Our privacy policy, updated as of January 1, 2006, describes the information we collect and how we use it.

Equitrader is committed to protecting the privacy of our users. We want to provide a safe, secure user experience. We will use reasonable commercial efforts to ensure that the information you submit to us remains private. Your personal information is immediately transferred from our Web server to behind our firewall, where it remains isolated from a direct connection to the Internet. By using this Web site, and in doing so accepting the Terms and Conditions of Use under which you may use this Web site (see Terms and Conditions of Use), you consent to the use of your personal information as described in this privacy policy.

Our privacy policy and security measures are periodically reviewed and enhanced as necessary. You should understand, however, that "perfect security" does not exist on the Internet. The information that you submit to us is used only for the purposes as set forth herein, as required by law, or when we believe in good faith that disclosure is legally required to protect our rights. We will not use your personal information for any other purpose other than as set out here without first obtaining your permission. The following reflects our commitment to you.

Your California Privacy Rights
California Civil Code Section 1798.83 permits registered users who are California residents to request certain information regarding disclosure of personal information to third parties for their direct marketing purposes. To request such information, please e-mail support@equitrader.com or write to us at:

Equitrader
C/O Topcoder, Inc
95 Glastonbury Blvd, 3rd Floor
Glastonbury, CT 06033
Attn: Privacy Department
Information About All Equitrader Visitors

We gather information about all of our users collectively, including without limitation (a) their Internet domain and their computer's IP address, (b) what area users visit most frequently, (c) the type of browser and operating system they use, and (d) if the user linked to our Web site from another Web site, the address of that other Web site. This information does not in any way personally identify a user; we only use this data anonymously and in the aggregate. We use this information to analyze trends and statistics to help us improve our services, plan site enhancements and measure overall site effectiveness. From time to time we may reveal general, anonymous, aggregated statistical information about our Web site, services and users, such as the number of visits and users and what Web site features they use.

Information About You Specifically
If you choose to register as a trader in order to participate in Equitrader competitions, you will provide us with additional information about yourself, including your name, address, handle (public login name) and other contact information. From time to time, we may use the contact information to alert members of new competitions and/or to communicate news, events and reminders. If you do not want to be notified of upcoming competitions, do not check the "Next Competition" box in the registration form. I f you do not want to be alerted to our news and other events, do not check the "Equitrader News and Events" box in the registration form. You may change these selections at any time by logging in and editing your profile. You may request the removal of your information from our database by emailing us at support@equitrader.com.

During a competition, traders who are participating will be shown and identified only by their handles. Only an Equitrader's handle and the value of his/her portfolio will be publicly displayed during a competition. If you win a prize in one of our competitions, we may also be required by law to request your date of birth. In addition, if you are a U.S. person (including U.S resident aliens), we will request your social security number (or taxpayer identification number) on IRS form W-9. If you are a prize winner, and you are not a U.S person, we will request a Certificate of Foreign Status of Beneficial Owner for United States Tax Withholding on IRS form W-8BEN. We use this information to verify your eligibility to participate in specific competitions, and to contact you and properly notify the IRS should you be a winner.

The results of each competition will be available to anyone. Your performance in a competition will allow us to help balance the competition. It will be recorded to calculate competition rating values and it will be posted on the Web site. Winners' names may also be released to competition sponsors and/or governmental authorities as required by law.

If you elect to share your contact information, only Equitrader sponsors and subscribers will have access to view your demographic information, educational and work experience, and other related contact information.

Equitrader sponsors may contact you proactively based upon your skills, experience and performance in Equitrader competitions. If you are contacted by a third-party regarding employment opportunities and/or media interest as a result in your participation in Equitrader competitions, you agree to promptly notify Equitrader of such contact. Equitrader may decide to utilize a process through which Equitrader members may choose to review online inquiries from interested Equitrader sponsors or subscribing companies before being contacted by those companies.

The personal information you provide must be accurate and complete and all registration details (where applicable) must contain your real name, address and other requested details. You are solely responsible for your personal information and we may take any action with respect to your personal information we deem necessary or appropriate if we believe it may cause us to suffer any loss, liability or commercial damage.

Forums
Equitrader forums make discussion topics available to our members and sponsors. These forums will identify Equitrader members by their user handles. Those simply viewing the discussions may do so without identifying themselves, but those who wish to participate must be members or sponsors and must login to prove their membership or sponsorship. Please remember that any information you disclose in these areas becomes public information. Accordingly, you should always exercise caution when deciding to disclose any personal information.

Cookies
To enhance your experience at Equitrader, we may use a feature on your Internet browser called a "cookie". As you may already know, cookies are small files that your Web browser places on your computer's hard drive. We use cookies for purposes such as remembering user names and passwords and preferences, tracking click streams, and for load balancing. Because of our use of cookies, we can deliver faster service, consistent, updated results, and a more personalized site experience. You have the option of setting your browser to reject cookies. Doing this may, however, hinder performance and negatively impact your experience on our Web site.

Feedback
Equitrader may ask you for feedback and comments about the Web site or our competitions and we encourage your participation. Any feedback that is submitted becomes the property of Equitrader. We may use this feedback, such as success stories, for marketing purposes, or to contact you for further feedback on the Web site.

Links to Other Sites
We may provide links to other Web sites that we believe can offer you useful information. We are not responsible, however, for the privacy policies of other Web sites, including those sites on which our logo or other information supplied by us appears. This privacy policy applies only to information collected by this Web site. We suggest that you access these other Web sites' online policies regarding their own data collection practices.

Access to Your Information
Equitrader will provide you with a reasonable opportunity to review the information that it has compiled about you, as well as a reasonable opportunity to correct any erroneous information. To view or correct your information, log in to the Equitrader Web site, access your profile and review the information.

Privacy of Children on Our Web Site Our Web site is not intended for use by children under the age of 13, and we do not knowingly collect personal information from children under the age of 13.

Privacy Commitment Changes
If we decide to change our privacy commitment for Equitrader, we will post those changes here so that you will always know what information we gather, how we might use that information, and whether we will disclose it to anyone. In the event that we make any significant changes to our Privacy Statement, we will also provide you with the opportunity to consent to different uses of your personal information. If, at any time, you have questions or concerns about Equitrader's privacy commitment, please feel free to e-mail us at support@equitrader.com.

This privacy policy is effective as of January 1, 2006.

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