PRIVACY POLICY

BRIDGEWAY BENEFIT TECHNOLOGIES LLC (“BRIDGEWAY”) HAS ADOPTED THE FOLLOWING PRIVACY POLICY, WHICH IS APPLICABLE TO ALL CONFIDENTIAL INFORMATION YOU PROVIDE DURING YOUR VISITS TO THE WWW.BRIDGEWAYBENTECH.COM WEBSITE (THE “SITE”).

Bridgeway is greatly sensitive to the confidentiality of your personal information and believes the protection of your confidentiality to be one of the company’s significant responsibilities. As a result of our obligation to your privacy and confidentiality, Bridgeway has adopted the following Privacy Policy, which is applicable to all personal and confidential information you provide during your visits to the Site.

Acquisition of Information – Bridgeway does not acquire any more confidential information about you than is required by law or is otherwise necessary to provide a high level of service efficiently and securely.

Employees and Privacy – Bridgeway trains all employees about the importance of privacy. We give access to your confidential information only to those employees who require it to perform their jobs.

Security Measures – Bridgeway makes access to confidential and sensitive information subject to rigorous procedural and technological controls, consistent with legal requirements and the demands of customer service.

Disclosure to Third Parties – It is our policy to never provide your confidential information to third parties without your express permission or if such disclosure is necessary to process transactions or provide services which you have requested. The only exception to this policy is if Bridgeway is compelled to do so by an appropriately empowered governmental authority.

Privacy and Bridgeway Business Partners – When we make Bridgeway technology or services available to business partners, we will not share with them any more confidential information than is necessary to perform the transaction you have requested. In addition, Bridgeway only does business with partners who agree to respect this Privacy Policy and will make every reasonable effort to assure, by contract or otherwise, that these third parties use our information, technology and services in a manner that is consistent with this Privacy Policy.

Personal Information – Users may visit the Site without revealing any personal information. The Site may ask users (i.e. general visitors to the Site) and customers (users with passwords that allow them to go to the password-restricted areas of the Site) to provide contact information (for example, name and email address), unique identifiers (for example, employee ID number for customers), demographic information (for example, zip code and age) and financial information (for example account or credit card numbers for purchases). Bridgeway uses your contact information to create access to products and services on the Site and to send you information about Bridgeway. Your contact information is also used to contact you when necessary. Financial information that is collected is used to check your qualifications and bill either you or your company for products and services, as applicable. Demographic and profile data is also collected at our site. Bridgeway uses this data to tailor your experience to the Site, showing you content Bridgeway believes might interest you, and displaying the content according to your preferences.

Corporate Data – Protecting the privacy of a customer’s personal information is a top priority; in addition, Bridgeway takes the protection of each customer’s confidential corporate data to be one of our most significant responsibilities. Bridgeway uses diligent efforts designed to ensure that (i) access each customer’s data is limited to the company for which that customer works or has authorization to access by using a company-specific password, and that (ii) such company’s data is not violated or accessed by unauthorized persons.

Nature of Information Acquired – The personal information Bridgeway acquires in processing payment transactions varies according to the nature of the transaction and the way in which merchants or financial institutions are using Bridgeway’s payment services. More often, it may include the amount of the transaction, name, credit card number and expiration date, checking account number, billing address, and shipping address.

Information/Data Center Security – Bridgeway stores transaction information on secure computer environments located in a locked data center. Only a small number of Bridgeway personnel involved in the management of the data center have physical access to these computers. Where possible, Bridgeway encrypts information stored on these computer environments as a further measure of protection. Bridgeway uses high industry standards in the acquisition and deployment of firewalls and other security technology designed to prevent our secure computer environments from being accessed by unauthorized persons.

Use of Cookies – A cookie is small amount of data that is transferred to your browser by a Web server. These cookies are used to track aggregate site visitation statistics and to enable our customers to authenticate to Bridgeway application services only once per session. These authentication cookies identify the user to multiple events. When a user logs into an application, their username, unique session identifier number, and other session data are captured in the cookie file, thus enabling the user to traverse through the screens of the application without authenticating at each new screen. Bridgeway authentication cookies are terminated at the end of the session, or after 90 minutes of idle time. No other information is captured in the authentication cookie file, nor is any information permanently transferred to the user’s system.

Access by Employees – Bridgeway customer service representatives have access to some transaction information in order to respond to your questions. Bridgeway limits that access to the minimum information required in order to provide prompt, high quality service. For example, these Bridgeway employees do not generally have access to complete credit card numbers. In general, employees who do have access to Bridgeway databases have undergone background checks and generally only retrieve data for supporting Bridgeway customers’ data or individual transactions, and not about individual customers.

Provision of Information to Others – To perform Bridgeway services, we must, of course, pass information about transactions to payment card processors and banks. From time-to-time Bridgeway may also provide third parties with aggregate information that is not linked to you or any other any particular individual. Bridgeway does not provide to any third party your name and email address, or the names and email addresses of other Bridgeway customers. Bridgeway does not sell any personal information of any user of the Site.

Children Under Thirteen – The Site is not designed to attract children and Bridgeway does not knowingly collect personal information from children under the age of 13. If you are under the age of 13, you must ask your parent or guardian for permission to use the Site.