Captira Analytical Privacy Policy Scope of this Policy Captira Analytical (“Captira”) has created this privacy policy in order to explain how we collect, use, maintain, share and protect your personal information when you use our website(s), www.captira.com and www.serve4sure.com (hereinafter “Website” or “Site”) in connection with technology services geared toward the bail bonds and process server industries. This privacy policy applies to information collected when you visit our Website. It does not apply to information collected in any other way, including information collected offline. Our Website is not directed at children under the age of 13. If you are under the age of 13, please do not use this Site. Changes to this Policy Captira reserves the right to modify this privacy policy at any time. If we make material changes to this privacy policy, the changes will be posted on this Site to alert you. Information Captira Collects Personally identifiable information is information that can identify you, such as your name and address.

Based on your relationship with us, you may be asked to provide certain personally

identifiable information as described below: 

Sales Contact, Customer Care, Billing. In order for us to contact you, you will need to provide your name, company name, position, physical address, telephone number, and an email address.

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Toolkit. In order to sign up for our Toolkit, you will need to provide your business name, physical address, telephone number, surety name, contact name(s) and email address(es), user names and credit card information.

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Client Portal. When you log in through the client portal you will need to provide us with your username and password

Non-personally Identifiable Information When you visit our Website, Captira may collect and store general Internet data, such as your internet protocol (IP) address, domain name, browser type, date and time of access, which of our web pages you visited, the referring Uniform Resource Locator (URL) and how long you spend on each page. This information may be collected to assist us in making improvements to our Website and to administer our Website. We do not link this information to any personally identifiable information. Captira may employ third party companies and individuals to facilitate these services (e.g., maintenance, analysis, audit, development). These third parties have limited access to your information and only to perform these tasks on our behalf. How Captira Uses your Information 7271641v1 4/6/15

  

The information collected through our Site may be used to: Respond to your inquiries or otherwise correspond with you if, for instance, you are contacting

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our sales, customer care or billing departments requesting product or service information or other assistance; 

Maintain your account, verify your identity, process payments, and collect debts you owe us;

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Administer, review and/or improve the Site;

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Provide you with marketing information about our services or special offers from Captira.

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To maintain For purposes permitted by your organization's agreement(s) with us (if any) for the provision of products and services;

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To maintain the security and integrity of our Website, products and services; and

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For the administration, review and/or the improvement of the content of our Website, products or services.

Information Sharing and Disclosure We may disclose information we collect through this Site to third parties as described in our Toolkit software specific terms and conditions, or as set forth below. Captira may disclose personally identifiable information: 

To Captira affiliates;

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To others providing services to Captira or as necessary to deliver Captira’s services. This includes information needed to verify an individual’s identity or for security purposes; As required by law, for subpoena or other legal process, when pertinent to judicial or

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governmental investigations or proceedings;

As necessary to investigate, take action on, or prevent suspected or actual illegal activities, fraud,

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or potential threats to safety or personal physical safety; and

To any third party that acquires or purchases Captira or its assets. That third party will assume

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responsibility for the personally identifiable information collected by us and will have the right to use and disclose it as described in this privacy policy. Cookies and Web Beacons 7271641v1 4/6/15

  

We use cookies to collect Website usage data, to improve the Site and our services, as well as your experience with the Site. Cookies are pieces of information generated by a web server and stored in your computer, ready for future access. The information can then be used to identify you when you return to the Site, to personalize web content, and in some cases suggest items of potential interest based on previous use. Captira may use both session cookies and persistent cookies. A session cookie enables certain features of the Site and our service and is deleted from your computer when you disconnect from or leave the Site. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Site. You can control cookies through your browser settings and other tools. The Site may use third-party services for analytics purposes. These third-party services collect information about you anonymously and report website trends without identifying individual visitors. These third-party services use their own cookies to track visitor interactions. Website owners can view a variety of reports containing aggregate information about how visitors interact with their website so they can improve their website. Captira does not control these third-party cookies and their use may be governed by the privacy policies of the third-party services employing these cookies. The Site also may use Web beacons, which are small strings of code that deliver a graphic image on a Web page or in an email message for the purpose of transferring data. Captira may use cookies and Web beacons to route users through the Site, customize users' experiences on the Site, to help us send you information about programs and services, and to improve the Site. Most browsers are set to accept cookies but users can change the setting to block cookies. Although disabling cookies will not interfere with your ability to access the Site, users will need to accept cookies to use certain services on the Site, including test registration. Users can disable the ability of Web beacons to capture information by blocking cookies. Third-Party Links and Websites The Site may contain links to non-Captira affiliated websites provided by third parties. Captira does not control the privacy policies or practices of these websites. You should review the privacy policy of the third-party website before providing any information through these websites. Captira is not responsible for the content or practices of any linked third-party websites, and provides these links solely for the convenience and information of visitors to the Site. Choice, Opt-Out and How We Respond to Do Not Track Signals As a user of our Website you make the decision whether to proceed with activities that request personally identifiable information, such as requesting follow-up contact regarding our services, receipt of email communications from us or receipt of our newsletter. Note however that if you do not provide the requested information, you may not be able to complete certain transactions or receive information from us.

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If you do not wish to continue receiving emails or other communications from Captira, we will provide instructions in our communications on how to opt-out of such communications. You can also notify us by email, phone or by contacting us in writing at the address listed in the Point of Contact section. Captira does not track its customers over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. To learn more about the choices you have regarding online tracking, please visit these sites: http://www.aboutads.info/choices/ http://ie.microsoft.com/testdrive/Browser/DoNotTrack/Default.html Access and Correction You may access, update or correct your personally identifiable information, or request that Captira close your account, by contacting: Captira Attn: Customer Care One Park Place 3rd Floor Albany, NY 12205 Phone: 1-866-955-7430 Data Retention Captira retains personally identifiable information as needed to provide you services or product information, to respond to your inquires, or as required by contractual, statutory or other legal obligations. Security and Confidentiality Captira strives to protect the personally identifiable information that we collect, maintain and disclose through the use of reasonable administrative, physical and technical safeguards. Our products and/or services online are transmitted through a secure sockets layer (SSL) transmission, which is a protocol for establishing a secure connection for transmission of your personal information.

Further, we have

security protocols and measures in place to ensure confidentiality of personally identifiable information and to protect the personally identifiable information we maintain about you from unauthorized access or alteration as well as unlawful disclosure. These measures include internal and external firewalls, physical security and technological security measures, as well as encryption of certain information and password protection for account information. Our security program is designed to: (1) ensure the security and confidentiality of personal information, (2) protect against any anticipated threats or 7271641v1 4/6/15

  

hazards to the security or integrity of the information, and (3) protect against unauthorized access to or use of the information that could result in substantial harm or inconvenience to any individual. In the course of business, Captira may collect or ask that you disclose Social Security numbers. To the extent practicable, Captira protects the confidentiality of all information we collect, including Social Security numbers.

Accordingly, Captira prohibits the unlawful disclosure of personally identifiable

information, including Social Security numbers, and limit access to same. Captira disposes of personally identifiable information by taking reasonable measures to protect against unauthorized access to or use of the information. Point of Contact If you have any questions or comments about Captira’s privacy policy or our privacy practices, please contact us at: Captira Attn: Customer Care One Park Place 3rd Floor Albany, NY 12205 Phone: 1-866-955-7430

Policy Revision History:

Last Updated Date

Editor

changed, and why

(MO/DD/20XX) 02/13/2015

Location of change(s), what was

Arnall Golden

Creation of website privacy policy

Gregory LLP 4/3/2015

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Matthew Phillips,

Answer inquiries, include details for

Captira

web-based signup and portal.