Privacy is important to The Cooley Group. We recognize that when you choose to provide us with information about your business, you trust us to act in a responsible manner. Such information helps us and our partners improve the products, services and opportunities available to our users and customers. This privacy policy explains what types of information we collect when you visit our Web site. By using our Web site, you consent to the collection and use of this information as outlined in this privacy policy. This policy is subject to change, so please check back periodically for updates.

Forms on our Web site may require users to give us contact information (like their name and email address). Other forms on our site may require users to provide financial information (like their account or credit card numbers). Periodically, we may use the information you have provided on a registration form to send you updates about our services and promotional material provided to us by our partners. WE DO NOT SELL, TRADE, EXCHANGE OR OTHERWISE MAKE AVAILABLE ANY PERSONALLY IDENTIFIABLE INFORMATION TO ANY OTHER COMPANY OR ORGANIZATION.

Other than what is mentioned above, we will not send you unsolicited information, commercial offers, and advertisements. This site contains links to other sites. The Cooley Group is not responsible for the privacy practices or the content of such Web sites.

USAGE AND TRANSACTION TRACKING
While you are on our Web site, we may automatically track information related to your use of the Web site. This information may include (among other things) URL tracking data, user's browser data, user's IP address, files downloaded or viewed by the user and user's path through the Web site. We may also track usage through cookies. A cookie is a small data file written to a user's hard drive. Cookies may be used to (among other things) allow automated login and may contain information such as a Login ID or other information about preferences or Internet use. They allow us to better analyze our site traffic patterns and to provide improved content, advertisements, products and services. They also allow us to refine and enhance visitor registration and to add personalization.

We may save information sent or posted to the Service for a reasonable period of time. For example, we may save messages posted in our discussion boards, clubs, or other message areas or feedback left for other users. We may collect correspondence sent to us, such as emails or letters.

CHILDREN'S ONLINE PRIVACY PROTECTION
The Cooley Group does not currently knowingly collect, use or disclose personally identifiable data on children under the age of 13. In the event that the Cooley Group were to collect, use or disclose personally identifiable data on children, we are committed to compliance with the Children's Online Privacy Protection Act of 1998 ("COPPA"), including but not limited to verifiable parental consent, choice regarding disclosures to third parties, and parental access to information.

SECURITY
This site has security measures in place to protect the loss, misuse and alteration of the information under our control. Our site uses firewall and encryption technology to protect your information, and our servers are located in a guarded co-location facility under 24-hour surveillance.

OPT-OUT
You may cancel any newsletter or email subscription from The Cooley Group at any time by following the 'unsubscribe' or 'cancel' instructions in each email message, or by sending an email to opt-out@cooleygroupusa.com indicating the subscription to cancel.

CONTACTING THE COOLEY GROUP ABOUT PRIVACY
Questions regarding our privacy policy should be directed to the Cooley Group site coordinator, at privacy@cooleygroupusa.com. You may also use this address to notify us that you do not wish to receive future mailings from the Cooley Group.