A. Overview

In order to operate the Brook Curtis website and to reduce the risk of fraud, Brook Curtis Corp. ("Brook Curtis" or "we") must ask you to provide us information about yourself and your credit card and/or bank account. This Privacy Policy describes the information we collect and how we use that information. Brook Curtis takes the privacy of your personal information very seriously and will use your information only in accordance with the terms of this Privacy Policy. We will not sell or rent your personally identifiable information or a list of our customers to third parties. However, as described in more detail in Part C below, there are limited circumstances in which some of your information will be shared with third parties, under strict restrictions, so it is important for you to review this Privacy Policy. This Privacy Policy applies to all services that are hosted on the Brook Curtis.com Web site. By accepting the Privacy Policy and User Agreement in registration, you expressly consent to our use and disclosure of your personal information in the manner described in this Privacy Policy. This Privacy Policy is incorporated into and subject to the terms of the Brook Curtis User Agreement. This Privacy Policy will take effect on January 1, 2005. Notification of Changes This policy may be revised over time as new features are added to the Brook Curtis service or as we incorporate suggestions from our customers. If we are going to use or disclose your personally identifiable information in a manner materially different from that stated at the time we collected the information, you will have a choice as to whether or not we use or disclose your information in this new manner. Any material changes will be effective only after we provide you by e-mail with at least 30 days' notice of the amended Privacy Policy (if you have closed your Brook Curtis account, you will not be contacted to notify you of the amended Policy and your personal information will not be used or disclosed in this new manner). We will post the amended Privacy Policy prominently on our Web site so that you can always review what information we gather, how we might use that information, and whether we will disclose it to anyone. Please check the Brook Curtis Web site at https://www.Brook Curtis.com/ at any time for the most current version of our Privacy Policy.

B. Information We Collect

Required Information To open a Brook Curtis account, you must provide your name, address, phone number, and e-mail address. In order to make payments through Brook Curtis, you must provide credit card, debit card or bank account information (bank account information is required to make payments totaling more than $1,000). We also ask you to choose two different security questions to answer (such as your city of birth or your pet's name) This required information is necessary for us to process transactions, issue a new password if you forget or lose your password, protect you against credit card fraud and checking account fraud, and to contact you should the need arise in administering your account. If you enroll in the Brook Curtis Distributor Program, we are required to collect your Social Security Number ("SSN") or other Taxpayer Identification Number ("TIN"). Information About You From Third Parties In order to protect all our customers against potential fraud, we verify with third parties the information you provide. In the course of such verification, we receive personally identifiable information about you from such services. In particular, if you register a credit card or debit card with Brook Curtis, we will use card authorization and fraud screening services to verify that your card information and address matches the information that you supplied to Brook Curtis, and that the card has not been reported as lost or stolen. Web Site Traffic Information Because of the way that World Wide Web communication standards work, when you arrive at or leave the Brook Curtis Web site, we automatically receive the Web address of the site that you came from or are going to. We also collect information on which pages of our Web site you visit while you are on the Brook Curtis site, the type of browser you use and the times you access our Web site. We use this information only to try to understand our customers' preferences better and to manage the load on our servers, so as to improve our service and your experience with Brook Curtis. We do not track the Web sites that you visit before or after you leave the Brook Curtis site. Our Use of "Cookies" "Cookies" are small files of data that reside on your computer and allow us to recognize you as a Brook Curtis customer if you return to the Brook Curtis site using the same computer and browser. We send a "session cookie" to your computer if and when you log in to your Brook Curtis account by entering your e-mail address and password. These cookies allow us to recognize you if you visit multiple pages in our site during the same session, so that you don't need to re-enter your password multiple times. Once you log out or close your browser, these session cookies expire and no longer have any effect.   Customer Service Correspondence If you send us correspondence, including e-mails and faxes, we retain such information in the records of your account. We will also retain customer service correspondence and other correspondence from Brook Curtis to you. We retain these records in order to measure and improve our customer service, and to investigate potential fraud and violations of our User Agreement. We may, over time, delete these records if permitted by law. Questionnaires, Surveys and Profile Data From time to time, we offer optional questionnaires and surveys to our users for such purposes as collecting demographic information or assessing users' interests and needs. The use of the information collected will be explained in detail in the survey itself. If we collect personally identifiable information from our users in these questionnaires and surveys, the users will be given notice of how the information will be used prior to their participation in the survey or questionnaire.

C. Our Use and Disclosure of Information

Internal Uses We collect, store and process your personal information on servers located in the United States. We use the information we collect about you in order 1) to provide our services and process your transactions, 2) to provide customer service, 3) to improve our products and services. We give access to individually identifiable information about our users only to those employees who require it to fulfill customer service requests. Disclosure to Brook Curtis Distributors If you are a registered Brook Curtis customer, your name, e-mail address, date of sign-up, are displayed to the Brook Curtis distributor that first referred you to Brook Curtis. However, your credit card number, and other financial information will NEVER be revealed to anyone unless we are required to do so pursuant to a subpoena or other legal process. Disclosure to Third Parties Other Than Brook Curtis Brook Curtis will not sell or rent any of your personally identifiable information to third parties. Brook Curtis will not share any of your personally identifiable information with third parties except in the limited circumstances described below, or with your express permission. These third parties are limited by law or by contract from using the information for secondary purposes beyond the purposes for which the information is shared. We share information with companies that help us process the transactions you request and protect our customers' transactions from fraud, such as sharing your credit card number with a service that screens for lost and stolen card numbers. See "Information About You From Third Parties" in Section B above. Additionally, if you go into a negative balance and owe us money, we may share information with processing companies including collection agencies. We disclose information that we in good faith believe is appropriate to cooperate in investigations of fraud or other illegal activity, or to conduct investigations of violations of our User Agreement. For example, this means that if we conduct a fraud investigation and conclude that one side has engaged in deceptive practices, we can give that person or entity's contact information to victims who request it. We disclose information in response to a subpoena, warrant, court order, levy, attachment, order of a court-appointed receiver or other comparable legal process, including subpoenas from private parties in a civil action.   We disclose information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you). We share aggregated statistical data with our business partners or for public relations. For example, we may disclose that a specific percentage of our users live in California. However, this aggregated information is not tied to personally identifiable information. As with any other business, it is possible that Brook Curtis in the future could merge with or be acquired by another company. If such an acquisition occurs, the successor company would have access to the information maintained by Brook Curtis, including customer account information, but would continue to be bound by this Privacy Policy unless and until it is amended as described in Section A above. We share your information with our parent, subsidiaries and joint ventures to help coordinate the services we provide to you, enforce our terms and conditions, and promote trust and safety. Our Contacts with Brook Curtis Customers We communicate with users on a regular basis via e-mail to provide requested services, and we also communicate by phone to resolve customer complaints or investigate suspicious transactions. We use your e-mail address to confirm your opening of a Brook Curtis account, to send you notice of purchases and commissions that you receive through Brook Curtis to send information about important changes to our products and services, and to send notices and other disclosures required by law. Generally, users cannot opt out of these communications, but they will be primarily informational in nature rather than promotional. We also use your e-mail address to send you other types of communications that you can control, including the Brook Curtis Periodical newsletter, promotions, customer surveys and notice of special promotions. You can choose whether to receive some, all or none of these communications when you complete the registration process, or at any time thereafter, by logging in to your account on the Brook Curtis Web site and changing your preferences in the Profile page of the My Account tab. You can also change your choices at any time through the same procedure. In connection with independent audits of our financial statements and operations, the auditors may seek to contact a sample of our customers to confirm that our records are accurate. However, these auditors cannot use personally identifiable information for any secondary purposes. Internet Address Information We use IP addresses, browser types and access times to analyze trends, administer the site, improve site performance and gather broad demographic information for aggregate use. Your Use of Information and Our Services By entering into our User Agreement, you agree that, with respect to other users' personally identifiable information that you obtain through the site or through a Brook Curtis-related communication or Brook Curtis-facilitated transaction, you will only use this information for: (a) Brook Curtis-related communications that are not unsolicited commercial messages, (b) using services offered through Brook Curtis (e.g. insurance, shipping and fraud complaints), and (c) any other purpose that such user expressly agrees to after adequate disclosure of the purpose(s). In all cases, you must provide users with the opportunity to remove themselves from your database and review any information you have collected about them. In addition, under no circumstances, except as defined in this Section, can you disclose personally identifiable information about another Brook Curtis user to any third party without our consent and the consent of such other user after adequate disclosure. Note that law enforcement personnel and other rights holders are given different rights with respect to information they access. Brook Curtis does not tolerate spam. Therefore, without limiting the foregoing, you may not add a Brook Curtis user to your mail list (email or physical mail) without their express consent after adequate disclosure, even if said user has previously made a purchase from you. We strictly enforce our Anti-Spam Policy! To report Brook Curtis-related spam to Brook Curtis, please contact us. Distributor Referral Program When you sign up for a Brook Curtis account, you become eligible to participate in our Distributor Referral Bonus program. We provide you with a link on the Merchant Referral Bonus page which identifies you as the referrer. If a merchant uses that link to sign up for a Brook Curtis Distributor account and completes the registration process, you are eligible for a referral bonus. If you use a referral link to sign up, your name may be listed in the referrer's Brook Curtis account, along with the amount of commission you have generated for the referrer, which is calculated as a percentage of your transaction volume, as described in the Distributor Commission Policy.

D. Information Security

Information Security Brook Curtis is committed to handling your customer information with high standards of information security. Your credit card and bank account information are stored only in encrypted form on computers that are not connected to the Internet. We restrict access to your personally identifiable information to employees who need to know that information in order to provide products or services to you. The security of your Brook Curtis account also relies on your protection of your Brook Curtis password. You may not share your Brook Curtis password with anyone. Brook Curtis will never ask you to send your password or other sensitive information to us in an e-mail, though we may ask you to enter this type of information on the Brook Curtis website, which will always have a URL beginning with https://www.BrookCurtis.com/. Any e-mail or other communication requesting your password, asking you to provide sensitive account information via email, or linking to a website with a URL that does not begin with https://www.BrookCurtis.com/ should be treated as unauthorized and suspicious and should be reported to Brook Curtis immediately.   If you do share your Brook Curtis password with a third party for any reason, including because the third party has promised to provide you additional services such as account aggregation, the third party will have access to your account and your personal information, and you may be responsible for actions taken using your password. If you believe someone else has obtained access to your password, please change it immediately by logging in to your account at https://www.Brook Curtis.com/ and changing your Profile settings, and also contact us right away as described in Section F below.

E. Accessing and Changing Your Information

You can review the personal information you provided us and make any desired changes to such information, or to the settings for your Brook Curtis account, at any time by logging in to your account on the Brook Curtis Web site and changing your preferences in the Profile page. You can also close your account through the Brook Curtis Web site. If you close your Brook Curtis account, we will mark your account in our database as "Closed," but will keep your account information in our database. This is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. However, if you close your account, your personally identifiable information will not be used by us for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement, or as required by law.