Thursday, August 28, 2008

Member NASD SIPC

J GIORDANO SECURITIES LLC INTERNET PRIVACY POLICY

November, 2005

This Web Site (this “Site) is published and maintained by J Giordano Securities LLC d/b/a J Giordano Securities Group (“JGIO”), with offices located at 1234 Summer Street, Stamford, Connecticut 06905. This Site is intended for use by JGIO institutional customers, as defined in Rule 15a-6 of the Securities Exchange Act of 1934, as amended (“Rule 15a-6’)(“Customers”) who are interested in receiving research reports and other information from JGIO’s global broker network (the “Global Broker Network”). JGIO’s Global Broker Network has been developed by JGIO via contractual relationships with various non-affiliated third party international brokers (“Third Party Brokers”). JGIO’s relationship with its Customers and with its Third Party Brokers is governed by applicable federal laws, rules and regulation and, in particular, the requirements of Rule 15a-6.

By visiting this Site, and/or using the services offered on or through this Site, you agree to the terms of this Privacy Policy, as it may be amended from time to time. As JGIO updates and expands its Global Broker Network, this Privacy Policy may change. You are responsible for checking this page periodically for changes and updates. Your use of this JGIO Site (the “Service”) following any posted change to the Privacy Policy will be deemed an acceptance of such change. This Privacy Policy is incorporated into, and made a part of, the JGIO Website Terms of Service, which govern your use of this Site and the Service in general.

Our Commitment to Your Privacy

Your privacy is a serious matter to JGIO. JGIO has a standing policy of protecting the confidentiality and security of information we collect about our Customers. In order to make your visit to our Site and use our Service worthwhile, we collect certain information from your computer each time you visit JGIO and sometimes we ask you for non-public personal information (“Information”). JGIO will not share Information about you with third parties, except as specifically described below. This Privacy Policy explains, in general, what Information is collected on this Site, how the Information is used, and with whom we may share such Information. Please take a few moments to read this Privacy Policy so that you understand how JGIO treats your Information.

What Information is Collected on This Site

JGIO limits the collection and use of Information to the minimum we require to deliver superior service to you as your broker. JGIO does not collect any Information from users of this Service without the knowledge and consent of such users. Some Information is collected as part of the process of registering for the Service. "Information" includes, for example, Customer name, business address, e mail address, telephone number, wireless Internet Protocol/device address or number, or any other information that may identify a Customer or allow online or offline contact with that Customer or the agent or employee of the Customer. Some Information about your viewing and use of the Site will be collected after registration and during your use of the Site, including the frequency with which you view the Site and from what IP address you view the Site. The information may be shared with JGIO’s Third Party Brokers in order to carry out business operations and to fulfill the business contemplated by this Site.

You may review the Information that you have provided to JGIO by e-mailing webmaster@jgiordano.com or by writing to JGIO at 1234 Summer Street, Stamford, Connecticut 06905 ATTN: Webmaster. We will send you a copy of such Information we have on file in your user account (if any). You may send us new or updated information at any time. We will endeavor to respond to your request to access, update or delete your information as soon as practicable. Before we are able to provide you with any information, correct any inaccuracies or delete any information, however, we may ask you to verify your identity and to provide other details to help us to respond to your request.

Right to Opt Out

If you prefer that we not disclose Information about you to Third Party Brokers or to any other third party, you may opt out of any such disclosure, that is, you may direct us not to make those disclosures to our Third party Brokers or other third parties (other than those disclosures permitted or required by law). If you wish to opt out of disclosures to any non-affiliated third party (ies), as contemplated by the Services herein, you may make any such request to opt out by sending an email to webmaster@jgiordano.com. Please note that, a request to have us stop sharing your Information with non-affiliated third parties will only apply as of the date of the request, and JGIO will not be responsible for any communications that you may receive from any such third party that received your Information prior to such request. In these cases, please contact that third party directly.

Disclosure of Information

JGIO may disclose any Information to or as directed by you or when JGIO believes it necessary for the conduct of JGIO’s Global Broker Network or where the law otherwise permits disclosure. It is JGIO’s policy to require all Third Party Brokers or other third parties who receive any Information to sign strict confidentiality and nondisclosure agreements.

In order to provide the Service to you, both you and JGIO's Third Party Brokers are granted a username and password. You can then login and access any and all foreign research that you may be interested in that is uploaded into the Site. Additionally, you will have an option to receive either a real-time notification of new research or an aggregated batch report sent to you daily by JGIO. These notifications contain limited information about the reports and you will need to click a hyperlink on this Site to view the entire research report.

JGIO will keep a record of all research uploads from each of our Third Party Brokers, including who uploaded what research report, what exactly was uploaded, when it was uploaded and how the research is profiled.

JGIO will likewise keep a record of all research reports that you view from the Site, when you view it, if you viewed it via email notice or from the Site, and from what IP address you have viewed the material. JGIO will also maintain a record of your profile, including what tickers, countries, industries, research types and market caps you have shown an interest in (the “Customer Profile”).

JGIO will disclose to you the name and limited information pertaining to our Third Party Brokers. This information will be disclosed to you when you download research reports from this Site.

JGIO may disclose the following Information to our Third Party Brokers:

• What Customer has viewed the Third Party Broker’s research report(s) • Which research report(s) the Customer has viewed • How many times the Customer has viewed the Third Party Broker’s research report(s) • When the research reports were viewed • Your Customer name • Who (what agent or employee of the Customer) viewed the research report(s) • From what IP address the Customer viewed the research report(s)

JGIO may disclosure the following Information to you about our Third Party Brokers:

• The name of the Third Party Broker who uploaded the research report(s) • The indigenous market that the Third Party Broker covers • When the Third Party Broker uploaded the research report(s) • How the research is profiled

Site Usage Information

JGIO tries to provide you with services and products customized to your interests. In order to do that, we use "cookies" to keep, and sometimes track, information about you. Cookies are small data files that are sent to your browser from a Web server and stored on your computer's hard drive. Cookies track where you travel on this JGIO Site and what you look at. Cookies may, however, store your login name, which allows you access to some of the Service offered through our Site. In doing so, a cookie may enable JGIO to relate your use of the JGIO Site to Information that has already been submitted. Many other web sites use cookies for very similar purposes. Most web browsers can be set to inform you when a Cookie has been sent to you and provide you with the opportunity to refuse that Cookie. Additionally, your Flash player can be set to reject or delete Flash Cookies. Refusing a Cookie will generally not interfere with your use of the JGIO Site. However, refusal of a cookie may, in some cases, preclude you from using or negatively impact the display or function of the Site or certain areas or features of the Site. Additionally, JGIO may use “clear GIFs,” or similar technologies, in the Site and/or in our communications with you to enable us to know whether you have received a message. A clear GIF is typically a one-pixel, transparent image (although it can be a visible image as well), located on a Web page or in an e-mail or other type of message, which is retrieved from a remote site on the Internet enabling the verification of an individual’s viewing or receipt of a Web page or message. Our server automatically collects data about your server’s domain address when you visit us. This information, known as an Internet Protocol address, or IP Address, is a number that’s automatically assigned to your computer by your Internet service provider whenever you’re on the Internet. When you request information from JGIO, our servers may log your IP Address and sometimes your domain name. Our server may also record the referring page that linked you to us (e.g., a search engine), the pages you visit on this Site, other information about the type of Web browser, computer, platform, related software and settings you are using, and any search terms you have entered on this site or a referral site.

How is the Information used

JGIO will use the Information you provide to the Site to carry out the business relating to JGIO’s Global Broker Network or for other related business purposes. We may also use your Information to maintain our internal record keeping. We may match information collected from you through different means or at different times, and use such information along with information obtained from other sources, including third parties. In addition, we may send you notices (for example, in the form of e-mails, mailings, and the like) about products, services, companies and events that we think might interest you.

Does JGIO share Personal Information and Site Usage information

JGIO has contractual relationships with the Third Party Brokers who participate in JGIO’s Global Broker Network. These Third Party Brokers execute services for JGIO in their indigenous markets, in accordance with Rule 15a-6 of the Securities Exchange Act of 1934, and pursuant to this Site. As disclosed herein, JGIO may share limited Information about you with these Third Party Brokers who provide services for or through this Site as part of JGIO’s Global Broker Network. Any and all disclosures are consistent with this Privacy Policy. JGIO reserves the right to analyze user behavior as a measure of interest in and use of the JGIO Site.

Legally Compelled Disclosure

JGIO may disclose user Information to government and quasi-government authorities, to regulators and to other third parties when compelled to do so by these authorities or otherwise as required by law. We also may disclose user Information when we have reason to believe that someone is causing injury to or interference with our rights or property, other JGIO Site users, or anyone else that could be harmed by such activities. Business Transfer

In the event that JGIO transfers or sells all or substantially all of its assets to one or more third parties as a result of a merger, sale, consolidation or liquidation, the Information may be one of the transferred assets. Consent to Processing

By providing Information to this Site, you understand and consent to the collection, maintenance, processing and transfer of such Information in and to the United States and other countries and territories.

Access to other sites through the JGIO Site

When you are on this JGIO Site you may have the opportunity to visit, or link to, other sites not operated by JGIO. These sites may collect Information about you. JGIO does not control sites that are operated by others and is not responsible for the information practices of these sites and this Privacy Policy does not address the information practices of those web sites or advertisers.

Security/Enforcement

JGIO will take reasonable steps to protect the security and integrity of all Information provided to the JGIO Site. However, due to the inherent nature of the Internet as an open global communications vehicle, JGIO cannot guarantee that this Information will be absolutely safe from intrusion by others, such as hackers. Any unauthorized access to or use of the JGIO Site or information collected and maintained by the JGIO Site should be immediately brought to the attention of JGIO at the Customer service e-mail address below. JGIO will investigate, and, if necessary, take action to prevent or halt, any violation of this Privacy Policy of which it becomes aware.

If you contact JGIO by e-mail, you should be aware that e-mail transmission might not be secure. A third party could view information you send by e-mail in transit. JGIO shall have no liability for disclosure of your information due to errors or unauthorized acts of third parties during transmission.

In the unlikely event that we believe that the security of your Information in our possession or control may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we would endeavor to do so as promptly as possible under the circumstances, and, to the extent we have your e-mail address, we may notify you by e-mail. By using this Site, you consent to our use of e-mail as a means of such notification.

How We Protect Information

Each of JGIO’s employees are required to protect the confidentiality of Information and to comply with our established policies. They may access Information only when there is an appropriate reason to do so, such as to administer our products or services. We also maintain physical, electronic and procedural safeguards to protect Information, which comply with Federal standards. Employees who violate our Privacy Policy are subject to disciplinary actions.

Former Customers

Even if you are no longer a Customer of ours for which we provided services, our Privacy Policy will continue to apply to you.

To Whom This Policy Applies

This Privacy Policy applies to any and all products or services provided pursuant to this Site by JGIO and/or by JGIO’s Third Party Brokers.

Access to and Correction of Information

If you desire to review any file we may maintain for your personal Information, please contact us at the address provided herein and JGIO will review the Information promptly. If we agree with you, we will correct our records. If we do not agree, you may submit a short statement of dispute, which we will include in future disclosures of the disputed Information. Information collected in connection with, or in anticipation of, any claim or legal proceeding will not be made available.

Further Information

JGIO reserves the right to change this Privacy Policy. The examples contained within this Privacy Policy are illustrations and they are not intended to be exclusive. This notice complies with a recently enacted Federal law and new SEC regulations regarding privacy. You may have additional rights under other foreign or domestic laws that may apply to you.

Questions concerning this Privacy Policy may be directed to us at 203-327-7844, fax at 203-541-8917 or by e-mail at webmaster@jgiordano.com.