This privacy policy covers the site www.InternalMatters.com and InternalMatters.com ("The Websites").

Because Internal Matters, Inc. ("Internal Matters, Inc.") wants to demonstrate its commitment to respecting the privacy of our Website users ("Users") we wish to convey how we collect, handle, archive and use the Personal Information as well as the Non-Personal Information provided by Users.

Internal Matters, Inc. has produced this Privacy Policy with respect to the privacy principles in Schedule 1 of the "Personal Information Protection and Electronic Documents Act" ("Act") of Canada.

The European Commission recognizes that the Act meets the demands of the "European Union's Data Protection Directive" and provides protection for personal information transferred between Canada and the EU.

The United States through the U.S. Department of Commerce has developed the "International Safe Harbor Privacy Principles" which are designed to satisfy the requirements of Article 25 of the EU Directive. Qualification by U.S. businesses and organizations is entirely voluntary.

Whether Users are from the United States, the European Union, or Canada they can be confident knowing that Internal Matters, Inc. meets or exceeds the personal information protection requirements of these seventeen countries and many others that have enacted similar acts.

Definition of Personal Information

"Personal Information" means information about an identifiable individual.

Personal Information does not include the name, title, business address or telephone number of any employee of any organization. Anything that might appear on your business card, or can be found through publicly available information such as the telephone book is not considered Personal Information.

Examples of a specific individual's Personal Information include:

• credit card or bank account numbers
• ID numbers such as social security or social insurance number, health card or benefit plan numbers
• image, weight, height
• medical records; income, ethnic origin or blood type
• opinions, evaluations, comments, social status or disciplinary action
• employee files, credit records or loan records

Because Internal Matters, Inc. limits its business activities to selling software and service solutions to business customers (not private persons) it collects very little Personal Information.

Aside from corporate bank account, credit card and/or credit reference information, Internal Matters, Inc. may be required to collect Personal Information such as home address or home telephone number if a personal credit card is used to purchase a Internal Matters, Inc. product or service on behalf of a corporate entity. Personal Information does not include information such as web analytics data for The Websites that is collected anonymously without identifying specific individuals or website Users, nor demographic information that does not directly link Personal Information of individuals or website Users.

Management of the Internal Matters, Inc. Privacy Policy

Accountability for compliance with this Privacy Policy rests with Internal Matters, Inc. Chief Operating Officer, Chris Caouette.

If a User has questions or concerns regarding this Privacy Policy, they may contact our Chief Operating Officer by facsimile transmission 401-490-3884, or by registered mail addressed, Attention, Chief Operating Officer, using Internal Matters, Inc.s' current contact information on this web site.

Other individuals within Internal Matters, Inc. are responsible for the day-to-day collection and processing of Personal Information, and from time to time other individuals within our organization may be delegated to act on behalf of our Chief Privacy Officer with respect to Personal Information.

Users can address and send a challenge concerning Internal Matters, Inc.'s compliance with this Privacy Policy to our chief privacy officer. All written privacy complaints received by facsimile transmission or registered mail will be reviewed, considered, and investigated. Please include your name, company name, company address, and/or email address when you contact us. If we find the complaint to be justified, we will take such action as is appropriate to comply with the Privacy Policy.

Internal Matters, Inc. is responsible for any Personal Information under its control, including Personal Information that Internal Matters, Inc. may transfer to a third party for processing. Internal Matters, Inc. will use contractual or other means to provide a comparable level of privacy protection should Personal Information be processed by a third party on Internal Matters, Inc.'s behalf.

Protection of Children's Information Online

If you are under thirteen years of age do not submit your personally identifiable information to Internal Matters, Inc. and do not register for any services offered on The Websites.

Internal Matters, Inc. products and services are not directed or intended for children under thirteen years of age. Internal Matters, Inc. limits its business activities to selling software and service solutions to business customers. It is not Internal Matters, Inc.'s policy to knowingly collect personally identifiable information from persons under thirteen years of age.

If you are the parent or guardian of a person under the age of thirteen whom you believe has disclosed personally identifiable information to Internal Matters, Inc., please contact Internal Matters, Inc.'s Privacy Officer outlined herein, so that Internal Matters, Inc. may delete and remove such person's information from our systems.

Consent, Collection, Use, and Disclosure of Personal Information

Consent, collection, use and disclosure of Personal Information by Internal Matters, Inc. are limited to Internal Matters, Inc.'s business, which a reasonable person would consider appropriate in the circumstances. These activities include, selling Internal Matters, Inc. solutions to business customers, servicing those customers, and processing job applications posted through The Websites.

Selling and Servicing Internal Matters, Inc. Software and Service Solutions

Internal Matters, Inc. limits its business activities to selling software and service solutions to business customers, it collects sensitive information required to enter into sales agreements and to sell and license Internal Matters, Inc. products and services. This includes corporate credit card and/or credit reference information.

Occasionally Personal Information may be collected when a personal credit card is used to purchase a Internal Matters, Inc. product or service on behalf of a corporate entity such as the credit card holder's home address and telephone number.

Internal Matters, Inc. obtains consent to collect and use any such Personal Information Users provide in person or over the telephone. Users may also give consent expressly by completing and submitting an order form to Internal Matters, Inc. by mail, by facsimile transmission, by e-mail, or through The Websites.

Internal Matters, Inc. may disclose certain Personal Information and/or sensitive information to trusted financial institutions such as credit card companies and banking institutions. Internal Matters, Inc. may also disclose Personal Information to credit bureaus and/or credit references in order to establish customer accounts and process credit applications.

In accordance with the User's wishes, Internal Matters, Inc. may use Personal Information to communicate via email or phone with potential customers and existing customers in order to provide services and product support regarding issues relating to their account.

Job Applicants

Internal Matters, Inc. collects and uses Personal Information submitted through The Websites to recruit, interview and assess prospective employees.

Internal Matters, Inc. will limit disclosure of information strictly to the name of the applicant when contacting work or personal references listed by the job applicant within their resume or curriculum vitae. Internal Matters, Inc. does not retain job applicant information electronically beyond six months.

By submitting their resume or curriculum vitae to Internal Matters, Inc., whether by mail, facsimile transmission, e-mail or through The Websites, the User expressly gives consent to the use of their Personal Information described herein.

Internal Matters, Inc. Does Not Sell Personal Information

Internal Matters, Inc. does not sell, distribute or trade Personal Information, nor does Internal Matters, Inc. use outside parties to collect information on our behalf.

Disclosure of Personal Information Not Previously Identified

If Internal Matters, Inc. plans to use or disclose Personal Information, which it has collected for a purpose not previously identified, Internal Matters, Inc. will identify and document this purpose. Internal Matters, Inc. will make a reasonable effort to specify the new purpose, either orally, in writing, by e-mail, or by electronic means, to the User from whom the Personal Information was collected before such new use or disclosure. Internal Matters, Inc. will state the new purpose in such a manner that an individual can reasonably understand how the Personal Information will be used or disclosed.

Disclosure of Personal Information as Required by Law

In certain circumstances, such as when required by law, Internal Matters, Inc. may disclose Personal Information without the knowledge or consent of the individual. These circumstances include situations where; it is disclosed to a government institution or investigative body in accordance with the provisions of the Personal Information Protection and Electronic Documents Act; it is necessary to comply with a subpoena, warrant, or court order made to compel production of records or to comply with the rules of the court relating to such production; the Personal Information is disclosed to a lawyer representing Internal Matters, Inc.; it is disclosed for the purpose of collecting a debt.

Collection, Use, and Disclosure of Non-Personal Information

Internal Matters, Inc. collects non-personal information for a number of reasons including, researching and developing web analytics solutions, plus marketing and selling Internal Matters, Inc. products. The collection, use and disclosure of non-personal information by Internal Matters, Inc. are limited to Internal Matters, Inc.'s business.

Internal Matters, Inc. limits collection, use and disclosure of information provided by business customers to non-personal information, other than for those purposes identified in the section titled, "Consent, Collection, Use, and Disclosure of Personal Information".

To help prevent collection of personally identifiable information on The Websites, data entry forms require that a company name be entered into the "Company Name" field. If no company name is entered, the User will be unable to submit information. Thereby helping Internal Matters, Inc. limit collection to non-personal information such as it would appear on the Users corporate business card.

Should information be collected, in person, over the telephone, by mail, facsimile transmission or e-mail, Internal Matters, Inc. will make a reasonable attempt to establish that the information relates to a company, business, organization or public entity.

Requesting a Trial Version of the Internal Matters, Inc. IM Commerce Service or Internal Matters, Inc. Software

If a User requests a trial version of the Internal Matters, Inc. IM Commerce Service, LiveSTATS Log Analyzer, or Internal Matters, Inc. Software, we require non-personal contact information such as name, company name, telephone number, business and email address; as it would appear on the User's corporate business card.

Users who request a trial version of Internal Matters, Inc.'s Software products will be contacted by email or telephone during and around the end of the trial period. These courtesy calls are intended to address any technical or sales questions the User might have.

Users who request a trial version of Internal Matters, Inc.'s IM Commerce service or software solutions will be contacted regularly throughout the trial period in order to carry out configuration of the Service, set up marketing reports for their website and to address any technical or sales questions the User might have.

Non-Personal contact information will be entered into the Internal Matters, Inc. Customer Resource Management ("CRM ") solution, which is used to manage and track potential and existing customers. Once entered into the Internal Matters, Inc. CRM solution, contacts will receive correspondence on occasion using the email address, phone number or mailing address provided in the request form. Reasons for Internal Matters, Inc. to contact Users include, new product announcements, upgrades, updates, service alerts, and special offers.

Internal Matters, Inc. provides a method for Users to opt-out of these communications once the trial period is complete. Please refer to the section titled Choice and Opt-out.

White Papers, Special Offers and Promotions

From time-to-time Internal Matters, Inc. may use The Websites to offer White Papers, Special Offers and Promotions. In order to access special offers and features, Users may be asked to provide non-personal contact information such as name, company name, telephone number, business and email address; as it would appear on the User's corporate business card.

Non-personal contact information will be entered into the Internal Matters, Inc. CRM solution, which is used to manage and track potential and existing customers. Users will receive correspondence on occasion using the email address, phone number or mailing address provided in the request form. Reasons for correspondence include, new product announcements, updates, press releases and special offers.

Internal Matters, Inc. provides a method for Users to opt-out of these communications. Please refer to the section titled Choice and Opt-out.

Newsletter

Users may subscribe to the Internal Matters, Inc. newsletter by providing non-personal contact information such as name, company name and email address; as it would appear on the User's corporate business card.

Non-personal contact information will be entered into the Internal Matters, Inc. CRM solution and list server. Users will receive scheduled newsletter correspondence.

Internal Matters, Inc. provides a method for Users to opt-out of these communications. Please refer to the section titled Choice and Opt-out.

Web Analytics Technology used on The Websites

LiveSTATS Log Analyzer Technology:

Internal Matters, Inc. uses LiveSTATS Log Analyzer, which it uses to analyze web server log files generated by The Websites. This includes Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referrers, entry pages, exit pages, navigation paths, operating system type, date & time stamp and geographic reports.

Log file data is not linked to personally identifiable information such as a persons name, place of residence, phone number or personal email address.

Log files record anonymous information in the aggregate such as most used site navigation paths and broad demographic information. Internal Matters, Inc. uses this insight to improve The Websites, test and improve Internal Matters, Inc. Web Analytics products and generally enable us to provide the best possible website experience for our Users.

The Who's On report and Geo-corporate reports retrieve the company name or service provider to whom the IP address is registered, and the Country, State or Province of the registrant; these reports do not link personally identifiable information.

Internal Matters, Inc. may retain log file data and anonymous statistical information indefinitely for statistical analysis and research purposes.

Internal Matters, Inc. may retain web analytics data and statistical information indefinitely for statistical analysis and research purposes.

External Links from The Websites

The Websites contains external links to other corporate websites. Please be aware that Internal Matters, Inc. is not responsible for the privacy practices of these other websites. Therefore Users are encouraged to read and understand the privacy statements of the external websites linked from The Websites.

Cookies

Cookies are a standard technology that installs a small text file on a visitors hard drive to assist the website to recognize future visits by that web browser. Cookies are often used to enhance the convenience and usability of a website, saving visitors time by not having to enter the same information repeatedly. For example, cookies are used on websites that personalize pages, or to track preferences and register download information.

Opt-out of Non-Personal Information

Newsletters: Potential customers, contacts and existing customers who no longer wish to receive our newsletter and promotional communications may opt-out by replying to unsubscribe in the subject line of the email or by emailing us at info@InternalMatters.com. Alternately Internal Matters, Inc. may be contacted by telephone at (401) 490-3884.

All Communications: Internal Matters, Inc. customers and potential customers are given the opportunity to 'opt-out' of all email communications by emailing us at info@InternalMatters.com. Certain implications and limitations may apply to customers who withdraw our ability to notify them of service related announcements and/or product updates or bulletins.

Web Analytics: Users can set their browser to notify when a cookie is received, giving them an opportunity to accept or reject the cookie. In addition Users may choose to disable the "cookies" option on their web browser; however doing so may affect use of websites on the Internet that utilize cookies.

Sale by Internal Matters, Inc. of Non-Personal Information

Internal Matters, Inc. does not sell or trade contact information that is collected from request forms on The Websites, nor does Internal Matters, Inc. use outside parties to collect information on our behalf.

Internal Matters, Inc. will use contractual or other means to provide a comparable level of privacy protection should non-personally identifiable information be processed by a third party on Internal Matters, Inc.'s behalf. Specifically such companies will not be entitled to retain, share, store or use information for any secondary purposes.

Limiting Collection, Use, Disclosure and Retention of Personal Information

Internal Matters, Inc. will limit its collection of Personal Information to the amount and type of Personal Information, which it needs for the purposes identified herein. Internal Matters, Inc. will only collect Personal Information by fair and lawful means.

Personal information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law.

Internal Matters, Inc. will retain Personal Information only as long as is necessary for the fulfillment of the purposes for which it was collected identified herein. Where Personal Information is no longer required to fulfill the purposes identified herein it will be destroyed, erased or made anonymous.

Business Transitions

In the event that Internal Matters, Inc. goes through a business transition, such as a merger, being acquired by another company or selling a portion of its assets, User's personal information will, in most instances, be part of the assets transferred.

Security Procedures to Protect Personal Information

Internal Matters, Inc. will use safeguards designed to protect Personal Information under its control against loss or theft, as well as against unauthorized access, disclosure, copying, use, or modification, regardless of the format in which the Personal Information is held. For example, Internal Matters, Inc.:

• limits access to Personal Information under its control to those officers and employees which have a need to know such information for the purposes it was collected
• uses physical, electronic, and procedural safeguards to protect Personal Information
• uses industry-standard SSL encryption to protect Personal Information supplied to it through its website (for more information refer to http://www.InternalMatters.com
• ensures that access to each customer account by its employees is password protected

All Personal Information that Internal Matters, Inc. collects is stored and processed on computers located at the Internal Matters, Inc. headquarters.

Openness, Accuracy and Individual Access to Personal Information

Internal Matters, Inc. will make information relating to our Privacy Policy available, how it is implemented within Internal Matters, Inc., what steps we take to ensure that our employees follow the Privacy Principles, how to contact our Chief Privacy Officer, and how to initiate a challenge concerning any Personal Information regarding a User by that User that may be within our protection.

Internal Matters, Inc. will use its best efforts to ensure that Personal Information under its control is accurate, complete, and up-to-date as is necessary for the purposes for which it is used. The extent to which Internal Matters, Inc. will ensure that such Personal Information will be accurate, complete and up-to-date will be dependant on how that Personal Information will be used, taking into account the interests of the User.

Upon written request by a User, Internal Matters, Inc. will disclose whether it has Personal Information regarding that User under its control, as well as how its used and disclosed. Internal Matters, Inc. will respond within a reasonable period of time (generally within 30 calendar days), subject to the User providing sufficient and accurate information, which Internal Matters, Inc. requires to determine the existence of the User's Personal Information under its control.

While Internal Matters, Inc.'s response may be provided at no cost to the User, Internal Matters, Inc. reserves the right, depending on the nature of the request and the Personal Information involved, to charge the User for its costs to process each request, and those costs must be paid in advance of processing the request.

Should Internal Matters, Inc. provide an account of third parties to which it may have disclosed Personal Information, it will attempt to be as reasonably specific as possible in the circumstances.

Should it be demonstrated to Internal Matters, Inc. that the Personal Information under its control is inaccurate or incomplete, Internal Matters, Inc. will update the Personal Information to the extent more accurate Personal Information is provided. If the challenge is not resolved to the satisfaction of the User, Internal Matters, Inc. will document and record the substance of the unresolved challenge.

Internal Matters, Inc. may refuse a request or a challenge or not be able to provide access to the Personal Information under its control. These exceptions will be limited to those permitted or required by law. Where permitted, the reasons for such refusal will be provided to the User upon request. For example, such reasons may include that the information:

• is prohibitively costly to provide, or contains references to other individuals
• cannot be disclosed for legal, security or commercial proprietary reasons
• is subject to solicitor-client or attorney client privilege
• was collected in the course of an investigation, or
• pertains to a dispute or pending or actual litigation or arbitration

Changes to this Privacy Policy

Internal Matters, Inc. may amend any or all of the provisions of this Privacy Policy, or post a new Privacy Policy in place of this one, at any time or times without prior notice to any party.

In addition, if we make any material changes in our Privacy Policy that affects user information already stored in the Internal Matters, Inc. CRM solution we will notify Users of the change by email.