Thank you for visiting the Internet website operated by Halden-Caviglia. ("Halden-Caviglia") located at the URL www.halden-caviglia.com. We take your privacy seriously. This Privacy Policy details certain policies implemented throughout the Site governing Halden-Caviglia's use of personally identifiable information about users of our Site and users of services available through this Site (the "Services").

Privacy Policy Updates Due to the Internet's rapidly evolving nature, Halden-Caviglia may need to update this Privacy Policy from time to time. If so, Halden-Caviglia will post its updated Privacy Policy on our Sites and we may send registered users an email, so that you are always aware of what personally identifiable information we may collect and how we may use this information. If any modification is unacceptable to you, you should cease using the Sites and the Services. If you do not cease using these Sites and the Services, you will be deemed to have accepted the change.

Information Collection You can generally visit our Sites without revealing any personally identifiable information about yourself. However, in certain sections of these Sites and when you use our Services, we may invite you to contact us with questions or comments or request information, contact us with feedback, participate in surveys, questionnaires or contests, recommend or rate content, or complete a registration form. To receive certain information or Services, you will be required to provide your first and last name and your email address, and may need to create a password that you can change.

Information Use We may use your personally identifiable information to register you to use our Sites and Services, to deliver certain Services, provide notices regarding the Services you have purchased, to verify your authority to enter our Sites, improve the content and general administration of the Sites and our Services and display targeted advertising on web pages served by the Sites.

Cookies and Similar Technologies We may use small text files called cookies to improve overall experience on the Sites. A cookie is a piece of data stored on the user's hard drive containing information about the user to improve the performance of the Sites. Cookies generally do not permit us to personally identify you. We may also use other technologies such as pixel tags, which are electronic images not visible to users that may be associated with the cookies, to allow us to count the number of users that have visited certain pages, to deliver Services and to help determine the effectiveness of certain services or branded campaigns.

Aggregate Information The Sites may track the information provided by cookies, server log files, pixel tags and other similar technologies to determine non-personally identifiable information, such as the total number of visitors to our Sites, the number of visitors to each page of our Sites, traffic patterns, and browser type. The Sites may also track IP addresses and certain variables about your computer environment (such as your MAC address, computer type, screen resolution, OS version, Internet browser type and version), and we may analyze this data for trends and statistics in the aggregate, but such information will be maintained, used and disclosed in aggregate form only and it will not contain personally identifiable information. We may use such aggregate information to analyze trends, administer the Sites, track users' movement, and gather broad demographic information for aggregate use.

Disclosure We may provide your personally identifiable information and the data generated by cookies and the aggregate information to the vendors and service agencies that we may engage to assist us in providing our Services to you. Such third party entities may be obligated to use your personally identifiable information solely to provide the services to us. We will disclose your personally identifiable information if we reasonably believe we are required to do so by law or regulation, or in cooperation with any governmental investigation. We will not sell your personally identifiable information to any company or organization except we may transfer your personally identifiable information to a successor entity upon a merger, consolidation or other corporate reorganization in which Halden-Caviglia participates or to a purchaser of all or substantially all of Halden-Caviglia's assets to which the Sites relate.

Links to Third Party Sites and Vendors These Sites may provide links to other Web sites, including those of third party vendors who provide certain value-added products or services which may be of interest to you which Halden-Caviglia does not have control ("External Web Sites"). Such links do not constitute an endorsement by Halden-Caviglia of those External Web Sites and it is your choice whether or not to provide your personally identifiable information to those Web sites and vendor. You acknowledge that Halden-Caviglia is providing these links to you only as a convenience, and further agree that Halden-Caviglia is not responsible for the content, activities or performance of such External Web Sites. Your use of External Web Sites is subject to the terms of use and privacy policies located on the linked to External Web Sites.

Other Communications If you affirmatively opt-in, Halden-Caviglia and other entities affiliated with Halden-Caviglia through co-branding and/or co-marketing arrangements may use your personally identifiable information to inform you of products, programs, services or promotions that we believe may be of interest to you. If you would prefer not to continue to receive such messages, you may opt-out from receiving further messages by following the "unsubscribe" instructions in the latest message that you receive. Please note that following such instructions will opt you out only from receiving further messages from the sender of the particular message from which you initiated the opt-out process.

Security We may employ procedural and technological security measures that are reasonably designed to help protect your personally identifiable information from loss, unauthorized access, disclosure, alteration or destruction. Halden-Caviglia may use encryption, password protection, and other security measures to help prevent unauthorized access to your personally identifiable information.

Notice to European Users The information you enter on these Sites or otherwise provide to Halden-Caviglia may be transferred outside of the European Union to the United States of America which does not offer an equivalent level of protection to that required in the European Union. In particular, you are advised that the United States of America uses a sectoral model of privacy protection that relies on a mix of legislation, governmental regulation, and self-regulation. Article 26 of the European Union's Data Protection Directive (Directive 95/46/EC, 1995 O.J. (L 281) 31) allows for transfer of personal data from the European Union to a third country if the individual has unambiguously given his consent to the transfer of personal information, regardless of the third country's level of protection. By agreeing to the terms of use and this privacy policy, you consent to the transfer of all such information to the United States of America which may not offer an equivalent level of protection to that required in the European Union and to the processing of that information by Halden-Caviglia on its servers located in the United States of America as described in this Privacy Policy.

Correction/Updating Personally Identifiable Information Halden-Caviglia provides you with the ability to review, correct and delete any of your user profile. If you wish to review or correct any profile information you have provided to us, you may submit a request to us at the contact email below or access your account online. If you have any questions regarding this Privacy Policy please contact us.

Last updated: October 20th, 2009

Effective: October 20th, 2009