ServiceFirst Solutions, Inc.'s Privacy Statement
Effective January 1, 2004

This Privacy Statement applies to ServiceFirst Solutions Inc.'s site.

Please note that our site contains links to other sites. ServiceFirst is not responsible for the privacy practices, privacy statements, or content regarding these other sites.

Information We Gather from You

Personal Information

We do not collect any personal information from a visitor to our site unless that visitor explicitly and intentionally provides it. Under no circumstances do we collect any personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, or sex life. If you are simply browsing our site, we do not gather any personal information about you.

There are two ways in which you may explicitly and intentionally provide us with and consent to our collection of certain personal information:

E-mail Request for Information or Registrations - We use links throughout our site to provide you with the opportunity to contact us via e-mail to ask questions, request information and materials, register or sign up for services, or provide comments and suggestions. You may also be offered the opportunity to have one of our representatives contact you personally to provide additional information about our products or service s. To do so, we may request additional personal information from you, such as your name and telephone number, to help us satisfy your request.

Enrollment - If you choose to enroll for one of our products or service s, we will request certain information from you. Depending on the type of product or service that you request, you may be asked to provide different personal information. For certain products and service s, we may require your name, address, telephone number, e-mail address, credit card number, bank account information, IP address, and/or social security number. Other products and service s may require different or supplemental information from you in order to apply. For a detailed listing of the type of personal information requested for our various products, please refer to the enrollment page for the particular product or service .

Statistical Information About Your Visit

When you visit our site, our computers may automatically collect statistics about your visit. This information does not identify you personally, but rather about a visit to our site. We may monitor statistics such as how many people visit our site, the user's IP address, which pages people visit, from which domains our visitors come and which browsers people use. We use these statistics about your visit for aggregation purposes only. These statistics are used to help us improve the performance of our Web site.

Use of Cookies

We only use "cookies" as described in this Section. A "cookie" is a piece of information that our Web site sends to your browser, which then stores this information on your system. If a cookie is used, our Web site will be able to "remember" information about you and your preferences either until you exit your current browser window (if the cookie is temporary) or until you disable or delete the cookie. Many users prefer to use cookies in order to help them navigate a Web site as seamlessly as possible. You should be aware that cookies contain no more information than you volunteer, and they are not able to "invade" your hard drive and return to the sender with personal or other information from your computer.

To find more information about cookies, if you are using Microsoft Internet Explorer® as your browser, go to the Microsoft Web site at http://www.microsoft.com/info/cookies.htm?RLD=291 or if you are using Netscape Navigator® as your browser, go to the Netscape Web site at http://home.netscape.com/security/basics/privacy.html#cookies

How We Use and With Whom We Share the Information We Gather

We assure you that the information we gather from you is used by us only as explained below.

Sending you responses and updates

We generally respond to any e-mail questions, requests for product or service information, and other inquiries that we receive. We may also retain this correspondence to improve our products, services, and Web site, and for other disclosed purposes. Frequently we retain contact information so that we can send individuals updates or other important information about our services and products. Occasionally these updates or other important information may be sent out by third parties on our behalf. Please be assured that any third party who contacts you in this capacity has executed a confidentiality agreement with us that contains a provision ensuring the privacy and security of any transferred information and limits the third party's use of the shared information to sending updates or providing services on our behalf. In situations where you have supplied your information in connection with a question or request for information about a product or service offered by a ServiceFirst business partner, we may also send the information you have supplied to the ServiceFirst business partners that offer such products or services. Please be assured that these ServiceFirst business partners have agreed to ensure the privacy and security of any transferred information and may only use the shared information to send you information about products or services about which you asked.

Facilitating the support, renewal, and purchase of our products and services

We may use the information you submit to contact you to discuss the support, renewal, and purchase of our products and service s. We may also provide the information you have submitted to us to a ServiceFirst subsidiary, business partner, representative or Affiliate (either within or outside the United States) so that the subsidiary, business partner, representative or Affiliate can contact you and facilitate the support, renewal, and purchase of ServiceFirst products and service s. Our Affiliates are either members of the ServiceFirst Trust Network (a certificate-based public key infrastructure that permits interoperable and secure electronic commerce and communications) or our payment service s affiliates, and in both cases they help us provide our foreign-based (and certain domestic) customers with support, assistance, and the provision of our products and service s in their local markets. You may receive a communication directly from one of our subsidiaries, business partners, representatives or Affiliates. Please be assured that any subsidiary, business partner, representative or Affiliate who contacts you for one of these purposes has agreed to use the information we supply only in accordance with a confidentiality agreement. To find out the names and locations of the subsidiaries, business partners, representatives and/or Affiliates to whom we have provided your information, please contact us at the address given at the end of this Privacy Statement.

Processing payments (if you are using our payment services)

If you use the ServiceFirst Payment Services payment gateway for online transactions, we may provide your personal information to appropriate financial institutions, processors, and third parties under contract with ServiceFirst or our Affiliates for providing a subset of the payment service s (for example, credit authorization and fraud screening). For financial institutions and processors, the use of personally identifiable consumer information is governed by federal and state privacy laws. For other third parties under contract with ServiceFirst, the use and distribution of your personal information will be used by such entity for its internal use related to fulfilling the transaction services for ServiceFirst, will be treated as confidential by this entity, and will be transferred between ServiceFirst and this entity only via encrypted means. We may also permit the merchant through which you placed your order to review the personal information you provide. The merchant's use of your personal information should be governed by your agreement with the merchant.

Assisting the merchant with your online purchase (if you are using Express Checkout)

If you use Express Checkout to purchase a product, the merchant from whom you are making the purchase is given a copy of the information you have given us. The merchant's use of your personal information should be governed by your agreement with the merchant and by the merchant's privacy policy (if any).

Disclosure by Law and Protection of ServiceFirst and Others

If we are required by law to disclose certain information to local, state, federal, national or international government or law enforcement authorities, we will do so (for example, we may disclose the identity of purchasers of certain software products to the U.S. Department of Commerce, Bureau of Export Administration, as required under the terms of our export licenses). We will also disclose information to third parties as necessary in order to comply with applicable laws and regulations. In addition, ServiceFirst may share information in order to investigate, prevent, or take action regarding illegal activities or suspected fraud, or enforce or apply ServiceFirst's agreements.

Surveys

From time-to-time we may request information from customers via surveys. Participation in these surveys is completely voluntary and the user therefore has a choice whether or not to disclose this information. Survey information will be used for purposes of monitoring or improving the use of and satisfaction with this Web site, and improving our customer service and product offerings.

Your Ability to Opt-Out of Further Notifications

From time-to-time, we notify our subscribers of new products, announcements, upgrades and updates. (In the case of the ServiceFirst Account Service, we will not notify you of new products, announcements, upgrades and updates, and therefore, you do not need to opt out of receiving these notices.) If you would like to opt-out of being notified, please contact us at the address given at the end of this Privacy Statement.

Please be aware that you may not opt out of receiving information regarding the security, initial use, expiration, product enhancement or migration of our Digital IDs or other products or services.

Please note that if you are using Express Checkout, the information you provide to us is used only to assist a merchant in making your online purchase, facilitating the support of Express Checkout or as required by law. We do not use this Express Checkout information to send you further notifications or communications other than those needed to support the product. Since we do not send you non-essential communications using your Express Checkout information, there is no need to indicate an opt-out preference. Please note that the merchant in Express Checkout may retain your information and you should follow that merchant's procedure to opt-out of further notifications.

Our Security Procedures

We consider the protection of all personally identifiable information we receive from our Web site visitors and subscribers as critical to our corporate mission. Please be assured that we have security measures in place to protect against the loss, misuse, and alteration of any information we receive from you. As with any transmission over the Internet, however, there is always some element of risk involved in sending personal information. In order to try to minimize this risk, we encrypt all information that you submit in ordering one of our products or service s using the Secure Sockets Layer (SSL) protocol. Our security procedures are also subject to at least an annual SAS-70 Type II audit by an internationally-recognized accounting firm.

Changes to this Privacy Statement

If a material change is made to this Privacy Statement and/or the way we use our customers' personally identifiable information then, we will post prominent notice of the nature of such change on the first page of this Privacy Statement and also on our home page.