Punch Networks Corporation has created this privacy statement to describe our privacy policy which represents our firm commitment to protect our users' privacy. The following discloses our information gathering and dissemination practices.

The Punch Networks' Products and Services generally operated at the web domains (punchnetworks.com, electradrive.com and punchwebgroups.com) generally track, among other things, the IP address, time of day, and browser software used when the sites are accessed. This information may, or may not, be called upon at any time in the future only for administrative purposes to ensure our customers have the best possible experience with our Web sites and services.

Cookies
In order to provide the best possible user experience, our product(s) may use cookies to keep track of a user's individual sessions. These cookies allow our products to intelligently update user's machines with new or updated information. We can also use cookies (at a user's request) to save login ID information so users need not re-enter them each time they use our products.

User Information
The Punch WebGroups Account Registration Form, ElectraDrive Account Registration Form and The Punch Networks Developer Program Registration Form require users to provide valid identification and contact information (name and e-mail address). We use this information from the registration form to send the user information about our company and future upgrades to these products and services. Punch Networks does not disclose, sell, or in any manner otherwise use or distribute this information.

Only authorized Punch Networks personnel (or those authorized by state or federal law agencies) have access to your account information - however no one can access your stored files, unless you either provide them with your account login credentials (or in the case of Punch WebGroups, if explicitly invite them to join one of your WebGroups). Punch Networks administrators conduct regular audits to ensure the integrity of the data (i.e. check for hacks or other malicious acts). Furthermore, the very operation of our Paris Sever software ensures file integrity and absolute confidentiality.

Private Forums
The Punch Networks Products allow users to upload documents of any type for access by other limited groups of users. To protect users' privacy, our products allow users to restrict other people from accessing their information (see Security, below) by creating personal WebGroups and/or Instant Folders which are not available to the general public.

File Privacy
Punch Networks considers files transmitted via our products to be private correspondence between the sender and recipient. Punch Networks does not monitor, edit or disclose the contents of users' private communications, unless we are required to do so:

• by law;
• to comply with legal process;
• if necessary to enforce the Punch WebGroups Terms of Service Agreement;
• to respond to claims that such communications violate the rights of third-parties;
• to protect the rights or property of Punch Networks or others.

Third Party Links
Punch Networks' Web site(s) may contain links to other third party Web sites. Punch Networks is not responsible for the privacy practices or the content of a third party's Web site. These links do not use the information we gather from users in any way.

Security
Punch Networks' products have extensive security features intended to protect the loss, misuse and/or alteration of our users' information, including:

• SSL Connection: All Punch Networks Products establish a Secure Socket Layer (SSL) connection with a user's browser before login. SSL prevents others from easily reading information as it is passed between the server and a user's browser.
• User Login ID and Password: Only the combination of valid Login ID and Password allows access to a user's information and files.
• Digital Certificates: A digital certificate assures a user's browser that the server sending it files is a Punch Networks servers. Digital Certificates prevent others from pretending/masking themselves as Punch Networks servers and sending harmful things to user computers, or accessing user files. Punch Networks' products require users to grant permission to Punch Networks (verified by our Digital Certificate) in order to publish and retrieve files properly.
• Secret Password: User passwords ARE NOT stored on the Punch Networks servers, rather they are hashed (similar to a fingerprint) with a secure one-way hash algorithm, the results of which ARE stored on the Punch WebGroups server. When logging in, the user password entered is hashed and the resulting fingerprint is compared with the fingerprint record stored on the Punch WebGroups server.
• Encrypted Files: User files are encrypted on the Punch Networks' servers, so no one can see a user's files unless they are directly and explicitly given permission by that user.

Change/Modify
At any time you may login to Punch Networks' products to edit any or all of your provided account information.

Opt Out
At any time a user may:

• Request to be removed from any Punch Networks' customer database, ensuring that they no longer receive announcements or promotions from Punch Networks.
• Remove themselves from a WebGroup, ensuring that they not longer receive updates.
• Unsubscribe to a file or folder, ensuring that the user will no longer receive notifications that the item has changed.

Contacting Punch Networks
If you have any questions about this privacy statement, the practices of Punch Networks Corporation, or your dealings with the Punch Networks' products, you can contact:

Punch Networks Compliance Team
Deep9 Corporation
500 Union Street, Suite 1010
Seattle, WA, USA 98101
(206) 405-DEEP (3337)