PRIVACY POLICY

GROUPGAIN INC., (GroupGain) is the sole owner of the information collected on this site. We will not sell, share, or rent this information to others in ways different from what is disclosed in this statement. You should be aware that the process of maintaining a web site is an evolving one, and this policy will be assessed on an ongoing basis against new technologies, business practices, and our customers needs. We reserve the right to change, modify, or amend this policy at any time. This privacy policy is incorporated into and subject to GroupGain's Terms and Conditions.

Children's Privacy

GroupGain does not intentionally collect personal information about children under the age of 13. If you are under the age of 18 but at least 13 years of age, you may use this web site only under the supervision of a parent or legal guardian who agrees to be bound the GroupGain's Terms and Conditions of Use. Children under the age of 13 may not use this web site and parents or legal guardians may not agree to GroupGain's Terms and Conditions on their behalf. If you do not agree to (or cannot comply with) any of GroupGain's Terms and Conditions, do not use this web site.

What Information Do We Collect?

GroupGain's goal is to provide you with the information and products and services that are most relevant to you. To achieve this goal, we collect two types of information from you when you visit our web site: personally identifiable information you voluntarily choose to disclose and aggregate information about your use of our web site that is automatically collected when you visit our web site.

Personal Information You Choose to Provide

Personally identifiable information refers to information that tells us specifically who you are. We collect personal information from you when you voluntarily choose to choose to become a member of GroupGain or when you participate in an auction as a buyer of seller. In this connection, you may be asked to provide information such as your name, mailing and current email address, credit card information, and user password. You also decide to provide additional personal information at your option, such as your marital status, household income, education, and employment status. We may ask you to confirm your personal information when you contact our Customer Service department. This will allow us to protect your confidentiality by verifying your identity. Further, if you choose to correspond with us through email, we may retain the content of your email messages together with your email address and our responses.

How We Use Your Personal Information

Broadly speaking, your personal information is used to help us customize the content and layout of our web site so that we may provide you with a smooth and efficient visit. We also use personal information for purposes of administering our business activities, providing customer service, and making available other products and services to our customers and prospective customers. Occasionally, we also may use the information we collect to notify you about important changes to our web site, new services, and special offers we think you will find valuable.

For example, we may use the information we collect on our web site to enhance your shopping experience to:

* Administer your participation in auctions as a buyer or seller
* Register you as a member of GroupGain
* Prevent fraud
* Respond to your customer-service inquiries or requests
* Communicate featured items and special offerings to you
* Customize your shopping experience

When and With Whom We Share Your Personal Information

We do not sell or rent your personal information to any third parties. We will share personal customer information only with our agents, representatives, service providers, contractors, sellers in auctions in which you participated and buyers who participated in you auctions for limited purposes, including fulfilling customer orders; offering certain products and services in connection with this web site; communicating to customers; providing customer service; enhancing and improving customers' shopping experience; enabling access to our partners' web sites; providing a personalized shopping experience; preventing fraud; and completing payment method processing.

GroupGain may offer a number of third party services from our web site. If you choose to use these optional services, we may provide some of your personally identifiable information to the service provider offering such services in order for them to provide the service. Conversely, the service provide may provide GroupGain with personal information about you.

We also may enter into strategic marketing alliances with third parties, such as strategic partners and affiliates, who may be given access to personal information, including your name, address, and email, for the purpose of providing you with information about products and services that may be of interest to you. We evaluate such partners to identify products and services that serve the needs of our members well. We cannot and do not, however, make any representations about the practices and policies of these companies.

Aside from the purposes described above, we will not share your personal information with any other third parties unless we have your express permission or under special circumstances, such as when we believe in good faith that the disclosure is required to prevent harm or injury (such as fraud, claims or other liability) or to comply with valid legal processes (subpoenas, warrants) or as required by law. We also may disclose your personal information in order to investigate network abuse or a violation of any of our Terms and Conditions or other published guidelines, or if you engage in (or are reasonably suspected of engaging in) any illegal activities. We reserve the right to report any suspected illegal activity to law enforcement for investigation or prosecution. We also reserve the right to disclose your information to other parties in the context of a business transaction or contemplated business transaction involving a merger, consolidation, change in management, acquisition by another company, sale of company stock or assets, or similar event. We may share aggregated demographic and statistical information with our partners. This is not linked to any personal information that can identify any individual person.

Aggregate Information

Aggregate information refers to information your computer automatically provides to us and that cannot be tied back to you as a specific individual. Examples include referral data (the web sites you visited just before and just after our site), the pages viewed, time spent at our Web site, and IP (Internet Protocol) addresses. An IP address is a number that is automatically assigned to your computer whenever you surf the Internet. When you request a page from one of our sites, our servers log your IP address to create aggregate reports on user demographics and traffic patterns for advertisers and partners, and for purposes of system administration. We use this aggregated information to determine consumer trends and needs, which allows both GroupGain and our partners to advertise more effectively, and allows you to receive advertisements that are less duplicative and more relevant to your interests.

Log Files

GroupGain uses IP addresses to analyze trends, administer the site, track users’ movements, and gather broad demographic information for aggregate use. We do not link your IP address to other personally identifiable information about you.

Cookies

Our site uses a feature of your browser to set a cookie on your computer. Cookies are small packets of information that a web site's computer stores on your computer. GroupGain's web site can then read the cookies whenever you visit our site. We may use cookies in a number of ways, such as to save your password so you don't have to re-enter it each time you visit our site, to deliver content specific to your interests, to track the pages you've visited and to make sure you don't see the same ads repeatedly. These cookies allow us to use the information we collect to customize your GroupGain experience so that your visit to our site is as relevant and as valuable to you as possible.

Most browser software can be set up to deal with cookies. You may modify your browser preference to provide you with choices relating to cookies. You have the choice to accept all cookies, to be notified when a cookie is set or to reject all cookies. If you choose to reject cookies, certain of the functions and conveniences of our web site may not work properly, and you may be unable to use those GroupGain services that require registration in order to participate, or you will have to re-register each time you visit our site. Most browsers offer instructions on how to reset the browser to reject cookies in the Help section of the toolbar. We do not link non-personal information from cookies to personally identifiable information without your permission.

Web Beacons

GroupGain also may use web beacons to collect non-personal information about your use of our web site and the web sites of selected sponsors and advertisers, and your use of special promotions or newsletters. The information collected by web beacons allows us to statistically monitor how many people are using our web site and selected sponsors' and advertisers' sites; how many people open our emails; and for what purposes these actions are being taken. Our web beacons are not used to track your activity outside of our web site or those of our sponsors. GroupGain does not link non-personal information from web beacons to personally identifiable information without your permission.

Information Collected In Ad Delivery

We may use a third-party advertising company to serve ads to you when you visit our Web site. This company may use information (not including your name, address, email address or telephone number) about your visit to our site in order to provide advertisements about goods and services that may be of interest to you. In the course of serving advertisements to this site, our third-party advertiser may place or recognize a unique cookie on your browser.

Notice Of New Services And Changes

Occasionally, we also may use the information we collect to notify you about important changes to our web site, new services, and special offers we think you will find valuable. If you would not like to receive these notifications, you can unsubscribe from receiving these notices at your Account page.

Controlling the Use of Your Information

You may review, correct, update, change or delete personal information you have submitted at any time by accessing your information on the My Account page of our web site.

Links to Other Web Sites

The GroupGain web site may contain links to advertiser and partner websites. We cannot be responsible for the privacy practices or the content of these third party web sites, and we do not control the practices of any of our advertisers or partners to whom we are linked. Please note that we provide these links to you only as a convenience, and our inclusion of any link does not imply that GroupGain endorses the site. Please read over the rules and policies of these linked sites before proceeding. If you have additional questions about how one of our advertisers, partners or sponsors use information about you, we urge you to contact them directly.

Notification of Changes

If we decide to change our privacy policy, we will post those changes on our site so you will always be aware of our latest policy. It is your obligation to periodically check our site for our most up-to-date privacy policy. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify users by way of email. Users will have a choice as to whether or not we use their information in this different manner.

Security

Our web site takes reasonable precautions to protect our user's information by utilizing advanced security measures designed to maintain data security and integrity. When you submit sensitive information, including financial information, via the web site, your information is protected both online and off-line. However, no system is 100% secure, and you should use caution whenever submitting important information over the Internet, whether to our web site or to any other.

Contact Us

If you have any questions about our privacy policy or web site, or wish to modify or delete any personally identifiable information that you have provided to us, please send an email to contact@groupgain.com.