PanOptica Privacy Policy and Statement

1. Introduction.

PanOptica, Inc. (“us,” “we,” or “PanOptica”) is committed to respecting the privacy rights of our visitors, and other users of the PanOptica site and services (“Services”) provided via the PanOptica website (collectively, the “Site”). We created this Privacy Policy to give you confidence as you visit and use the Site, and to demonstrate our commitment to fair information practices and the protection of privacy. This Privacy Policy is only applicable to the Site, and not to any other websites that you may be able to access from the Site, each of which may have data collection, storage, and use practices and policies that differ materially from this Privacy Policy. Your use of the Site is governed by this Privacy Policy and the Legal Terms and Conditions of Use.

2. Traffic Data Collected.

We automatically track and collect the following categories of information when you visit our Site:

(1) IP addresses; (2) domain servers; (3) types of computers accessing the Site; (4) types of web browsers used to access the Site; (5) referring source which may have sent you to the Site; and (6) other information associated with the interaction of your browser and the Site (collectively “Traffic Data”). We may collect other Traffic Data in the future, as new technologies are implemented.

3. Cookies.

This Site may use a technology called a “cookie.” A cookie is a piece of information that our web server sends to your computer (actually to your browser file) when you access a website. Then when you come back to our Site, our Site will detect whether you have one of our cookies on your computer. Our cookies help provide additional functionality to the Site and help us analyze Site usage more accurately. For instance, our Site may set a cookie on your browser that keeps you from needing to remember and then enter a username and/or password more than once during a visit to the Site. With most browsers, you can erase cookies from your computer hard drive, block all cookies or receive a warning before a cookie is stored. Please refer to your browser instructions or help screen to learn more about these functions.

4. Web Beacons.

We make also may make use of web beacons (clear GIFs) to gather information when you visit our Site or read and interact with our newsletter and promotional emails. We may also use beacons to gather and compile such information about you when you return to our Site so that we may better customize our services and information for you.

5. Internet Protocol Address and Clickstream.

This Site uses Internet Protocol (IP) Addresses. An IP Address is a number assigned to your computer by your Internet service provider so you can access the Internet. Generally, an IP address changes each time you connect to the Internet (it is a “dynamic” address). Note, however, that if you have a broadband connection (e.g., DSL or cable), depending on your individual circumstance, it is possible that your IP Address that we collect, or even perhaps a cookie we use, may contain information that could be deemed identifiable. This is because with some broadband connections your IP Address doesn’t change (it is “static”) and could be associated with your personal computer. We use your IP Address to report aggregate information on use of and to help improve the Site. A “clickstream” or “clickstream data” reflect the specific web pages visited by an individual user, and, importantly, the manner or traffic pattern by which a user moves from one web page to another. We track such information only within our Site and do not track any clickstream activity outside of the PanOptica Site.

6. Personal Information Collected.

Through this Site, we do not automatically capture and store personal information other than logging certain user and website usage information, deemed non-personal information. However, PanOptica will collect personal information that can identify you, such as your name, address, telephone number, e-mail address, and other similar information (“Personal Information”) when it is voluntarily submitted to us. We may use Personal Information for the following, unless stated otherwise:

* We may store and process that information to better understand your needs and how we can improve our products and services;
* we, or a third party on our behalf, may use that information to contact you;
* we may provide third parties with summary, but not individual, information about visitors to or users of our Site;
* we may use the information to respond to queries and requests submitted by you;
* we may provide the information to other offices to enable them to send you information which may be of interest to you or which may have been requested by you; and
* we may use the information to contact you and/or provide you with general health information (like information on certain health conditions) as well as information about our products and services.

If you communicate with us by, for example, e-mail or letter, any information provided in such communication may be collected as Personal Information. You may choose not to provide us with any or certain items of Personal Information. In such case, you can still access and use much of the Site; however you will not be able to access and use those portions of the Site that require the Personal Information you have chosen not to submit. If you do not want your Personal Information to be collected, please do not submit it to us.

7. Non-Personal Information

Any other information transferred by you in connection with your visit to this Site (“Non- Personal Information” or, information that cannot be used to identify you) may be included in databases owned and maintained by PanOptica or its agents and may be used for system administration and to provide statistics which PanOptica may use to evaluate use and efficiency of service of the Site. PanOptica retains all rights to these databases and the information contained in them however we may from time to time supply third parties with Non-Personal Information or aggregated information for uses in connection with this Site. Non-Personal Information we collect may include your IP Address and other information gathered through our web logs, beacons and cookies.

8. The Privacy of Children.

This Site is not intended for children under the age of 18. We do not knowingly collect personally identifiable information online from visitors in this age group. If you are under 18 years of age, please do not send us your Personal Information (for example, name, address, email address). If you are under 18 years of age and wish to ask a question or use this Site in any way that requires you to submit your Personal Information, please ask a parent or guardian to do so on your behalf.

9. Security of Personal Information.

Although we make good faith efforts to store Personal Information in a secure operating environment that is not open to the public, you should understand that there is no such thing as complete security, and we do not guarantee that there will be no unintended disclosures of your Personal Information. If we become aware that your Personal Information has been disclosed in a manner not in accordance with this Privacy Policy, we may, but are not required to, try to notify you of the nature and extent of the disclosure (to the extent we know that information) as soon as reasonably possible and as permitted by law.

We may share Personal Information with agents, contractors or partners of PanOptica in connection with services that these individuals or entities perform for, or with, PanOptica. These agents, contractors or partners are restricted from using this data in any way other than to provide services for PanOptica, or services for the collaboration in which they and PanOptica are engaged (for example, some of our products are developed and marketed through joint agreements with other companies). We may, for example, provide Personal Information to agents, contractors or partners for hosting our databases, for data processing services, or so that they can mail you information that you requested.

10. Transfer of Information.

PanOptica’s executive offices are located in the US and therefore use of this Site by non-US users will involve transmission of information and personal data from your country or domicile to the US. In relation to European Union (EU) users, countries outside the EU, including the US, may not have similar data protection laws to the EU. If information is transferred from the EU or other countries to the US, we will take steps to ensure that your privacy rights continue to be protected.

Except as set out in this Privacy Policy, we will not disclose any Personal Information without your permission unless we are legally entitled or required to do so, for example, PanOptica reserves the right to share Personal Information to respond to duly authorized information requests of governmental authorities or where required by law. In addition, PanOptica will use any information supplied necessary in connection with adverse events reporting. In exceptionally rare circumstances where national, state or company security is at issue (such as with the World Trade Center terrorist act in September, 2001), PanOptica reserves the right to share our entire database of visitors and customers with appropriate governmental authorities. Additionally, where we believe that such disclosure is necessary to protect and/or defend our rights, property or safety and those of our users, customers and other interested parties, we reserve the right to disclose such information. We may also provide Personal Information to a third party in connection with the sale, assignment, or other transfer of the business of this Site to which the information relates, in which case we will require any such buyer to agree to treat Personal Information in accordance with this Privacy Policy.

As a convenience to our visitors, this Site currently contains links to a number of sites that we believe may offer useful information. The policies and procedures we describe here do not apply to those sites. We suggest contacting those sites directly for information on their privacy, security, data collection, and distribution policies. PanOptica is not responsible for the data collection, use practices or content found on the third party sites of merchants and other companies to which the Site may link, nor are we responsible for the data collection and use practices of those sites that link to the Site.

In relation to retention of information collected through this Site, we intend to keep such information in accordance with our retention policy. If you wish us to stop using your Personal Information for any or all of the purposes detailed or to be removed from our contact lists, please write to PanOptica at the address at the end of this Privacy Policy.

11. What Does This Privacy Policy Cover?

This Privacy Policy only covers the PanOptica Site (www.PanOptica.com). Other links within this Site to other websites are not covered by this Privacy Policy and users should review the privacy policy and any terms and conditions of such websites. PanOptica takes no responsibility or liability for any information, services or participation by you in such websites even if you accessed the third party website using links from the PanOptica Site or you linked to the PanOptica Site from a third party website. Nonetheless, PanOptica seeks to protect the integrity of its Site and the links placed on it and therefore requests any feedback, not only on this Site but also for websites it links to.

12. Updating This Privacy Policy.

We may update this Privacy Policy from time to time, including the way in which we may use your information. When we do update it, for your convenience, we will make the updated policy available on this page. Your continued use of the Site after changes have been made to this Privacy Policy will indicate your assent to the changes; therefore, you should refer back to this Privacy Policy from time to time.

13. Consent.

By using the Site, you signify your agreement to the terms and conditions of this Privacy Policy. If you do not agree to these terms and conditions, please do not disclose any Personal Information to the Sites. If you have any questions or comments about our use of Personal Information or about this Privacy Policy, please contact us via this Site or at the address listed above. PanOptica will use reasonable efforts to promptly investigate any complaint you may have regarding our use of Personal Information and to comply fully with the legal and regulatory supervisory authorities responsible for enforcing our adherence to the privacy principles stated above.

14. Contact Us.

If you have questions about this policy or PanOptica’s information collection, use, and disclosure practices, you may contact us at PanOptica, Inc., 13 McGregor Avenue, Mount Arlington, NJ 07856.

When you contact us, please note the name of the website or other online resource to which you inquiring, as well as the nature of the information about which you are inquiring. We will use reasonable efforts to respond promptly to requests, questions or concerns you may have regarding our use of personal information about you. Except where required by law, PanOptica cannot ensure a response to questions or comments regarding topics unrelated to this policy or PanOptica’s privacy practices.

Updated August 27, 2009.