InfoGenius, Inc. ("InfoGenius") knows that you may be concerned about your privacy. In general, we use the information collect on our websites only to process orders and subscriptions and to enhance our customer service. This privacy policy describes how we collect and use information at www.elayer.com and its related websites manager.elayer.com and centralpass.elayer.com and describes the circumstance in which we may share such information with third parties. If you have questions about our policy, please contact us at InfoGenius, Inc., Attn: Legal Department P.O. Box 90550, Allentown, PA 18109 or @elayer.com.

INFORMATION COLLECTION

USER REGISTRATION: To take advantage of our special services, a user may create an Account and become an Account Holder by completing the registration form. During registration a user is required to give contact information (such as name and email address). We use this information to contact the Account Holder about services for which he or she has expressed interest. In the event a user does not create an Account, we may collect information about a user's use of our websites as described below, but such information will not include personal information, such as the user's name and address.

ORDERS: We request information from the Account Holder on our service billing forms. An Account Holder must provide contact information (such as name, email, and mailing address) and financial information (such as credit card number, expiration date). This information is used for billing purposes and to fill Account Holder's orders. If we have trouble processing an order, the information is used to contact the Account Holder.

SURVEYS & CONTESTS: From time-to-time our site requests information from users and/or Account Holders via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose this information. The requested information typically includes contact information (such as name and shipping address), and demographic information (such as zip code). Contact information will be used to notify the winners and award prizes. Demographic information will be used for purposes of monitoring or improving the use and satisfaction of this site. Users' personally identifiable information is not shared with third parties unless we give prior notice and choice. Though we may use an intermediary to conduct these surveys or contests, they may not use personal information about our users for any secondary purposes.

A SPECIAL NOTE ABOUT CHILDREN: InfoGenius will not knowingly accept personal information from children under 16. We ask that children do not submit any personal information to us. If you are a child, you may not register with us. If you live in a country or area that has additional restrictions on Internet use by minors, we ask that you abide by those restrictions.

THIRD PARTY ADVERTISING: Some of the ads appearing on InfoGenius sites are delivered by third parties. Information about users' visit to the site, such as number of times they have viewed an ad (but not user name, address, or other personal information), is used to serve ads to users on this site. If you "right click" with your mouse on an ad on our site and select properties, you can see the URL for the advertiser that serves that ad.

STORAGE OF, AND SECURITY FOR, PERSONAL INFORMATION

COOKIES: A cookie is a piece of data stored on the user's computer. For users or Account Holders that have registered with InfoGenius, cookies are linked to information about the user or Account Holder while on our site. We use both session ID cookies and persistent cookies. For the session ID cookie, once users close the browser, the cookie simply terminates. A persistent cookie is a small text file stored on the user's hard drive for an extended period of time. Persistent cookies can be removed by following Internet browser help file directions. Users do not need to accept cookies to browse our sites. However, to take advantage of our special Services, such as email updates or newsletters, users must accept cookies. Some of our business partners use cookies on our site (for example, advertisers). However, we have no access to or control over these cookies, once we have given permission for them to set cookies. This privacy statement covers the use of cookies by InfoGenius only and does not cover the use of cookies by any business partner.

CLEAR GIFS: InfoGenius sometimes employs a software technology called clear gifs, that help us better manage content on our site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track web site usage. If a user or Account Holder submits personally identifying information to InfoGenius, the information from clear gifs may be linked with the personally identifying information. Third parties advertising on InfoGenius websites may also use clear gifs. While these gifs are used in the same way that InfoGenius uses them, they will not be linked to personal information that you have submitted to InfoGenius.

PROFILE: We store information that we collect through cookies, log files, and clear gifs to create a profile of our users. A profile is stored information that we keep on individual users that details their viewing preference and enables us to provide offers to, and improve the content of the site for, the user. This profile is used to tailor a user's visit to our Website and to direct pertinent promotions to them.

LOG FILES: Like most standard Web site servers we use log files. This includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks to analyze trends, administer the site, track user's movement in the aggregate, and gather broad demographic information for aggregate use.

SECURITY DURING TRANSMISSION OF PERSONAL INFORMATION: When our order form asks users to enter sensitive information (such as credit card number and/or social security number), that information is encrypted and is protected with the best encryption software in the industry - SSL. While on a secure page, such as our order form, the lock icon on the bottom of Web browsers such as Netscape Navigator and Microsoft Internet Explorer becomes locked, as opposed to un-locked, or open, when users are just ‘surfing'.

SECURITY FOR STORED INFORMATION: While we use SSL encryption to protect sensitive information online, we also do everything in our power to protect user-information off-line. All of our users' and Account Holder's information, not just the sensitive information mentioned above, is password protected. Only employees who need the information to perform a specific job (for example, our billing clerk or a customer service representative) are granted access to personally identifiable information. All employees are kept up-to-date on our security and privacy practices. Finally, the servers used to store personal information are maintained in a locked facility.

OUR USES OF PERSONAL INFORMATION

NEWSLETTER: If a user wishes to subscribe to our newsletters, we ask for contact information such as name and email address. Out of respect for our users privacy we provide a way to discontinue newsletter subscription. See below.

SERVICE ANNOUNCEMENTS: On rare occasions it is necessary to send out a strictly service related announcement. For instance, if our service is temporarily suspended for maintenance we might send users an email. Generally, users may not opt-out of these communications, though they can deactivate their account. However, these communications are not promotional in nature.

CUSTOMER SERVICE: We communicate with users and Account Holders on a regular basis to provide requested services and in regards to issues relating to their account. Account Holders may occasionally receive information on products, services, and special deals.

SHARING YOUR INFORMATION

THIRD PARTIES: Except as stated in this policy, InfoGenius will not sell or share information about you, such as your email address, without your express consent.

AGGREGATED INFORMATION: We share aggregated demographic information with our partners and advertisers. We do this for marketing and promotional purposes. The aggregate information that we share is not linked to any information that identifies particular users.

CREDIT CARD PROCESSING: We use a credit card processing company to bill users for services. This processing company is not permitted to retain, share, store or use personal information about users for any purposes other than credit card processing.

BUSINESS TRANSITIONS: In the event InfoGenius goes through a business transition, such as a merger, being acquired by another company, or selling a portion of its assets, Account Holders' and users' personal information will, in most instances, be part of the assets transferred. Account Holders will be notified via a prominent notice on our Web site for 30 days prior to a change of ownership or control of their personal information. If as a result of the business transition, the users' or Account Holders personally identifiable information will be used in a manner different from that stated at the time of collection they will be given choice consistent with our notification of changes section.

LEGAL REQUESTS: We may need to disclose information about users and Account Holders when required to comply with a current judicial proceeding, a court order or legal process served on our websites.

OPTIONS FOR USERS TO LIMIT USE OF PERSONAL INFORMATION: Our users and Account Holders are given the opportunity to ‘opt-out' of having their information used for purposes not directly related to our site at the point where we ask for information. Users or Account Holders who do not wish to receive our newsletters may opt-out of receiving these communications by selecting UNSUBSCRIBE in the NEWSLETTER section of our sites. Users of our site are always notified when information sent to our site will be provided to, or collected by, an outside party. We do this so our users can make an informed choice as to whether or not to proceed with such services.

OTHER TERMS

CHANGING YOUR PERSONALLY IDENTIFIABLE INFORMATION: At your request, we will change or deactivate your account, contact information, billing information, and financial information from our active databases. To make this request, email [email protected]. Such information will be changed or deactivated as soon as reasonably possible based on your account activity and in accordance with our deactivation policy and applicable law. You must promptly update your information with us if it changes. We will retain in our files information you have requested to remove in some circumstances, such as to resolve disputes, troubleshoot problems and enforce our User Agreement. Furthermore, such prior information is never completely removed from our databases due to technical and legal constraints, including stored "back up" systems. Therefore, you should not expect that all information about you will be completely removed from our databases in response to your requests.

LINKS: This Web site contains links to other sites. Please be aware that InfoGenius is not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of each and every Web site that collects personally identifying information. This privacy policy applies solely to information collected by this InfoGenius websites.

CHANGES TO OUR PRIVACY POLICY: We may change our privacy policy. We will post any changes to this privacy statement so our users are always aware of what information we collect, how we use it, and under what circumstances we share it. We will attempt to use information only in accordance with the privacy policy under which the information was collected. If we make any material changes in our privacy practices, we will post the updated privacy policy on our Web site, which shall serve as the sole notice to users and Account Holders of the change. Continued use of our website and services shall constitute your acceptance of the change to our privacy policy.