At SpiderWeb, Inc. (“SpiderWeb”, “We” or “Us”), we are committed to protecting your privacy. This privacy statement explains the data collection and use practices of SpiderWeb’s real-time communications services. This privacy statement does not apply to our public Web site. By using the Service ("Software"), you are consenting to the information collection and use practices described in this privacy statement.  Individual usage by participants of any of the SpiderWeb solutions, including any classrooms, meeting rooms or support rooms will be referred to as “events.”

Collecting Your Information
Information that is provided by meeting organizers or administrators such as meeting schedules, attendee lists, subject matter, and content of any Web presentations, visual or audio and any content uploaded to our servers by meeting organizers or administrators are considered confidential to the purchaser or sponsor of the event or conference center where such information was provided. We will not view such information except as necessary to appropriately provide and support the Software. We will use the information for the purpose of capacity planning and anticipating, diagnosing, supporting or resolving any problems that might limit or disrupt the Software. Any business information collected during the event may also be used to facilitate debugging during development, or to debug customer reported errors.

We will collect your personal information if you choose to register or request information for the Software or participate in an event facilitated by the Software. The information we collect may include your name, postal address, email address, telephone number, facsimile number, company name, job title, and information about your company as well as information about the nature of your usage of our Software, including the number of event attendees, duration, and frequency of events.

Furthermore, as part of the Software, we collect and log information concerning participants, including but not limited to which participants viewed slides during the presentation, questions and answers that are delivered to other participants, slide transitions, notes or annotations made by you and any other participants, application sharing, or posting of comments.  This information may also be viewed by other participants. We also collect polling results including how each participant voted. This information is also shared with the party who is hosting or sponsoring the event.

We may collect certain anonymous information about your visit, such as the name of the Internet service provider and the Internet Protocol (IP) address through which each participant accessed the Internet; the date and time you access the Web site; the pages that each participant accessed while at the Web site and the Internet address of the Web site from which you linked directly to our site. This anonymous information is used to help improve the Software, analyze trends, and administer the Software.

Use of Personal Information
The personal information we collect will only be used to provide the service.  This may include using the personal information to:

• Provide you with important information about the Software, including critical updates and notifications;
• Allow third parties to provide enhanced services;
• Provide you with more effective customer service;
• Substantiate bills to our customers;
• Authenticate the participant;
• Send information about products, services, special promotions, if requested by you;
• Share your registration information and aggregate usage data with our partners, who may occasionally use your email address to notify you of changes or additions to their services.

We occasionally hire other companies to provide limited services on our behalf, such as handling the processing and delivery of mailings, providing customer support, or performing statistical analysis of our services. We will only provide those companies the personal information they need to deliver the service. They are required to maintain the confidentiality of that information and are prohibited from using that information for any other purpose.  We may access and/or disclose personal information if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on SpiderWeb or the site; (b) protect and defend the rights of property of SpiderWeb ; or, (c) act in urgent circumstances to protect the personal safety of SpiderWeb employees, users of SpiderWeb products or services, or members of the public.  Personal information collected by SpiderWeb, may be stored and processed in the United States or any other country in which SpiderWeb or its affiliates, subsidiaries or agents maintain facilities, and by using this site, you consent to any such transfer or information outside of your country. SpiderWeb abides by the safe harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of such data from the European Union.

Control of Your Personal Information
Except as otherwise described in this statement, personal information you provide related to the Software will not be shared outside of SpiderWeb Communications and its controlled subsidiaries and affiliates without your permission.  With regard to personal information that is collected at registration from our users (e.g. name, user ID, email address), we present the option not to receive communications regarding the Software. Customers who no longer wish to receive communications may opt out or unsubscribe from receiving these communications. Each communication will have a way to unsubscribe from that list.

Access to Personal Information
If your personally identifiable information changes, we will endeavor to provide a way to correct or update your personal data. Customers can log in and click on the User links to modify their own personal information. SpiderWeb Communications customers also may contact us.

Security of Your Personal Information
SpiderWeb is committed to protecting the security of your personal information. We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. For example, we store the personal information you provide on computer servers with limited access that are located in secure and controlled facilities. We do not disclose your private, online communications except as appropriate during an event to the participants of that event.

Use of Cookies
We may from time to time use cookies to save information (name, address, phone number, email address) so you are not asked to reenter this information each time you visit the Web site. A cookie is a small text file that is placed on your hard disk by a Web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a Web server in the domain that issued the cookie to you. The primary purpose of cookies is to provide a convenience feature to save you time. With certain exceptions, you have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you can still use the Software, but you may be required to fill in information each time you sign on, and you may not be able to fully experience all of the features of this or other Web sites you visit. Further, a cookie will be set when you agree to the SpiderWeb , end-user license agreement (the “EULA”), in order to facilitate future access to the service. This cookie is also used in subsequent sessions to take you directly to the SpiderWeb service and you will not be able to use the Software if you disable this cookie.

Links to Other Web Sites
This Web site may contain links to other Web sites. Please be aware that this privacy statement applies solely to the information collected by the Software. We are not responsible for the privacy practices or the content of other Web sites. In some cases, SpiderWeb service may be hosted by a customer on the customer’s site. In such cases when our service is being run on the customer’s network, users should visit the SpiderWeb Communications site in order to review the privacy policy. We encourage you to be aware when you are leaving this Web site and to read the privacy statements of each and every Web site that you visit before providing any personal information.

Changes to the Privacy Statement
We may occasionally update this privacy statement. When we do, we will revise the date in the footer of this privacy statement. We encourage you to periodically review this privacy statement to stay informed about how we are helping to protect the personal information we collect. Your use of the Software constitutes your agreement to this privacy statement and any updates.

Contact Information
SpiderWeb welcomes your comments regarding this privacy statement. If you believe that SpiderWeb has not adhered to this privacy statement, please contact us by email or postal mail at the address provided below and we will use commercially reasonable efforts to promptly determine and remedy the problem.  If you have questions regarding this statement, please contact us.

SpiderWeb Privacy Statement

August, 2004