NeoGrid Privacy Policy

This Privacy Policy sets forth the policy of NeoGrid with respect to the privacy of information NeoGrid collects from visitors (collectively, "Users") to the web based trading exchange located on the Internet at (the "NeoGrid Exchange"). 

1. Collection and User of Information. 

a. Registration Information.

In order to become a registered user on the NeoGrid Exchange, a User must first register and provide certain contact information and other information about the User's company (collectively, "Registration Information"). Registration Information will be used for evaluating qualifications for participation in the NeoGrid Exchange. NeoGrid may publish certain Registration Information (including User name and contact information) in a trading partner directory available only to other users of the NeoGrid Exchange. NeoGrid may use Registration Information to communicate with a User regarding (i) new and modified services and features offered by NeoGrid; (ii) special offers made available by NeoGrid or its partners; and (iii) specific activities in which the User is participating. NeoGrid will not disclose a User's Registration Information to third parties for sales and marketing purposes without the User's consent. 

b. Site Information.

When a User accesses the NeoGrid Exchange, the NeoGrid Exchange captures, records and retains general data about the User's use of the NeoGrid Exchange, including, without limitation, the User's domain name, the web page(s) from which the User entered the NeoGrid Exchange, the web page(s) which the User visited on the NeoGrid Exchange and the amount of time the User spent on each web page of the NeoGrid Exchange (collectively, "Site Information"). NeoGrid may use Site Information to measure the Web Site's performance and Exchange activity and improve the Web Site's design and functionality. NeoGrid may also use Site Information to investigate and prosecute security violations or to identify the particular User who engaged in a transaction on behalf of a company in the case of a repudiation or other issue with the transaction. 

c. User Information.

Users communicate and exchange information with NeoGrid and other Users through their use of NeoGrid services (collectively, "User Information"). NeoGrid provides User Information to other Users of NeoGrid services who are designated through use of the NeoGrid Exchange to be provided access to such information. NeoGrid may extract information, in aggregated form only and in a form which does not specifically identify a User or a specific transaction of the User (or enable this information to be derived when combined with other data) ("Aggregated Data"), from User Information and other data collected through use of the NeoGrid Exchange. NeoGrid will only provide Aggregated Data to others for the purpose of increasing market awareness, adoption and utilization of NeoGrid services. 

d. Cookies.

A "Cookie" is a small piece of information sent by a web server to be stored on a web browser so it can later be read back from that web browser. The information collected from Cookies is currently used to improve the functionality of the NeoGrid Exchange. Cookies are also useful in allowing more streamlined log-in for Users and in preserving information between sessions. Cookies may play an integral part in assuring that information provided to Users will reflect their preferences and be most relevant to their needs. 

e. Other Information.

A User may choose to send NeoGrid a question via e-mail, register for a special service or otherwise communicate with NeoGrid. NeoGrid uses such information to communicate with Users and to enhance the NeoGrid Exchange to better meet the needs of Users.

2. Opting Out.

Participation in the NeoGrid Exchange is voluntary. To opt-out of receiving communications from NeoGrid, a User should send an e-mail to NeoGrid at Notwithstanding any such opt-out request, NeoGrid retains the right to collect, maintain and process information provided by and collected about Users on the NeoGrid Exchange and to disclose such information to comply with its reasonable contractual and legal obligations. Requests to review, change or update information previously provided by a User to the NeoGrid Exchange may be made by that User sending an e-mail to NeoGrid at 

3. Disclosure under Laws.

NeoGrid may disclose a User's Registration Information, User Information or Site Information if NeoGrid is required to make such a disclosure under applicable laws. In addition, NeoGrid reserves the right to disclose this information to report a violation or suspected violation of applicable laws to governmental authorities to which notification is appropriate or may be required. 

April 15, 2013