Privacy Policy
OVERVIEW
The MCC web site is located at http://www.mccglobal.com.com (the Site) and is owned and operated by Moore Clayton & Co., Inc.

This web site Privacy Notice (Notice) describes the personally identifiable and non-personal information MCC collects in connection with your use of the Site (Personal Information and Non-Personal Information, respectively). This Notice does not address any other information exchanges between you and MCC, including information gathered by us in the course of a client relationship (if any) between you and MCC, or information gathered by us from you on behalf of our client(s). If you do not agree with the terms and conditions of this Notice, do not use the Site.

We recognize that our clients expect privacy and security for the nonpublic information they provide to us. If you choose to submit Personal Information to us via this Site, and subject to your choices, we will use your Personal Information in accordance with this Notice, until such time as you ask us to stop.

Unless you provide it to us voluntarily, MCC does not collect Personal Information about you in connection with your requests for publications and other informal information, other than your computer's IP address. Your computer's IP address is used solely for quality control and Site management purposes.

Please read this Notice carefully to learn how you can verify the accuracy of your Personal Information and how you can request us to delete or update that information.

MCC does not want to collect Personal Information from minors (children under 13 years of age, or any other age defined under applicable law). If we become aware that a minor is attempting to or has submitted Personal Information via this Site, we will notify the user that we may not accept his or her Personal Information. We will then delete any such Personal Information from our records.

WHAT INFORMATION DO WE ASK YOU TO SUBMIT?
In order to accommodate your requests for more information, you may be asked to submit your first and last name, company affiliation (if any), title, and email address. If you choose to receive our publications via postal mail, we will ask you for your mailing address.

We occasionally may conduct surveys among users which request the provision of Personal Information such as name and email address, as well as Non-Personal information regarding your experience on our Site. You may be selected for participation in such surveys based upon the personal information options (Personal Information Options) you select at this Site. Participation in these surveys and the corresponding submission of Personal Information are voluntary.

HOW WILL WE USE YOUR INFORMATION?
We will use the information you submit (i) to send you materials that you have requested; (ii) to respond to your email queries; (iii) at your option, to notify you of other communications that may be of interest to you; (iv) in the administration of the Site; and (v) as otherwise described in this Notice.

DO WE USE COOKIES AND OTHER TRACKING MECHANISMS?
When you visit this Site, information about your browser type, operating system, IP address, and the domain name from which you access this Site (e.g., yahoo.com) are collected. In addition, we may collect information about your browsing behavior, such as the number of times you have visited the Site, the date you visited the Site, and the amount of time you spent viewing the Site. This information is used solely for our internal purposes in managing the Site and improving its functionality.

TO WHOM DO WE DISCLOSE YOUR INFORMATION?
Subject to our professional standards and applicable law, we and our Service Providers (as defined below) disclose your Personal Information:

• To our affiliates;
• To unaffiliated third parties that are under contract to perform services for or on behalf of MCC (Service Providers), and are required to uphold and maintain policies with respect to privacy and the treatment of your Personal Information (e.g., vendors maintaining MCC's computer databases or performing marketing activities for MCC relating solely to services provided by MCC and its affiliates); and
• To other persons, including law enforcement officials, as permitted or required by applicable law or regulation.
Any access to such information will be limited to the purpose for which such information was provided to the affiliate or Service Provider. Our affiliates and Service Providers may be located throughout the world. Accordingly, your Personal Information may be sent to countries that have a different level of privacy protection than the United States of America (USA) or your country of residence. MCC will, at your request, provide you with details of recipients and countries to which your Personal Information has been sent.

In addition, federal, state and foreign laws give people with governmental, regulatory or supervisory responsibility, and those involved in lawsuits and other legal proceedings, the right under certain circumstances to obtain information from us, our affiliates and from our Service Providers, including your Personal Information. Subject to our professional standards, you should understand that MCC, our affiliates and Service Providers will comply with these laws to the extent we and they are required to do so.

SALE OR TRANSFER OF INFORMATION
In the event of a sale, merger, liquidation, dissolution, or transfer of part of the business, trade or assets of MCC and/or any of its individual affiliates, all Personal Information collected about you via this Site may be sold, assigned, or transferred to the party acquiring all or substantially all of the equity or assets or business of MCC and/or our affiliates. Subject to your election to opt out as described below, by using this Site, you consent to the sale and transfer of your information as described in this paragraph.

LINKS AND THIRD PARTY WEB SITES
This Notice applies only to http://www.mccglobal.com. This Site may include links to the web sites of both our affiliated and non-affiliated entities (Other Sites), including access to content, products and services of such affiliated and non-affiliated entities. In some cases, these Other Sites may have the same (or a similar) look and feel as our Site and therefore may appear to be part of our Site. However, whenever you choose to access Other Sites or non-MCC content via the MCC Site, a separate browser window will launch and you will leave the MCC Site. We urge you to familiarize yourself with the individual privacy and other terms for each linked site prior to submitting your personal information.


HOW DO WE PROTECT YOUR INFORMATION AND WHERE IS IT STORED?
MCC maintains physical, electronic, and procedural safeguards to protect your Personal Information. Your information is stored within secure operating environments and MCC's personnel and affiliates are trained to maintain the privacy and security of your Personal Information consistent with this Notice.

The Personal Information that you submit via this Site is stored on servers in the USA. The storage on servers in the USA is necessary for the purposes described in this Notice. If you are located in another jurisdiction, you should be aware that once your Personal Information is submitted, it will be transferred to our servers in the USA using secure encryption-based transmission services, and that the USA currently does not have uniform data protection laws in place.

CONSENT TO PROCESSING
Subject to your opt-out choices and all of the provisions contained in this Notice, you hereby consent to the collection, processing and transfer by MCC of your Personal Information for the purposes described under this Notice, including but not limited to the transfer of such Personal Information between MCC and its Service Providers and affiliates in accordance with this Notice. Your consent to our right to transfer Personal Information in accordance with this Notice includes consent to the transfer of your Personal Information to jurisdictions that may have different levels of privacy protection than that available to you under your local law.

OTHER TERMS
Your use of our Site is subject to and contingent upon your agreement with our Web Site Terms, which are hereby incorporated by reference.

Except as described in this notice, and subject to your choices, MCC will not use your Personal Information for any other purpose unless we first obtain your express authorization.
If you have questions concerning this Notice, including enforcement of this Notice, please contact our US or UK Privacy Administrator via email at
legal@mccglobal.com

© Moore, Clayton and Co. Inc 2004 all rights reserved