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Aspen Conferencing, Inc. Privacy Policy

Effective on: 03/01/04 Aspen Conferencing, Inc. ("Aspen") is a leading provider of integrated audio, Web and video conferencing services. We have developed our Web sites (the "Aspen Sites") to provide you with access to our communications services. We understand your need for privacy when using the Web for your communication. This policy discloses Aspen's practices with respect to the collection, use and disclosure of user information collected through the Aspen Sites and through your use of Aspen services.

POLICIES:

1. COLLECTION AND USE OF PERSONAL INFORMATION. We will ask you to provide us with information that personally identifies you or allows us to contact you ("Personal Information") when, among other things; you register on any Aspen Sites, use one of our services, fill out a survey, make a request for information, or enter a sweepstakes or contests through the Aspen Sites. Because of the nature of our products and services, we must collect Personal Information from users. During the registration process we collect contact information such as, first and last name, mailing address, company name, title or position, e-mail address, and phone number. We may also collect financial information such as a valid credit card number to process payment for service. When you conduct a meeting, we collect information about your participants such as first and last name and e-mail address. Service Use: We will use the Personal Information that you provide us in these circumstances to operate the Aspen Sites, to provision, deliver, operate features, bill and collect for services as well as provide information that you request from the Aspen Sites. We may use your Personal Information to notify you about updates or free upgrades to products you have previously purchased or to inform you about critical technical issues relating to our services. Generally, you may not opt-out of these communications if you wish to continue using our services. Our products and services by necessity require us to provide some Personal Information to third parties. For example, when you use Aspen services to conduct a meeting, we will provide some Personal Information about each participant to you as the moderator as well as to other participants in your meeting. In addition, we will share some of your Personal Information with credit card companies as necessary to bill and collect for our services ("Service Use").

Secondary Use: Unless you instruct us not to do so, Aspen may also use the Personal Information that you provide us to contact you regarding additional or new services and features offered by Aspen, special offers by Aspen, third party promotions that are administered by Aspen, or other information regarding Aspen and our services ("Secondary Use").

Promotional Communications from Third Parties: In addition, with your permission, or if we tell you when we collect the information, we may provide your Personal Information to our partners, advertisers or third parties who may contact you regarding products, services, and offers that may be of interest to you, but that may not be directly related to Aspen or the Aspen Sites ("Promotional Communications from Third Parties").

Free Users: If you register for any free service, Aspen may use your Personal Information for any Service Use, Secondary Use or Promotional Communications from Third Parties. You may opt-out of such use by upgrading to a chargeable service or canceling your free service account. Referral Use: We may use Personal Information that you provide us if you elect to use our referral services. If you elect to inform a friend about our site, we ask you for your friend's name and e-mail address. We will automatically send your friend a one-time e-mail inviting the friend to visit the site. To request the removal of this information from our database, your friend may contact Aspen by sending a message to support@aspenconferencing.com. Information submitted to us regarding becoming a partner is completely voluntary and enables us to provide you with information on Aspen opportunities. You may submit this information via forms located at our site or by contacting us at support@aspenconferencing.com. ("Referral Use").

Supplementation of Information: At times it is necessary for us to supplement the information we receive from you with information from third party sources. For example, Aspen verifies the billing address on all credit card transactions and may obtain credit reports for corporate customers. The information obtained from these third party sources is maintained in a manner consistent with our Privacy Policy.

2. CHOICE. You may stop the delivery of informational or promotional mail from us by following the instructions included in the informational or promotional mail itself. Once you have agreed that your information may be used for Promotional Communications from Third Parties, or you have responded to an offer by any third party on an Aspen Site, Aspen can no longer update any of your Personal Information that has been transferred to such third parties or opt you out of such third parties use so that you no longer receive their promotional or marketing information. Instead, you must either contact that third party or refer to their privacy policy to update your Personal Information or to let them know that you no longer want to receive promotional or marketing information about their products, services, or offerings. Even though we cannot update your Personal Information once it has been provided to a third party, you may instruct Aspen to stop providing your Personal Information to third parties going forward by changing your status as instructed below in Section 3 - Access.

3. ACCESS. When you register to use any of the services offered by Aspen, Aspen will send you a confirmation of your registration showing the Personal Information that we obtained from your registration. Also, whenever possible, we will take reasonable steps to give you the opportunity to confirm and/or modify your Personal Information. If you wish to change your personal information for Aspen Meeting Edition, go to the "Manage Your Account" page where you can change your user name, e-mail address and update your credit card information. Alternatively, you may contact us at support@aspenconferencing.com to update or change your Personal Information. You can also change your e-mail subscription status to receive our newsletter, e-mail marketing communications and third-party promotions.

4. SECURITY. The Personal Information that we collect from you is stored in secure operating environments that are not available to the general public. In the case of credit card numbers and other financial information, your Personal Information is encrypted for even greater protection. Nevertheless, we remind you that no security measure is perfect. In addition, the other sites that you may access through the Aspen Sites may have different security practices and you should familiarize yourself with those practices.

5. COMPLAINTS. If at any time you believe that we have violated any of these Policies, please notify us by e-mail at support@aspenconferencing.com and we will use all commercially reasonable efforts to promptly investigate and remedy the problem.

6. DISCLOSURE FOR LEGAL PURPOSES. We may disclose Personal Information if required to do so by law or in the good-faith belief that such action is necessary: (a) to conform to the edicts of the law or comply with legal process served on us or our affiliates, (b) to protect and defend our rights or property or those of our users, (c) to act immediately to protect the personal safety of our users or the public, (d) in connection with a merger, consolidation or sale of substantial assets of Aspen or (e) as necessary to ensure compliance with the terms and conditions and policies regarding the use of our services. In addition, if Aspen sells assets to another entity, or is acquired by, or merged with, another entity, Aspen may provide to such entity Personal Information that is related to that part of our business that was sold to or merged with the other entity without your consent.

7. ANONYMOUS INFORMATION. Please understand that, in addition to collecting Personal Information, Aspen will also gather information that does not personally identify you regarding your use of the Aspen Sites ("Anonymous Information"). The Anonymous Information that we collect regarding your use of the Aspen Sites may be used by us to measure the effectiveness of marketing efforts on the Aspen Sites, for improving the services we offer to you, or to share with third parties for other purposes. For example, we might use this Anonymous Information to inform our advertisers how many users visited a particular advertisement, and for how long, so they can measure whether the advertisement was effective. Anonymous Information may include data on connection information, including the timing and size of all packets sent over the Internet during use of our services or traffic patterns throughout Aspen Sites. Generally, you will not be aware when such Anonymous Information is being collected about you - it may be collected in various ways, such as through traffic data or direct surveys of our customers and may entail the use of, among other things, cookies, IP addresses, or other numeric codes used to identify a computer by which a user accesses our site or used to identify other devices by which a user may access our services. Like most Web sites, our servers use log files to analyze trends, administer the site, track user's movement in the aggregate, troubleshoot, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.

8. COOKIES. We use cookies to provide you with better service. Cookies are pieces of information that a Web site transfers to your computer's hard disk for record-keeping purposes. Cookies can make the Web more useful by storing information about your preferences for a particular site. The use of cookies is an industry standard, and many major Web sites use them to provide useful features for their customers. Cookies in and of themselves do not personally identify users, although they do identify a user's computer. Most browsers are initially set to accept cookies. If you prefer, you can set your browser to refuse cookies. However, you may not be able to take full advantage of the functionality of the Aspen Sites or services if you do so. We use both session cookies and persistent cookies. For the session cookie, if a user fails to complete a function within a specified period of time, the cookie terminates. A persistent cookie is a small text file stored on the user's hard drive for an extended period of time. Persistent cookies can be removed by following Internet browser help file directions. Persistent cookies enable us to track and target the interests of our users to enhance the experience on the Aspen Sites. We use persistent cookies for purposes such as tracking movement on the Aspen Sites, managing your login process, and limiting the display messages to the same user more than once. We do not store your passwords in cookies. We treat any personal information that may be contained in cookies with the same level of protection as other personal information you provide to us.

9. VENTURING OFF THE ASPEN SITE. The Aspen Sites contain ad banners and hyperlinks that can take you to Web sites run by other third parties ("Third-Party Sites"). Aspen has no control over how such Third-Party Sites will treat your Personal Information, and the terms of the privacy policies of such Third-Party Sites may differ from the terms of this Privacy Policy. Accordingly, Aspen strongly recommends that you review the terms of the privacy policy at each Third-Party Site that you choose to visit before providing any Personal Information to that site. REMEMBER, THIS PRIVACY POLICY ONLY APPLIES TO THE ASPEN SITES. WHEN YOU ARE NO LONGER ON THE ASPEN SITE, YOU MAY ENCOUNTER DIFFERENT PRIVACY AND SECURITY PRACTICES AND YOU SHOULD FAMILIARIZE YOURSELF WITH THOSE PRACTICES EACH TIME YOU VISIT A NEW SITE.

10. CHANGES TO OUR PRIVACY POLICY. All Personal Information that we collect and maintain will be subject to the version of the Privacy Policy in effect at the time of such collection. Aspen reserves the right to change the Privacy Policy from time to time in our sole discretion, and will provide notice of material changes on the home page of the Aspen Site. If as the result of such changes, you want to alter the ways in which Aspen is allowed to use your personal information, you can do so by following the procedure described in the section titled "Access." You will be deemed to have been made aware of, and will be subject to, the changes to the Privacy Policy by your continued use of our services or the Aspen Sites after such notice has been posted for thirty (30) days with the following exception: If at the time you provide personal information to Aspen you are given the opportunity (as you currently are) to limit how such information will be used to communicate with you, either by Aspen or by third parties, Aspen will not change your preference in this regard without your express consent.

11. CONTACTING US You may also contact us by writing or calling Aspen at:

Customer Information
311 South 1st
Aspen, CO 81611
support@aspenconferencing.com
1-800-363-9527


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