In order to protect the privacy of our clients, we have established the following guidelines and policies for secure treatment of personal information.

The use of the information that we receive is specifically limited to those activities for which NetATM, Inc. has been employed. Such information may be used to compile reports and other materials, and may be used to process plan benefits and summarize account information, as appropriate, in connection with our services and the participants to which such information relates.

Computer files and written copies containing such information are maintained as deemed appropriate for providing ongoing services to our clients, in a manner reasonably calculated to maintain and preserve the confidentiality of this information. Please note that no data transmission over the Internet is 100% secure. While we cannot absolutely guarantee the security of information that you transmit over our site, we do employ extensive physical, electronic, and procedural controls in keeping with industry standards and practices, and we regularly adapt these controls to respond to changing requirements and advances in technology.

All of our employees are trained in how to handle private information in a confidential and secure manner pursuant to our company’s written privacy policies, and all employees execute confidentiality agreements reflecting an understanding of these policies. Employees are prohibited from disclosing client information to anyone outside of our company, except as required in connection with providing our agreed services. We also maintain internal security procedures with regard to our premises and computer systems to restrict access to information maintained therein.

We are required to comply with any legal process that might require disclosure of certain client information. However, it is the company’s policy to have all such requests reviewed by legal counsel, and to notify our clients of those requests prior to complying with any request to disclose client information pursuant to a subpoena or other legal process.