware that despite our best intentions and the guidelines outlined in this privacy policy, no data transmission over the Internet or encryption method can be guaranteed to be 100% secure.

What security measures does the Site employ?

To help protect the privacy of data you transmit through use of this Site, where Personal Information is requested by the Site, TAM uses technology designed to encrypt Personal Information you input before it is sent to us. In addition, TAM takes steps to protect the user data we collect against unauthorized access. However, you should keep in mind that this Site and our services are run on software, hardware and networks, any component of which may, from time to time, require maintenance or experience problems or breaches of security beyond our control.

How can you correct or update your Personal Information?

You may correct or update Personal Information in the Site by managing your account profile. We will use reasonable efforts to update our records. For our records, we may retain original and updated information for reasons such as technical constraints, dispute resolution, troubleshooting and agreement enforcement.

What about software downloaded from the Site?

TAM may make certain software available for download from the Site. Use of the software will be governed by a separate license agreement.

What are the policies of linked Sites and other third parties?

This privacy policy only addresses the use and disclosure of information we collect from you. You should be aware that when you are on the Site, you can be directed to other Sites that are beyond our control and TAM is not responsible for the privacy practices of third parties or the content of linked Sites. We encourage you to read the posted privacy policy whenever interacting with any website.

What about children’s privacy?

The Site is not intended for children. TAM does not intend to collect Personal Information from anyone we know to be under thirteen (13) years of age.

How will I know about changes in the Privacy Policy?

TAM reserves the right to update this privacy policy from time to time. Please visit this page periodically so that you will be apprised of any changes. However, we will only use Personal Information in accordance with the Privacy Policy that was in effect at the time the information was collected. If at any point we should decide to use differently Personal Information that had previously been collected, we will notify users through a posting on the Site or by email.

How to contact us?

If you have any questions about this privacy policy or the practices of this Site, you may request more information by contacting us at our corporate headquarters. Please see the www.telecomassets.com/contact.asp for details on how to contact us.