Legal

Ethics Metrics has created this website privacy policy ("Privacy Policy") in order to demonstrate and inform our valued customers and visitors ("User(s)") to the EthicsMetrics.com and CorporateGovernanceCouncil.com websites (this "Site") of our firm commitment to fair information practices and the protection of each Users' privacy. This Privacy Policy applies only to information collected through this Site and not to information collected offline.

Types of Information Collected

• Traffic Data Collected. Ethics Metrics automatically tracks and collects aggregate data and information when a User visits this Site, including but not limited to, a User's (i) IP address; (ii) domain server; (iii) type of computer; and (iv) type of web browser (collectively, "Traffic Data"). Traffic Data is anonymous data broad demographic information that does not personally identify a User, but is helpful for administering our Site and improving a User's experience on the Site. Ethics Metrics may share such non-personally identifiable Traffic Data with existing and prospective business partners and advertisers. As is the case with most web sites, Ethics Metrics also uses "cookies" to customize content specific to User's interests.

• Personal Information Collected. In order for a User to access and use certain services Ethics Metrics offers via this Site, Ethics Metrics may require Users to provide information that personally identifies that User ("Personal Information"). Personal Information may include: (i) a User's name, title, employer, office telephone number, mailing and e-mail addresses ("Contact Data"); (ii) a User's account, credit card number or other financial information ("Financial Data"); and (iii) demographic data, such as a User's zip code and gender ("Demographic Data"). If a User communicates with Ethics Metrics by e-mail or otherwise completes an on-line form or survey, any information provided in such communication may be collected as Personal Information.

• Data and Reports Compiled or Generated Through the Site Services. As a part of certain services, Ethics Metrics compiles and stores data and information and generates reports related to User's access to and use of such services ("Service Data and Reports").

Use of Personal Information Collected

• Contact Data. Ethics Metrics uses Contact Data to send Users information about Ethics Metrics or our products or services, promotional material from selected partners, or to contact Users when necessary. By establishing an account with us, and each time you make a purchase through our Site, you grant permission for Ethics Metrics to contact you at your e-mail address. To stop receiving our marketing emails, send an e-mail to us at optout@EthicsMetrics.com. If a User would prefer not to receive direct communications from select advertisers or promotional partners that may be of interest, such User will be given an opportunity to opt-out of such communications, though Ethics Metrics may send Users information on their behalf. In all cases, we will use your information only as permitted by law.

• Financial Data. Ethics Metrics uses a User's Financial Data to verify that User's qualifications for certain products or services, order processing and to bill the User for products and services.

• Demographic Data. Ethics Metrics uses Demographic Data to customize and tailor the User's experience on the Site, and to display content that Ethics Metrics thinks a User might be interested in according to that User's preferences.

• Service Data and Reports. Ethics Metrics may use Service Data and Reports for such purposes as Ethics Metrics deems appropriate, including without limitation, disclosure and/or sale of such Service Data and Reports to Ethics Metrics suppliers and business partners. By using the Site, User consents to the collection and use of User's Personal Information and Service Data and Reports by Ethics Metrics as described in this Privacy Policy.

User Choice Regarding Collection, Use and Distribution of Personal Information

• Users may choose not to provide Ethics Metrics with any Personal Information. In such an event, Users can still access and use much of the Site; however, such Users will not be able to access and use those portions of the Site that require User's Personal Information.

Confidentiality and Security of Personal Information

• Except as otherwise provided in this Privacy Policy, Ethics Metrics will keep your Personal Information and Service Data and Reports private and will not share any of it with third parties, unless such disclosure is necessary to: (a) comply with a court order, legal process or as otherwise required by law; (b) protect Ethics Metrics or a User's rights or property; (c) protect against misuse of the Site and to identify persons who may be violating law or the rights of third parties; (d) to cooperate with the investigations of possibly unlawful activities; or (e) enforce our Terms of Service. Please note that Ethics Metrics may not provide you notice prior to disclosure in such cases. To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, Ethics Metrics has put in place industry standard physical, electronic, and managerial procedures to safeguard and secure the information Ethics Metrics collects on-line that is under Ethics Metrics' control. For example, User's Personal Information is stored on secure servers. Ethics Metrics provides Users with the capability to transmit User's Personal Information via secured and encrypted channels if User uses a similarly equipped web browser. However, no data transmission can be guaranteed to be completely secure, and Ethics Metrics does not warrant the security of information transmitted by you over the Internet to Ethics Metrics.

User Ability to Access, Update, and Correct Personal Information

• In order to ensure that all of User's Personal Information is correct and up-to-date, you or your Company Administrator may visit your personal profile at EthicsMetrics.com at any time. Through User's personal profile you may review and update your Personal Information that Ethics Metrics has already collected.

Other Limits to Your Privacy

• This Site provides links to various web sites or sponsors that we do not control for your convenience. When you click on one of these links, you will be transferred out of our Site and connected to the web site of the organization or company that you selected. We are not responsible for the nature, quality or accuracy of the content or opinions expressed in such web sites, and such web sites are not investigated, monitored or checked for quality, accuracy or completeness by us. Inclusion of any linked web site on our Site does not imply or express an approval or endorsement of the linked web site by Ethics Metrics, or of any of the content, opinions, products or services provided on these web sites. Even if an affiliation exists between our Site and a third-party web site, Ethics Metrics exercises no control over linked sites. Each of these linked sites maintains its own independent privacy and data collection policies and procedures. While Ethics Metrics expects its partners, advertisers and affiliates to respect the privacy of our Users, Ethics Metrics cannot be responsible for the actions of third parties. If you visit a web site that is linked to from our Site, we encourage you to consult that web site's privacy policy before providing any personal information and whenever interacting with any web site.

Disclosure of Customer Information through Business Transfers

• As Ethics Metrics continues to develop our business, Ethics Metrics may buy, merge or partner with other companies or businesses, and in so doing, acquire customer information. In such transactions, Personal Information may be among the transferred assets. Similarly, in the unlikely event that a portion or substantially all of Ethics Metrics assets are sold or transferred to a third party, Personal Information would likely be one of the transferred business assets.

Special Notification for California Residents

• Under California law, individual customers who reside in California and have provided their personal information to Ethics Metrics may request information about our disclosures of certain categories of personal information to third parties for their direct marketing purposes. In response to your written request, Ethics Metrics will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties.

• If you would like to exercise your rights under California law, please send your written request to optout@EthicsMetrics.com. We reserve our right not to respond to requests submitted other than to optout@EthicsMetrics.com. Your request must include your postal address so that we may provide you with our notice and third party direct marketing opt-out form.

Consent to Privacy Statement

• This Site is controlled, operated and administered entirely within the United States . By using this Site, you signify your agreement to the terms of our Privacy Policy. If you do not agree with this Policy, please do not disclose any Personal Information through this Site. This Privacy Policy and the use of this Site are governed by Virginia law. Any claim related to the Site or this Privacy Policy shall be brought in a federal or state court in Albemarle County , Charlottesville , Virginia , within one year after the claim arises. Users of the Site consent to the jurisdiction and venue of such courts as the most convenient and appropriate for the resolution of disputes concerning this Privacy Policy. This Privacy Policy and the notices outlined herein are not intended to and do not create any contractual or other legal rights in or on behalf of any third party.

Updates and Changes to Privacy Policy; Account Revisions, Revoking and Deleting Personal Information

• Ethics Metrics reserves the right to add to, change, update or modify this Privacy Policy by posting such change, update or modification on the Site. Any such change, update, or modification will be effective immediately upon posting on the Site.

• At any time, you may revoke your consent, cease further use of your email address to send you updates, and direct Ethics Metrics to delete the information you have supplied. Although it is not always possible to remove or modify information in the databases, Ethics Metrics will make reasonable efforts to do so.

• Ethics Metrics welcomes your comments and questions. You may contact us using the following address and contact information:

info@EthicsMetrics.com
239-777-4638

DISCLAIMER & COPYRIGHT

The materials contained on this website are provided for general information only and do not constitute any form of advice. Ethics Metrics assumes no responsibility for the accuracy of any particular statement and accepts no liability for any loss or damage that may arise from reliance on the information contained on this site. Links to other websites from these pages are for information only and Ethics Metrics accepts no responsibility or liability for access to or the material on any website which is linked from or to this website. By providing links to other websites, Ethics Metrics does not guarantee, approve or endorse the information or products available at these websites, nor does a link indicate any association with or endorsement by the linked site to EthicsMetrics.com.

Website Copyright

Copyright 2009. Ethics Metrics LLC. Save to the extent expressly permitted below, the context of these pages may not be reproduced or transmitted or made available on a network in whole or in part without the prior consent of EthicsMetrics.com. These pages may be downloaded or printed for your personal and private use provided that you make no alteration to any of these pages and you do not use any part of the pages in any work or publication in whatever medium stored.

Ethics Metrics Ratings

Analytic services provided by Ethics Metrics' ratings services ("Ratings Services") are the result of separate activities designed to preserve the independence and objectivity of Ratings opinions. Ethics ratings issued by Ethics Metrics are solely statements of opinion and not statements of fact or recommendations to purchase, hold, or sell any securities or make any other investment decisions. Accordingly, any user of Ethics Ratings issued by Ethics Metrics should not rely on any such ratings or other opinion issued by Ethics Metrics in making any investment decision. Ratings are based on information received by Ethics Metrics.