VIA3 Corporation is committed to providing you with a superior level of services and products designed to meet the needs of business professionals. We believe this superior level of service includes respecting your privacy and offering a high level of security. We have developed this Privacy Policy and Security Policy to inform you about our privacy and security practices for the entire VIA3.com site. VIA3 Corporation adheres to the Safe Harbor Principles established by European Union and the U.S. Department of Commerce.

This privacy policy covers what information we collect from you when you visit our site, how we use it, and under what circumstances we disclose it. It will also give you more information about how we approach privacy and our overall philosophy in protecting your rights. The beliefs we hold about privacy and security include:

• You should be informed about how your personal information will be used and disclosed
• We do not sell personal information to third parties
• You should have choices to limit the use and disclosure of your personal information
• Information about you should be accurate and maintained in secure systems
• You should be able to communicate with us quickly and easily about any concerns or questions regarding our security or privacy practices
• You should be able to reference our website at anytime for the latest updates and most current versions to our privacy and security policies
• We believe your online meeting should be encrypted at all times including all video, audio and data with leading industry security standards
• We cannot access your client account password in order to protect you and the contents of your online meetings

This Privacy and Security Policy applies only to information you provide to us online while visiting or using our site. It does not apply to information we have obtained or may obtain offline through other traditional means. VIA3 Corporation will update this policy if our practices change. You should refer back to this page for the latest information. Below is more detailed information on our privacy and security policies.

Notice to Persons Accessing the Site from Outside the United States

PERSONALLY IDENTIFIABLE INFORMATION YOU PROVIDE TO US ON OUR SITE IS PROCESSED ON OUR COMPUTER SYSTEMS LOCATED IN THE U.S. CONSEQUENTLY, IF YOU RESIDE OUTSIDE THE U.S., ANY INFORMATION YOU PROVIDE TO US ON OUR WEBSITE WILL BE TRANSFERRED OUT OF YOUR COUNTRY AND INTO THE U.S. IF YOU DO NOT WANT YOUR PERSONALLY IDENTIFIABLE INFORMATION TO LEAVE YOUR COUNTRY, DO NOT PROVIDE THE INFORMATION OVER THE INTERNET. BY PROVIDING PERSONALLY IDENTIFIABLE INFORMATION TO VIA3 CORPORATION, YOU CONSENT TO ITS STORAGE AND USE AS DESCRIBED IN THIS PRIVACY STATEMENT AND SECURITY POLICY.

Privacy Statement

1. 1. The Information We Collect

      When you use our site, we receive and collect certain information. The information that we receive and collect depends on what you do when you visit VIA3 Corporation’s website (VIA3.com).

      Automatically Collected Information.

      Some information is automatically received and sometimes collected from you when you visit the VIA3.com site. This information may include some or all of the following items: the name of the domain and host from which you access the Internet, including the Internet protocol (IP) address of the computer you are using and the IP address of your Internet Service Provider; the type and version of Internet browser software you use and your operating system; the date and time you access our site; the length of your visit; the specific pages, images, video or forms that you access while visiting the site; the Internet address of the website from which you linked directly to our site, and if applicable, the search engine that referred you and any search strings or phrases that you entered into the search engine to find this site; and demographic information concerning the country of origin of your computer and the language(s) used by it. We use this information to monitor the usage of our site, assess its performance, ensure technological compatibility with your computer, and understand the relative importance of the information provided on our site. We also use this data to conduct statistical analyses on visitors’ usage patterns and other aggregated data. Also, when we send e-mails to you, we may be able to identify information about your e-mail account, such as whether you can read graphic-rich HTML e-mails.

      Information Collected via Cookies.

      We use cookies to enhance the website experience of VIA3.com. “Cookies” are small files or records that we place on your computer’s hard drive to collect information about your activities on VIA3.com. The information captured makes it possible for us (i) to speed navigation, and provide you with custom-tailored content; (ii) to authenticate you for use of the My Account section; (iii) to remember information you gave to us so you don’t have to reenter it each time you visit VIA3.com; (iv) to monitor the effectiveness of certain marketing e-mail campaigns; (v) to ensure proper navigation through the product registration process and (vi) to monitor total number of visitors and pages viewed.

      Most people do not know that cookies are being placed on their computers when they visit the VIA3.com or most websites because browsers are typically set to accept cookies. You can choose to have your browser warn you every time a cookie is being sent to you or you can turn off cookie placements. If you refuse cookies, you can still browse VIA3.com. However, you must have cookies enabled on your system to be able to log on to the My Account section or purchase from the VIA3 Corporation website. To enable cookies, you must make a simple adjustment to your browser settings. If you need assistance, please call Client Services at 1 (866) 265-8060. Also, by not using cookies, your overall Internet browsing experience will be adversely affected.

      
      

      Information Collected Using Pixel Tags or Clear GIFs.

      To help us understand the effectiveness of certain marketing efforts, VIA3.com may use “message format” and “message open” sensing technologies. Both technologies require the use of pixel tags or clear GIFs (also called web beacons). The “message format” sensing technology allows us to recognize whether you have enabled your e-mail program to receive HTML e-mails; if so, this information is then associated with your e-mail address so that subsequent messages can be sent to you in HTML format. The “message open” sensing technology allows us to recognize whether you have opened our e-mail message. We can only detect this if you have enabled your e-mail program to receive HTML e-mails. Additionally pixel tags or clear GIFs may be used to monitor the success of specific marketing campaigns and track the successful completion and submission of web forms.

      Information You Actively Submit to VIA3.com.

      For most of the browsing services we provide, we neither require nor collect “Client Information”. Client Information is information that could personally identify you, for example, your name, e-mail address, physical address, phone number, job description and or other information that can be used to identify or contact you. You can browse the VIA3.com site and take as much time as you want to review our services without having to submit such Client Information.

      When you want to engage in any of the following activities on our website, we do need you to actively submit Client Information: (i) download our software, (ii) create a client profile; (iii) create a job applicant profile; (iv) apply online for employment; (v) send us an e-mail request for training; (vi) obtain a demonstration of our software; (vii) request that a VIA3 Corporation sales representative contact you about our software; (viii) update client information, (ix) request to become a VIA3 Corporation partner , (x) access white papers or other documents, or (xi) otherwise communicate with VIA3 Corporation by e-mail through our site.

      You are not restricted to online requests, so you may be able to obtain the information, product or services you are requesting offline without providing any Client Information through the website. See the applicable web page and forms for more details and any available alternatives. In lieu of entering information online, you may call us at 1 (866) 265-8060. If you provide Client Information online, then by doing so, you are expressly authorizing VIA3 Corporation to use and disclose your Client Information for the purpose(s) for which you have provided it.

      Creating a Client Profile.

      When downloading any of our software or otherwise setting up a client account with VIA3 Corporation, we ask you to create a Client Profile containing Client Information. You must also create a username, password and a password hint. When you want to access the My Account section of the website, or change your stored Client Information, we authorize your access by verifying your account through your specific username and password. We do not have access to passwords for ANY of our clients. Passwords must be maintained by each individual client for their complete security and privacy.

      Creating a Job Applicant Profile.

      If you wish to apply for employment with VIA3 Corporation, we ask that you create an Applicant Profile containing certain Client Information. You must also create a username and password in order to access your profile and information pertaining to your application. When you create an Applicant Profile, VIA3 Corporation will send a confirmation e-mail message to the e-mail address that you provide.

      Sensitive Information.

      VIA3 Corporation does not require or request that you provide us with “sensitive information” (e.g., information on racial or ethnic origin, political or religious beliefs, trade union membership, medical or health data, sexual preferences) for any purpose. However, if at any time we become aware that you have provided us with sensitive information, and believe that we have a need to disclose such sensitive information, we would request and receive your express permission (you would be given the right to opt in) before disclosing the sensitive information to a third party or using it for a purpose other than its original purpose or the purpose subsequently authorized by you.

      Personal Information about Children.

      Because the VIA3 Corporation website is targeted for use by business professionals, we do not market to or create special areas for use by children. Accordingly, we do not collect age identifying information nor do we knowingly collect any personal information from children under the age of 13 years. However, we hereby advise all visitors to our site under the age of 13 not to disclose or provide any personally identifiable information on our site. In the event that we discover that a child under the age of 13 has provided personally identifiable information to us, in accordance with the Children’s Online Privacy Protect Act (see the Federal Trade Commission’s website at http://www.ftc.gov/privacy/privacyinitiatives/childrens.html for more information about this Act), we will delete the child’s personally identifiable information from our files to the extent technologically possible.

      Communicating with VIA3 Corporation by e-mail.

      When you send an e-mail to VIA3 Corporation, we will share your correspondence, including any Client Information provided in the e-mail, with employees, representatives, resellers or agents most capable of addressing your particular correspondence. We will retain your communication until we have done our very best to provide you with a complete and satisfactory response and may subsequently retain your communication for our records. We will not use or disclose your e-mail address or other Client Information contained in your correspondence for any purposes other than those for which you have provided them without first obtaining your permission.

      All comments, feedback, suggestions, ideas, and other submissions disclosed, submitted, or offered to VIA3 Corporation in connection with your use of this website (collectively “Comments”) will become and remain the property of VIA3 Corporation. Unless otherwise prohibited by law, you agree that VIA3 Corporation may use or disclose Comments in any manner, without restriction and without compensation to you.

      
      

      How We Use and Share Personal Client Information

      VIA3 Corporation may use the Client Information you provide on this website in the following ways:

      1. To process, complete or otherwise act upon or respond to your request or reason for submitting that information;
      2. To register and/or verify you in connection with a service or feature that you are attempting to access or obtain;
      3. To communicate with you about your request or reason for submitting that information;
      4. To provide additional information to you about VIA3 Corporation and its services that we believe may interest you if you have affirmatively chosen to receive such information;
      5. To study and analyze the use of the information and features available on our website; and
      6. To assist, when necessary, in protecting our rights or property, enforcing the provisions of our Privacy Statement and Terms of Use, preventing harm to you or others, and/or otherwise complying with an applicable law.
      
      

      Our view on disclosing Client Information is simple. We do not sell Client Information to third parties. And unless we first obtain your permission for some other purpose, we share your personally identifiable information with third parties only under the limited circumstances stated below:

      
      
      1. Bonded mail houses and recruitment firms may receive your name, mailing address and e-mail address to effect delivery of direct and/or e-mail marketing campaigns if you have opted to receive such campaigns.
      2. VIA3 Corporation has entered into contractual agreements with resellers and agents within and outside the United States. VIA3 Corporation will disclose Client Information to its resellers and/or agents for the purpose of delivering customer service.
      3. If you apply for a job online, VIA3 Corporation may use your Client Information to conduct a background check to determine your suitability for employment with VIA3 Corporation. In conducting these checks, we may disclose Client Information to credit reporting agencies, private investigators or other companies whose business includes background investigations on potential employees, governmental agents and agencies, your prior employers and any personal references that you may provide to VIA3 Corporation. Any such disclosures will be made solely for the purpose of confirming the information you have provided to VIA3 Corporation in the course of applying for employment and determining your suitability and qualifications for the position for which you have applied.
      4. Client Information is subject to disclosure in response to judicial or other governmental subpoenas, warrants, demands and court orders served on VIA3 Corporation in accordance with their terms.
      5. Client Information is subject to disclosure to protect our rights or property, to enforce the provisions of our Privacy and Security Policy or Terms of Use, to prevent harm to you or others, and/or to otherwise comply with an applicable law.
      6. Client Information may be disclosed and transferred if VIA3 Corporation or its business is sold or offered for sale to another company or person(s), if a petition for relief under the United States Bankruptcy Laws is filed by or against VIA3 Corporation, or if VIA3 Corporation becomes subject to an order of appointment of a trustee or receiver.

      With respect to the personally identifiable information that you provide to VIA3 Corporation on this site, we will not use or disclose your personally identifiable information for a purpose incompatible with the purpose(s) for which it was originally provided or subsequently authorized by you. If we believe that we have a reasonable need to use your personally identifiable information for another purpose, we will first seek your permission before doing so.

      As stated above, we may use the services of third parties to assist us in connection with services you request. As a result, any such third parties will have access to your personally identifiable information but are prohibited from using it for any purpose other than to provide the requested services and are required to adhere to the principles of Notice and Choice described in this Privacy Statement and Security Policy. Please be aware that, while we require any such third parties to adhere to the Notice and Choice principles, VIA3 Corporation cannot and does not guarantee or otherwise ensure their compliance.

1. 1. Instant Messaging and Instant Messaging Archiving

      VIA3 Corporation makes instant messaging (“IM”) available for your use. IM are communications between you and another user, not communications between you and VIA3 Corporation. VIA3 Corporation clients have the option to set up their account to provide for instant messaging archiving (“IMA”). If you or a party with whom you are corresponding via IM has set up its account to enable IMA, then the account holder(s) may automatically and/or selectively archive its IM communications. Archived IM communications are stored on VIA3 Corporation’s servers in an encrypted format. The party archiving the IM communications may then later access all archived IM. VIA3 Corporation does NOT have access to the content of messages in these IM archives, and does not monitor, access, review, or use the IM or archived IM communications of its clients, and does not share IM or archived IM communications of its clients with third parties.

      Although we take reasonable steps, through the use of security software and protocols, to ensure that IM and IMA are safe, it is technologically impossible to guarantee that information transmitted via IM or IMA will never be accessed by unauthorized persons. You are hereby advised that you can opt out of having your IM archived by another party without your consent ONLY by not using IM or by receiving assurance from the party with whom you are corresponding via IM that he or she does not have IMA enabled.

      
      

      ALL USERS OF IM AND/OR IMA, INCLUDING USERS REGULATED BY THE GRAMM LEACH BLILEY ACT, THE SARBANES-OXLEY ACT, THE HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ACT, THE USA PATRIOT ACT, AND/OR THE CHILDREN’S ONLINE PRIVACY PROTECTION ACT, USE IM AND/OR IMA SOLELY IN THEIR OWN DISCRETION AND AT THEIR OWN RISK AND TAKE FULL AND SOLE RESPONSIBILITY FOR COMPLYING WITH ANY APPLICABLE LAWS, INCLUDING BUT NOT LIMITED TO THE ONES JUST MENTIONED. VIA3 CORPOARATION HEREBY EXPRESSLY DISCLAIMS ANY AND ALL RESPONSIBILITY AND LIABILITY WHATSOEVER THAT MAY RESULT DIRECTLY OR INDIRECTLY FROM YOUR USE OF IM AND/OR IMA.

1. 1. Communications From VIA3 Corporation

      As a client, you may receive the following communications from VIA3 Corporation:

      E-mails and instant messages related to transaction maintenance activities.

      These e-mails and instant messages include responses to requests for information, confirmations of your orders or activities while on the site, information updates, problem notifications, as well as information pertaining to software upgrades and patches.

      Communications containing information about VIA3 Corporation and its products and services.

      We send e-mails and other communications to VIA3 Corporation clients regarding products and services. All VIA3 Corporation clients must proactively opt-in for such communications. In addition, if at any time you wish to stop receiving these types of e-mails from VIA3 Corporation, you may notify us by using the contact information provided in Section 9 below.

   2. Linking to Third-Party Websites

      VIA3 Corporation provides links to other websites that it does not own or control. When you click on links on our site that take you to third-party websites, you will be subject to the third parties’ privacy policies. While we support the protection of privacy on the Internet, VIA3 Corporation cannot be responsible for the actions of any third-party websites. We encourage you to read the posted privacy statement of any and every site you visit, whether you are linking from our site or browsing on your own.

   3. Access to and Managing Your Client Information

      We believe it is important for you to be able to find out what personally identifiable information you have provided to us through our site. If you have provided us with personally identifiable information, you can contact us to request that we provide you with the personally identifiable information we have in our records about you. We reserve the right to limit the number of times such a request can be made and to charge you for responding to such requests if this process is misused or abused. Note that, as stated above, we do not have access to any personally identifiable information you provide using our instant messaging or instant messaging archiving services, as these are communications between you and another user rather than between you and VIA3 Corporation.

      You may contact us using the contact information provided in Section #9 below to inquire about the personally identifiable information we have in our records about you and how to correct, amend, or delete your personally identifiable or sensitive information. We know you want the personally identifiable information we have on record about you to be as complete and accurate as possible. We feel the same way, since maintaining accurate information is essential to our efforts to give you the best possible experience when you visit our site and to provide you with the most up-to-date information about the exciting things happening on our site and with our business. If you become aware that personally identifiable information or sensitive information you may have provided that we have in our records about you is inaccurate, incomplete, or incompatible with the purposes for which it was provided or subsequently authorized by you, please notify us using the contact information provided below.

      If you have created either a Client Profile or an Applicant Profile, then you may view and edit the Client Information maintained in your profile on the “Edit Profile” page within the “My Account” section of the website by using your appropriate username and password.

1. 1. What You Need to Do to Protect Your Personally Identifiable Information

      You have several options when deciding how you can best protect your personally identifiable information. One option is simply not to volunteer it. As stated above, this approach would allow you to still visit our site. And you have the option of obtaining VIA3 Corporation’s products and services, obtaining additional information about VIA3 Corporation and its offerings, and applying for employment with VIA3 Corporation without submitting personally identifiable information online. To do this, please contact Client Services at 1 (866) 265-8060.

      The Federal Trade Commission’s website, www.ftc.gov , also offers useful information about how to protect personally identifiable information provided to a website. Outside of the United States, you should check the applicable sites of your particular country, such as the Information Commissioner’s Office in the United Kingdom (http://www.ico.gov.uk/) or the Office of the Federal Privacy Commissioner in Australia (http://www.privacy.gov.au/).

1. What to Do About Suspected Violations of This Privacy and Security Policy

   We have internal processes in place to monitor our compliance with the Safe Harbor Principles, to train employees in their implementation, to discipline employees for failure to follow them, and to address all questions or complaints. We encourage you to raise any concerns or complaints related to our compliance with this Privacy Statement and Security Policy or the Safe Harbor Principles directly with us by notifying us using the contact information provided in Section #9 below. We will make all commercially reasonable efforts to promptly address your concerns. For complaints that cannot be resolved directly between you and VIA3 Corporation, VIA3 Corporation submits to the American Arbitration Association’s alternative dispute resolution mechanism to resolve any such disputes under the Commercial Arbitration Rules and the Supplementary Procedures for Online Arbitration (see www.adr.org ). If VIA3 Corporation fails to comply with any AAA orders, VIA3 Corporation grants AAA permission to notify such failure to a governmental body with applicable jurisdiction or to the courts, as appropriate, and to notify the U.S. Department of Commerce.

2. Changes to Privacy Statement

   This privacy policy was last changed on June 29, 2007. If we change our Privacy Statement, we will post those changes on our website so you are always aware of what information we collect, how we use it, how we protect it and under what circumstances, if any, we disclose it. If we make material changes, we will also post a notice on our home page, which notice will run for 10 consecutive days following the effective date of the modified privacy statement. Unless we clearly express otherwise, we will use information in accordance with the Privacy Policy under which the information was collected and/or authorized for use. YOU ARE HEREBY ADVISED THAT YOUR CONTINUED USE OF OUR SITE AND/OR SUBMISSION OF CLIENT INFORMATION CONSTITUTES YOUR ACCEPTANCE OF ANY AMENDMENTS TO AND THE MOST RECENT VERSION OF THIS PRIVACY STATEMENT AND SECURITY POLICY.

3. Contact Information

   If you have any questions or comments concerning our privacy policy, please contact VIA3 Corporation, 6929 N Hayden Rd., Suite C4, Box 606, Scottsdale, AZ 85250; or e-mail: billing@via3corp.com .

4. Limitation on Application of Safe Harbor Principles

   Adherence by VIA3 Corporation to the Safe Harbor Principles may be limited (a) to the extent required to meet national security, public interest or legal obligations; and (b) to the extent an applicable law, rule, or regulation confers a conflicting obligation or an explicit authorization upon VIA3 Corporation. Where such authorization exists, VIA3 Corporation will minimize its non-compliance with the principles so as to do no more than is necessary to satisfy these legitimate overriding interests.

Security Policy

1. 1. Protecting Your Information

      We are committed to securing the personally identifiable information you provide to us. We utilize processes and technology to provide you with the reasonable assurance that your personally identifiable information is secured against loss, misuse, unauthorized access, disclosure, alteration, and destruction. The personally identifiable information you provide through online forms is secured using Secure Sockets Layer (SSL) encryption technology. We use this SSL technology to help prevent such information from being intercepted and read as it is transmitted over the Internet. The encrypted data goes to a secure site where your information is stored on restricted-access computers located at restricted-access sites. We cannot, however, guarantee protection of personally identifiable or sensitive information because of technological limitations and the inherent insecure qualities of the internet.

      If you communicate with us by e-mail, that message will typically not be encrypted. Accordingly, VIA3 Corporation encourages you to limit the amount of personally identifiable information that you include in any e-mail message that you send to us.

      Your password is always encrypted and not even accessible by VIA3 Corporation employees. So it is imperative that once you set up your password that it is never forgotten or lost as we cannot recover it for you. This practice is put in place to offer you a high level of security when using VIA3 Corporation’s services.

1. 1. Password Security

      To further secure your Client Information, we require you to create a personal password when you establish an account with us. We strongly encourage you to use a password that cannot be guessed (i.e., don’t use your name or street name). Keep your password secret; do not share it with anyone.

      As mentioned in Section #1 above, VIA3 Corporation receives passwords in a totally encrypted format and does not have access to decrypt any passwords; therefore we cannot be responsible for the recovery of lost passwords since this imposes a security risk to all our users.

      If you forget your password, you can send Client Services a request (billing@via3corp.com) and they will send you only the hint for your password. If you want to change your password you can do so within the VIA3 product. If you would like to change your profile or account information please log on to our My Account section of our website.

1. Remember to Sign Out

   To prevent unauthorized access to your account, remember that, after you sign in, you should sign out or lock your computer once you have (i) completed managing your account, or (ii) decided to step away from your computer. Anyone who accesses your computer after you have signed in but before you have signed out can access your account or any information on your computer.

2. Alternative Customer Purchasing Options

   If you do not feel comfortable sending any of your personally identifiable information over the Internet, you still can obtain information about or purchase our online meeting services. We welcome you to contact one of our Sales representatives by calling 1 (866) 265-8060.

3. Changes to Security

   This security policy was last changed on June 29, 2007. If we change our Security Policy, we will post those changes on our website so you are always aware of the measures we are taking to protect the information collected on this site. If we make material changes, we will also post a notice on our home page, which notice will run for 10 consecutive days following the effective date of the modified privacy statement. YOU ARE HEREBY ADVISED THAT YOUR CONTINUED USE OF OUR SITE AND/OR SUBMISSION OF PERSONALLY IDENTIFIABLE INFORMATION CONSTITUTES YOUR ACCEPTANCE OF ANY AMENDMENTS TO AND THE MOST RECENT VERSION OF THIS PRIVACY STATEMENT AND SECURITY POLICY.