Introduction

The Colbent Corporation's privacy policy covers personally identifiable information received by Colbent from its clients and from the clients, customers, or shareholders of its clients.  This personally identifiable information is contained in public records, publicly available information and non-public information (see Definitions below). Colbent is committed to promoting the responsible use of information and protecting individual privacy rights. In recognition of the commitment, Colbent adheres to the principles contained within its privacy policy. Colbent recognizes that certain statutes may regulate some of the Personally Identifiable Information handled by Colbent, and Colbent diligently complies with the requirements of these laws. Colbent reserves the right to deviate from this privacy policy if it is required to do so by operation of law, upon request of law enforcement, or, if necessary, to prevent fraud or to maintain integrity of its computer systems.

Definitions:

Personally Identifiable Information

Personally Identifiable Information means information about a specific individual that either identifies the individual or is directly attributed to the individual. Personally Identifiable Information is contained in public records, non-public information and publicly available information. Examples of Personally Identifiable Information include:

• Name
• Address
• Telephone number
• Date of birth

Public Records

Public records are those records created and maintained by government agencies and open for public inspection. Examples of public records include:

• Motor vehicle registrations
• Uniform Commercial Code (UCC) filings
• SEC filings

Non-Public Information

Non-public information is information about an individual obtained from a source that is privately owned and is not available to the general public. Non-public information may include the following data elements:

• Name
• Previous names used, such as alias names, maiden names or previous married names
• Current and previous addresses
• Social Security number
• Birth date information

Publicly Available Information

Publicly available information is information about an individual that is available to the general public from non-governmental sources. Sources of publicly available information include:

• Newspapers and other publications
• Telephone directories
• Classified ads

Accuracy

While maintaining, using or disseminating personally identifiable information, Colbent takes reasonable steps to accurately reproduce data it receives from its various sources. However, due to the nature of public records, non-public information and publicly available information, it is reasonable to expect these files to contain some errors. For public records and publicly available information, Colbent will direct the consumer to the data supplier or government entity that can review the claim and make appropriate corrections.

Sharing of Non-Public Information

Colbent distributes non-public information only to its clients, and then only when the information or data in question is pertaining to the clients, customers or shareholders of that Colbent client. If upon investigation Colbent finds that non-public information is used inappropriately or unlawfully, it will take reasonable steps to stop the misuse, educate the user concerning the appropriate and lawful use of the information, and prevent similar future misuses.

Colbent will never sell or otherwise market personal data to third parties.

Limitations

Colbent will only collect, use or disclose non-public information gathered on behalf of its clients, or pertaining to the clients, customers or shareholders of Colbent clients, for the purposes disclosed to the client in question, and never for any other purpose.

Security

Colbent is committed to keeping its data secure and takes all reasonable and appropriate steps to protect its information and data from unauthorized access.