Geminare’s Privacy Policy and Procedures

Accountability: We educate all our staff to be privacy sensitive; our Privacy Compliance Officer has instituted compliance measures, monitors ongoing compliance and responds to inquiries.

Identifying Purposes: We state the purposes for collecting information before or at the time of collection.

Consent: We obtain the prior consent of customers / members/ participants of our programs.

Limiting Collection: We limit the collection of information to that which is required for a specific program and to that
which is voluntarily provided by program participants, either through a client program or individually

Limited Use, Disclosure and Retention: We use the information that is provided to us for no other purposes than those
disclosed (for which the information was collected) and we retain it only as long as necessary to fulfill those disclosed
purposes.

Accuracy: Our employees take reasonable steps to ensure the accuracy of information provided to us by our participants.

Safeguards: We use industry standard methods of physical, organizational and technological security safeguards in the
collection, use, disclosure, and retention of information provided to us. We do not sell, trade, or exchange mailing lists
without consent, under any circumstances, with external third party vendors.

Openness: We are committed to making our policies and procedures for management of personal information readily
available to our participants.

Individual Access: Upon request, our participants shall be informed of the existence, use and disclosure of their personal information by us, and receive access to that information.

Opting Out of a Program: Participants may opt out of a program. Geminare also has a “Do Not Mail / Do Not Call” service for customers.

Disclosure to Service and Trading Providers

To process transactions, Geminare must disclose some of your personal information to certain service providers.
Geminare only discloses to service providers that agree with Geminare to protect the privacy of your personal information
in a manner consistent with this Policy.

Disclosure in Business Transfers

If Geminare sells or transfers some or all of its business, it may disclose your personal information to the acquiring
organization, if the acquirer agrees to protect the privacy of your personal information in a manner consistent with this
Policy.

Law Enforcement and Legal Disclosure

Geminare may disclose your personal information to a government or quasi-governmental agency that has asserted its
lawful authority to obtain the information or where Geminare has reasonable grounds to believe the information could be
useful in the investigation of unlawful activity, or to comply with a subpoena or warrant or an order made by a court,
person or body with jurisdiction to compel the production of information, or to comply with court rules regarding the
production of records and information, or to Geminare’s legal counsel.

Links

Web sites owned and managed by Geminare (‘Web Site’, ‘Site’) may contain links to other sites. Geminare assumes no
responsibility for the information, statements, product/service claims, or privacy practices of other sites. Read the privacy statements of each web site that collects identifiable information.

Cookies

Web sites owned and managed by Geminare use “cookies”, a technology that installs information on a web site user’s
computer to permit the web site to recognize future visits using that computer and enhance your user experience. E.g.,
Geminare uses your “cookie” information to recognize you as a previous user of the site. You may choose to decline
cookies if your browser permits, but doing so may affect your use of the Web Site and your ability to access certain site
features or engage in transactions through the Site.

Non-Identifiable Information

Like many other web sites, web sites owned and managed by Geminare automatically collect certain non-identifiable
information regarding site users, such as your computer’s and your Internet Service Provider’s Internet Protocol (IP)
addresses, the date and time you access our site, the Internet address of the site from which you linked directly to our
site, your operating system, the sections, pages and images of the site you visit, read and view, and the content you
download from the site. Geminare uses this non-identifiable information for site and system administration purposes and to improve the site.

Intellectual Property

The names, trademarks, logos and taglines identifying Geminare Incorporated, products and services are proprietary to
Geminare Incorporated and are protected by domestic and international intellectual property laws. Except as otherwise
expressly stated elsewhere on this Web site, any use and/or republication or dissemination of the content of this Web site without our prior express written consent is strictly prohibited. Trademark notices on company and product names of unrelated entities are for informational purposes only and are not intended as a claim of rights by Geminare Incorporated.