We are committed to protecting consumer privacy. Our Online Privacy Statement is available to inform you about our collection and use of personal information so that you can make informed choices about how your own information is collected and used. This Online Privacy Statement reflects the ChucKlein policies covering personal information collected at this web site on or after the effective date shown above.

Consumers and businesses can rely on ChucKlein for safe and reliable service. Each day we endeavor to reinforce our commitment to our clients and consumers. Central to that commitment is ensuring that we abide by a set of privacy policies, which are outlined below. These policies guide us in the collection and use of information as well as employee responsibilities in protecting your privacy. We use personal information about consumers only in a manner consistent with these policies.

We may alter this statement as needed for certain products and services and to abide by local laws or regulations around the world. ChucKlein reserves the right to amend or modify this statement from time to time. We urge you to review this statement whenever you visit in order to obtain the most current statement.

Acceptance of These Terms

By using this web site, you are agreeing to the terms and conditions contained herein (as amended from time to time).

Collection of Information

ChucKlein collects personal information to enable us to deliver our online products and services to you. For example, some of our products and services will require a payment to be made via a secure credit card facility. Your contact details may be used from time to time to notify you of new products or services. Some of the information we collect is used to help us develop and improve the quality of our products and services, which in turn provides you with a more satisfying and enjoyable online experience. This data is also used to gain a better understanding of our customer base, thus enabling us to tailor our web site content to our customers' specific wants and needs.

We may obtain this information from a variety of sources:

• Directly from customer applications, questionnaires and other materials submitted to us by customers;
• From transactions in which ChucKlein and consumers are involved;
• From click thru activity on our web sites; and
• From a variety of third-party sources, such as, but not limited to, our business customers, government repositories, consumer reporting agencies and other financial institutions.

Disclosure of Information

ChucKlein does not disclose customer information to third parties without first giving customers an opportunity to opt-out of certain kinds of disclosures. We do not sell your personally identifiable information to others. We may provide you information about products and services from partners we select that we think may be of interest to you.

There are some disclosures necessary to effect, administer or enforce a transaction requested by you, to companies that perform services for us or to prevent fraud.

Finally, ChucKlein may disclose information about former customers to third parties and companies with which ChucKlein is affiliated, as well as unaffiliated third parties. Those disclosures may consist of the following:

• Financial background information describing a customer's financial status;
• Identification information, such as name and address data;
• Transaction information, such as account activity, debit activity or credit activity; and
• Other information relating to financial matters.

Recipients of Information

ChucKlein may disclose consumer information to companies affiliated with ChucKlein and to companies or other parties not affiliated with ChucKlein (Subject to consumers' opt-out rights).

These recipients include:

• Financial institutions, such as banks, credit card companies and brokerage houses;
• Companies that process transactions or provide other services for us;
• Government agencies; and
• In addition, under United States law ChucKlein is permitted to disclose customer information to certain recipients, like credit reporting.

Protecting the Confidentiality of Personal Consumer Information

ChucKlein limits access to personal information to those employees of ChucKlein and its affiliates who need it to fulfill their business responsibilities. Employees must adhere to ChucKlein privacy policies. Employees violating these policies may be subject to disciplinary action, up to and including dismissal. Vendors and other outside contractors we engage are subject to our contractual requirements to ensure that sensitive personal information is safeguarded.

Security Safeguards

At ChucKlein, security is a priority. We employ appropriate measures to protect consumer information against unauthorized access, disclosure, alteration or destruction. These may include, among others, encryption, physical access security and other appropriate technologies. ChucKlein continually reviews and enhances its security systems, as necessary.

Procedures to Assure the Quality of Information Collected

ChucKlein employs appropriate measures to assure the quality of information we collect directly from consumers. Where ChucKlein collects information directly from consumers or sources other than our business customers, we permit them, if possible, to dispute or correct any erroneous or out-of-date personally identifiable information. Of course, this correction would not be possible if the information is proprietary to one of our business customers, reflects historical transaction information or if correction would violate the privacy or legal rights of a third party. Where applicable, we abide by laws related to such information. You can correct factual errors in your personally identifiable information by sending us a written request that credibly shows error. We reserve the right to independently verify claims made. To protect your privacy and security, we also will take reasonable steps to verify your identity before making corrections. We reserve the right to assess a service charge for providing you any information in connection with your request.

Children's Guidelines

ChucKlein is committed to complying with the provisions of the Children's Online Privacy Protection Act of 1998 and the Rules and Regulations made pursuant thereto. Our web site is not directed at children under the age of 13 and we do not knowingly collect or maintain information at our web site from those who are under the age of 13. If we learn that we have personal information on a child under the age of 13, we will delete that information from our systems.

Links

ChucKlein may create links to third party web sites. ChucKlein is not responsible for the content or privacy practices employed by web sites that are linked from our web site. "Clicking" on a banner advertisement or another type of link contained on our site, may result in you leaving our site and your browser being redirected to a web site owned and controlled by a third party. ChucKlein has no control over these sites and accepts no responsibility for the content of these sites or the actions of the operators in relation to the collection of personal information of users of these sites.

While ChucKlein makes every effort to protect your personal information and your privacy, we cannot guarantee the security of any information you disclose online and you do so at your own risk. Please keep in mind that whenever you give out personal information online, that information can be collected and used by people that neither you nor we know.

Contact Us

If you have any questions or indeed comments about our Online Privacy Statement, or for some reason believe we have not adhered to our statement, please contact: Customer Service

Effective Date December, 2004