Ingenious Group Privacy Statement

General Information

Ingenious Group, Inc. respects the privacy of our customers, business partners, employees, job applicants, and other visitors to our websites who may choose to provide us with their personal information. We recognize the need for appropriate protections and management of personal information that you provide to us. This Privacy Statement will assist you to understand what types of information we may collect, how that information may be used, and with whom the information may be shared.

Safe Harbor Compliance

Ingenious Group, Inc. is in compliance with the U.S. Department of Commerce Safe Harbor requirements regarding the transfer of personal information from European Union member countries to the United States. The principles of Safe Harbor compliance are notice, choice, onward transfer, security, data integrity, access and enforcement. Additional information about the Safe Harbor principles and certification process can be found at http://www.export.gov/safeharbor/

Information We Collect

Personal Information is information that can be used to identify or contact a specific individual, such as a name, address, telephone number or email address. Ingenious Group may collect certain personal information from customers, business partners, and employees. Ingenious Group does not collect personal information when you visit Ingenious Group’s web sites unless you choose to provide such personal information.

Customers and Partners: On Ingenious Group web sites you can order products or services, register products, request information, subscribe to marketing or support materials, register to a secure extranet site to obtain access to product information, support, services and training. The types of personal information you provide to us on these pages may include name, address, phone number, e-mail address, user IDs and passwords, billing and transaction information, credit card or other financial information, and contact preferences.

How Personal Information is Used?

Ingenious Group will use personal information to provide customers and business partners with information and services and to help us better understand your needs and interests. Specifically, we use your information to help you complete a transaction or order, to communicate with you, to deliver products/services to you, to bill you for products/services you have purchased, and to provide ongoing service and support. Occasionally we may use your information to contact you to complete surveys that we use for marketing and quality assurance purposes. Personal information collected online may be combined with information you provide to Ingenious Group through other sources such as trade shows or seminars.

Ingenious Group may share your personal information with third parties in responding to your requests for products or services or product evaluations. Also, we may on occasion allow selected partners to send you special offers in blind mailings. Generally, you will be given the opportunity to opt out of having your personal information shared with these third parties. However, if you request information on any of our products/services, Ingenious Group may provide your information to third party distributors and resellers who may subsequently contact you directly to purchase such products/services. In these instances, you will not have the opportunity to opt out of having your information shared with these third party distributors and resellers.

Some of Ingenious Group’s websites use on-line newsgroups, chat forums and blogs that are made available to our website and service users. Any information that is disclosed in these forums becomes public information and we urge you to exercise caution when deciding to disclose any personal information. Each participant’s opinion expressed in a newsgroup is his or her own and should not be considered as reflecting the opinion of Ingenious Group.  Ingenious Group may, from time to time, send email or other notifications regarding our products and services to users who have posted to our newsgroups.  Some Ingenious Group websites may also provide facilities for engaging in “Live Chat” or “Live Support” wherein Ingenious Group personnel may have the ability to monitor the user’s areas of interest in the web site and engage in instant messaging with the user to provide additional information or answer any questions.

Except as provided in this Statement, Ingenious Group does not use your personal information for a purpose other than the stated purpose for which such information is collected.

Personal information given to Ingenious Group may be transferred within Ingenious Group across state and country borders for efficient data consolidation, storage and simplified information management.

Who Does Ingenious Group Share Personal Information With?

Ingenious Group may contract with third party service providers and suppliers to deliver partial or complete products, services and solutions for our customers. Ingenious Group may share personal information with its service providers and suppliers for the sole purpose and only to the extent needed to support the customers’ business needs. Service providers and suppliers are required to keep confidential the personal information received from Ingenious Group and may not use it for any purpose other than as originally intended.

Third party vendors, service providers and suppliers receiving personal information are expected to apply the same level of privacy protection as contained in this Privacy Statement.

Except as provided above, Ingenious Group will not share personal information with any other third parties without your permission. Ingenious Group will not sell, trade or lease your personal information to others.

Choice and Consent

Ingenious Group does not require customers, business partners or non-employee visitors to Ingenious Group websites to provide Ingenious Group with personal information. The decision to provide personal information is voluntary. If you do not wish to provide the personal information requested, however, you may not be able to proceed with particular activities or receive the full benefit for which the personal information is being requested. Except as expressly stated otherwise in this Privacy Statement, you may opt out of having Ingenious Group share personal information with third parties as described in this Privacy Statement by notifying Ingenious Group in writing of your desire to do so.

Sensitive Personal Information

Sensitive personal information is defined as personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or information specifying the sex life of the individual.

Except as provided below, Ingenious Group does not request or receive sensitive personal information from visitors to our web sites. However, Ingenious Group will treat as sensitive any personal information received from a third party where the third party treats and identifies the information as sensitive.

Data Quality

Ingenious Group makes efforts to keep your personal information accurate. We have implemented technology, processes and policies to maintain data accuracy and integrity. We will provide you with access to your information, and in some cases may make reasonable efforts to provide you with online access and the opportunity to change your information. To protect your privacy and security, we will also take reasonable steps to verify your identity before granting access to your data.

Ingenious Group will not process personal information in a way that is incompatible with the purposes for which it has been collected or authorized by the individual, or as required by applicable law.

Security

Ingenious Group is committed to making reasonable efforts to secure the personal data you choose to provide us. To protect the privacy of any personal information you may have provided to us, we employ reasonable industry-standard controls including physical and logical access controls, network security devices, and anti-virus protection. Access to sensitive data as defined in this Statement is limited to those individuals and agents having a need to know.

Other Information

Ingenious Group collects and/or logs Internet Protocol (IP) addresses, Internet domain names, the web browser and operating system used to access the Ingenious Group web site, the files visited, the time spent in each file, and the time and date of each visit.

Ingenious Group may also use cookies on some of its web sites. Cookies are identifiers that can be sent from a web site via your browser to be placed on your computers hard drive. You may elect not to accept cookies by changing the privacy or other settings on your web browser. Choosing not to accept or utilize cookies may prevent you from accessing or using certain features of our web sites. The information collected from the use of cookies is used and analyzed to improve Ingenious Group’s web sites, information and product and services and to personalize your web-browsing experience.

Ingenious Group uses the services of third party vendors to help us measure the effectiveness of our advertising and how visitors use ingeniousgroup.com, testcraft.com and onlinetests.com. To do this, we may use cookies and other tokens provided by third parties on our sites. The type of information we collect includes the pages visited, navigation patterns, time spent on our site, etc. This information helps us learn things such as what product information is of most interest to our customers, and what kinds of offers our customers may like to see. Although our third party vendors log the information coming from our site on our behalf, Ingenious Group determines how that data may and may not be used and may not offer opt-out functionality for this information collected on these websites.

Links to Non-Ingenious Group Web Sites and Third Parties

The Ingenious Group web sites may provide links to third-party web sites for your convenience and information. If you access those links, you will leave the Ingenious Group web site. Ingenious Group does not control those sites or their privacy practices, which may differ from our own. We do not endorse or make any representations about third party web sites. The personal data you choose to give to unrelated third parties is not covered by the Ingenious Group Privacy Statement. We encourage you to review the privacy policy of any company or website before submitting your personal information. Some third party companies may choose to share their personal data with Ingenious Group; that sharing is governed by that third party company’s privacy policy.

Verification

Ingenious Group will engage in periodic self-assessment to verify that it continues to be in compliance with this Privacy Statement.

Contact Information

If you have any questions regarding this Privacy Statement or believe that the privacy of your personal information has not been respected, you may make a written submission to the attention of Ingenious Group’s Legal Administration Office, P.O. Box 317, New Hartford, CT 06057.

Dispute Resolution

Ingenious Group agrees to handle all disputes involving the transfer of personal data from the EU to the U.S. using the Better business bureau Online dispute resolution procedures applicable to Safe Harbor.

Except as provided above, dispute resolution for all other individuals shall be in accordance with applicable law.

Changes to this Statement

Ingenious Group will review and update this Privacy Statement periodically, and will note the date of its most recent revision below.

Revised: June 2007