GLOBAL TOUCH ONLINE POLICY STATEMENT
Effective November 1, 2008

At Global Touch, Inc. (“Global Touch”), we value and protect your privacy. We thank you for the trust that you place in us and we want you to know that the information you share with us will be treated with care.

The objective of our Online Privacy Statement is to disclose and explain what information we collect, use, and share and to explain the privacy choices that you can make. We encourage you to read our Online Privacy Statement as well as those of all websites that you visit.

WHAT INFORMATION WE COLLECT AND HOW WE USE IT

Global Touch does not sell or share personal information with marketers outside of Global Touch for purposes of offering their own products or services.

Collecting Information About You

When you visit our website, we collect information in order to service your accounts, save you time and better respond to your needs. We use "cookie" technology to collect site statistical information and improve your customer experience. Cookies set by Global Touch do not capture any personally identifiable information, such as your individual e-mail address.

We automatically collect some statistical data as you browse this website. For example, we automatically collect your "IP Address" used to connect your computer to the Internet, browser type and version, operating system and platform, average time spent on our site, pages viewed, information searched for, access times, "clickstream data," and other relevant information about your online experience.

You may browse our Website anonymously by choosing not to provide us with any "personally identifiable information (PII)," such as your name or e-mail address, or choosing not to register during your visits to our sites. When you browse this way, we will not link your online activity with the accounts you may have with us.

Global Touch may use "Web beacons" to present offers on globaltouch.com, other sites on which Global Touch advertises, or in our e-mails. This enables us to enhance e-mail offers and track website usage. We sometimes use "vendors" and "business partners" to manage web beacons and the data they collect; however, Web beacons do not capture your individual e-mail address or any other personal information that you enter on the Global Touch site.

Web beacons are sometimes used on globaltouch.com website pages where transactions take place. In addition, e-mail offers that we send may contain web beacons to help us record response rates and to assist us in measuring the offer's effectiveness. No personally identifiable information such as name, address, telephone number, credit card number, or e-mail address is ever collected or passed via the use of web beacons.

Using Your Personal Information

Global Touch does not sell or share customer information with entities outside of Global Touch who may want to market to you their own products and services. You don't need to take any action for this benefit. Global Touch uses your information to process or complete transactions, respond to your requests, deliver the products and services in which you enroll or for which you apply, and notify you of promotions, updates, or special offers that we think may interest you. We also use your information to provide you with a more effective customer experience while on our website. In order to do this, we may process your information or combine it with other information that is publicly available. This enables us to customize your Global Touch experience and provide you with more relevant offers. Global Touch may also use the information that we collect from you online to market to you through alternative channels.

Global Touch may share your information within our family of companies; and, to provide services to you, we may share information with carefully selected "vendors" and "business partners" with whom we work. This includes companies that manage accounts; offer affinity, frequent-user, and reward programs; and, companies that perform marketing services and other business operations for us. All companies that act on our behalf are contractually obligated to keep all information confidential and to use the customer information only to provide the services we ask them to perform for you and us.

If you apply to purchase a products and service online, we may share information we collect about you with credit bureaus and similar organizations if we have your express consent or when required or permitted by law. To the extent permitted by law, we may disclose personally identifiable information to government authorities or third parties pursuant to a legal request, subpoena, or other legal process. We may also use or disclose your information as permitted by law to perform charge verifications, report or collect debts owed, fight fraud, or protect the legal rights of Global Touch, our customers, our websites, or its users.

Using Your E-mail Address

We may use your e-mail address for the following types of e-mail messages:

• Occasional Updates and Valuable Offers. We may send you e-mail updates about our products and services as well as valuable offers from our business partners that we send you on their behalf. For examples of these offers, please visit Global Touch Selects.
• Regularly Scheduled E-mail Newsletters related to Global Touch products or services in which you are enrolled.

You can also elect to receive other types of e-mail messages from us, including newsletters, alerts, or notifications.

Please note that even if you opt-out of marketing e-mails, we will continue to send you e-mail service notifications that are related to your account(s). These include e-mails that provide account information, answer your questions about a product or service, facilitate or confirm a sale, or fulfill a legal or regulatory disclosure requirement.

Mobile Offers

Global Touch does not sell or share mobile phone numbers with third parties and will only use the information for the specific communication into which you have opted-in.

Resources That Link to Our Site

Global Touch may hire other companies to place our banner ads on other websites and to perform tracking and reporting activities on this site and other websites. This enables us to learn which advertisements and websites bring users to our websites. A unique "cookie," if it exists on your computer, is placed there either by us, an ad management partner, or by another advertiser who works with our ad management partners. However, these companies do not collect personally identifiable information in this manner and we do not give any personally identifiable information to them.

Third-party ad partners have their own privacy policies. It is your responsibility to review and ensure compliance with third-party policies.

COMMUNICATION CHOICES

Global Touch respects the choices that you make regarding your privacy. You may request that Global Touch no longer send you marketing e-mails, which may include information about new products, services or blog content.

To opt-out of Global Touch emails, please email globaltouch@globaltouch.com with “Opt-Out” in the subject line.

SECURING YOUR INFORMATION

Global Touch takes reasonable precautions to keep all information obtained from our online visitors secure against unauthorized access and use and we periodically review our security measures.

Do not use e-mail to send us any personally identifiable information, since it would be unencrypted and can be read by anyone who receives or intercepts it.