LEGAL

PRIVACY POLICY

Last Update: 2008 Jan 22

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING THIS WEBSITE OR SUBMITTING ANY PERSONAL INFORMATION. BY USING THIS WEBSITE YOU ARE AGREEING TO THESE PRIVACY TERMS. IF YOU DO NOT AGREE, DO NOT USE THIS WEBSITE.

Commitment to Privacy

This Website, www.globproj.com, (the "Website") is owned and operated by Global Project Management, Inc. ("GPM", "us", "we" or "our"), a New York corporation. GPM respects the privacy of every individual who uses this Website and therefore, we only wish to process and use the data obtained through the Website for our own purposes. The privacy policy located on this Website ("Privacy Policy") outlines the information we will collect and how we will use that information.

Changes to Privacy Statement

Because of changes in Internet technology and practices, this Privacy Policy, and our security and other policies may change from time to time. Please consult this portion of the Website for important changes to the Privacy Policy as they occur. Unless otherwise provided in an agreement between you and GPM, by using the Website after GPM posts any changes to this Privacy Policy, you agree to accept those changes, whether or not you have reviewed them, and such acceptance shall be deemed legally conclusive. If at any time you choose not to accept the terms of this Privacy Policy, you should not use the Website and enter information about yourself or your business.

Other Agreements with GPM

For users who have entered into agreements with GPM for other services off-line, those agreements shall govern the relationship between the user and GPM for that service. To the extent those provisions differ from this Privacy Policy, the terms of that agreement shall govern and control that particular service.

Personally Identifiable Information

When you access and/or use this Website, we or our service providers may obtain data concerning that access and use. If you register to use and log in and use any areas or services provided on or through the Website you may be asked to provide personally identifiable information about yourself. This data may include, but is not limited to your name address and other demographic, professional data, telephone number, credit or financial information, government issued identification number or email address. We will not collect any personally identifiable information about you unless you provide it to us voluntarily. If you opt not to provide us with personally identifiable information, no material consequences will result, although there may be services that may be unavailable to you.

Use of Personally Identifiable Information

GPM may store and process your personally identifiable information in order to effect your purchase of our services, to better understand your needs and to learn how to improve our services and products. We may also use your personally identifiable information to contact you (for example, we may send you marketing or promotional materials or other information, we may respond to your comments or requests for information, we may ask you for feedback on products and services or we may contact you if needed in the course of processing your requests). GPM may also use your personally identifiable information in accordance with any agreements that you may have entered into with us.

If you do not wish us to send you any information concerning new services or other matters offered by us please contact us by email at privacy@globproj.com to notify us of your wishes.

European customers

GPM is in compliance with the Data Protection Act (the "Act") of 1998.

GPM has legal obligations under the Act to collect any data that you provide to us fairly. Each time you provide us with personal data, GPM will let you know how we intend to use it and whether we will pass the information on to a third party. GPM will hold your personal information securely and will only maintain a record of your information in circumstances where you have provided us with your consent.

Credit Card and Financial Information

When you submit your credit card and/or financial information (the "Information") to purchase historical data, software components, or to make any other purchases on this Website, we will only use your credit card and/or financial information for the purpose in which the information was submitted. Additionally, we will only keep the Information for as long as necessary to process the requested transaction. After the transaction is completed, the Information will be deleted, unless you request that we store it.

Disclosure

To enable us to more efficiently provide the products and services you have requested from us, GPM may share your personal information with selected third parties who are acting on our behalf as our agents, suppliers, or providers. Such third party service providers are provided only with such information as is necessary under the circumstances. Information provided to third parties is used only for the purposes stipulated and those third parties are subject to confidentiality obligations. We may also enhance or merge personally identifiable information with data obtained from third parties for any of the foregoing purposes. Nothing in the Privacy Policy shall be deemed to prohibit us from disclosing your identity or information if we are required by law to do so.

Contacting Us Regarding Your Personally Identifiable Information

If you have submitted personally identifiable information through an GPM Website, or if someone else has submitted your personally identifiable information through the foregoing, and you would like to review, request changes or have that information deleted from our marketing databases, please contact GPM via e-mail at privacy@globproj.com, or send a letter to our Privacy Compliance Officer at  P.O. Box 351, Church Street Station, New York, NY, 10008. We will then use reasonable efforts to change or remove your personally identifiable information from our files, unless we are entitled or required to retain it pursuant to other agreements or by law. GPM will use reasonable efforts to supply you with this information and correct any factual inaccuracies in this information.

Non-Personally Identifiable Information Collected Automatically

In some cases, GPM may collect information about you that is not personally identifiable. Examples of this type of information include but are not limited to the frequency of your use of this Website and the route by which you choose to access it and your use of any hyperlinks available on this Website. We and our service providers, agents or advisors may process and use this data for purposes including but not limited to; planning Website development, assessing patterns of use, planning and assessing marketing initiatives by GPM, to include you in e-mail or mailing lists so that We may send you information or updates and or offer you services.

Cookies

"Cookies" are small text files that are either used for the duration of a session ('session cookies'), or saved on a user's hard drive in order to identify that user the next time he/she logs on to the Website ('persistent cookies'). GPM may use 'session cookies' to identify registered users logging-in to GPM web services. These cookies are deleted from the component's server soon after the session ends and are not collected or saved. GPM may also use 'persistent cookies' when a registered user clicks on the "save password" check box on login. Most Web browsers automatically accept cookies, but you can usually change your browser to prevent that, although if you do disable cookies from your browser you may not be able to access certain sections of the Website.

Security

GPM provides electronic services to the global commodities trading marketplace. The engineering and operations of these services involve the creation, transfer and storage of sensitive client data. We recognize the importance of such data and therefore we dedicate significant resources to information security. Procedures and technical security mechanisms in place to maintain the confidentiality, integrity, and availability of data include:

Encryption

128-bit or stronger encryption is used to authenticate and encrypt all customer communications involved in GPM systems. Encryption prevents potential malicious third parties from intercepting sensitive data and credentials in transmission.

System Security

GPM systems are hardened and secured via standardized procedures. Monitoring, auditing, and assessment tools and procedures are used to protect systems from new attacks.

Intrusion Detection

Multi-layer intrusion detections systems are used to notify GPM personnel of any attempted network intrusions. These systems monitor the network at multiple points and are regularly updated to be aware of new threats.

Access Control

Application-layer access controls impose strict restrictions on the data available to individual users. Data storage is physically and logically segmented from application servers, and queries can only be formed and executed after access control databases have been queried and credentials fully verified. These processes ensure clients can only retrieve data related to their account.

Although GPM will use reasonable efforts to safeguard the confidentiality of your personally identifiable information (including credit card information), transmissions made by means of the Internet cannot be made absolutely secure. GPM will have no liability for disclosure of information due to errors in transmission or unauthorized acts of third parties.

Your Security Obligations

You have an obligation to keep your User ID, Password and personally identifiable information secure. As part of maintaining this obligation we recommend that you do the following:

Keep your User ID and Password confidential;

Utilize a unique Password and change it frequently;

Make sure others are not watching you enter your User ID and/or Password on your keyboard when using protected areas of the Website; and

Do not leave your computer unattended while logged onto protected areas of the Website. After you finished accessing your information, exit the protected area.

Children

This Website is not intended for use by persons under the age of 18. If you are under 18, do not use this Website. If parents believe their minor children have accessed this Website and provided their personally identifiable information, please contact us using the information provided in the "Contact Use Regarding Your Personal Identification Information" section of this Privacy Policy.

Other Sites

The Website may contain links to other websites. GPM is not responsible for the privacy practices employed by other websites. Users are encouraged to review the privacy policy of any website linked to from the Website.

Transfer of Business Assets

As we continue to develop our business, we might acquire or buy other businesses or assets. In such transactions, customer information generally is one of the transferred business assets. Also, in the event that GPM or substantially all of its assets are acquired, both personally identifiable and non-personally identifiable user and customer information will be one of the transferred assets.

Site Disclaimer

GPM only wishes to process and use the data obtained through this Website for its own purposes as described below and does not sell or re sell that data. When you access and or use this Website, GPM or its service providers may obtain data concerning that access and use. If you register to use and log in and use any areas or services provided on or through this Website you will be asked to provide data about yourself. This data may include, but not be limited to, your name, address and other demographic and professional data. The GPM and or its service providers may also obtain other data including but not limited to the frequency of your use of this Website and the route by which you choose to access it and your use of any hyperlinks available on this Website. GPM and its service providers, agents or advisors may process and use this data for purposes including but not limited to: planning Website development; assessing patterns of use; planning and assessing marketing initiatives by GPM; to include you in e-mail or mailing lists so that we may send you information or updates and or offer you services. If you do not wish GPM to send you any information concerning new services or other matters offered by GPM please ensure that you answer the data question appropriately when you register.

LIMITATION OF LIABILITY

In no event will GPM be liable for any damages, including without limitation direct or indirect, special, incidental or consequential damages, losses or expenses arising in connection with any failure of performance, error, omission, interruption, defect, delay in operation or transmission, computer virus or line or system failure, even if GPM or their agents or advisors are advised of the possibility of such damages, losses or expenses. Hyperlinks to other internet resources are used by you at your own risk; GPM is not in a position to and does not seek to monitor or verify the content, accuracy, opinions expressed and other links provided by these resources in any way and is not liable for any aspect of such resources or any consequence arising from your use of those resources.

COPYRIGHT

Materials copyrighted, trade marked, or in any way owned by GPM or owned by any individual or entity are presented here for personal use or for reference only. Documents, content or images contained in this Web site may not be copied, reproduced, distributed or resold in any form without prior written permission from GPM.

REGISTRATION

By registering for any areas or services provided through this Website you agree to pay any fees that are due in respect of any such services that you use or subscribe for until you de register or GPM suspends or withdraws such service. Where any service for which you register on or through this Website is provided by or with a service provider, agent or partner of GPM you agree that you will observe any additional terms and conditions associated with the part of the service provided by them.

COOKIES

"Cookies" are small text files that are either used for the duration of a session ('session cookies'), or saved on a user's hard drive in order to identify that user the next time he/she logs on to the web site ('persistent cookies'). GPM may use 'session cookies' to identify registered users logging-in to GPM web services. These cookies are deleted from the component's server soon after the session ends and are not collected or saved. GPM may also use 'persistent cookies' when a registered user clicks on the "save password" check box on login. Most Web browsers automatically accept cookies, but you can usually change your browser to prevent that, although if you do disable cookies from your browser you may not be able to access certain sections of the site.

NO SOLICITATION IN RELATION TO SECURITIES OR COMMODITIES

Nothing on this site constitutes a solicitation for the purchase or sale of securities or commodities. Quotes and other data are provided for information only and are not intended for trading.

INDEMNITY

You agree to indemnify GPM and to hold it, its officers and or agents and or employees in respect of any and all claims, demands, costs, damages and or penalties arising out of any failure by you or any agent acting on your behalf to fully observe these terms and conditions or by reason of any use by you or such agent of any information or images provided on this Website.

CHOICE OF LAW

This Website and these terms and conditions are governed by English law and are subject to the jurisdiction of the Supreme Court of England and Wales, save that GPM reserves to itself the right to pursue the enforcement of these terms and conditions or seek protective or other relief in any court of competent jurisdiction.

ACCEPTANCE

By accessing all or any part of this Website you fully accept and agree to comply with all of the terms and conditions set out above. Please read these terms and conditions carefully.

NO WARRANTY

The information and materials contained in this site-including text, graphics, links or other items-are provided "as is" and "as available." Global Project Management, Inc., and its subsidiaries, does not warrant the accuracy, adequacy or completeness of this information and materials and expressly disclaims liability for errors or omissions in this information and materials. No warranty of any kind, implied, express or statutory, including but not limited to the warranties of non-infringement of third-party rights, title, merchantability, fitness for a particular purpose and freedom from computer virus, is given in conjunction with the information and materials. The information on this site is liable to change at short notice. You should not rely on any information contained in this site without first checking with us that it is correct and up to date.

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