Privacy Statement

Your privacy is very important to us. This privacy policy discloses how DBM Group (“DBMG”) collects, protects, uses and shares personal information gathered about you. Our privacy practices are consistent with:

All Personal Information is collected in a fair and non-intrusive manner, with your voluntary consent. Personal Information is not accessible to anyone outside the specific function for which it is collected. DBMG respects the privacy of our DBMG customer, and other visitors to our websites who may choose to provide personal information. We recognize the need for appropriate protections and management of personal information that you provide to us. This Privacy Policy 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. This Privacy Policy explains DBM Group’s practices regarding the information collected online from users of the DBM Group’s corporate website located at www.dbmgroup.com and thru any website operated by or on behalf of DBMG.

This Privacy Policy applies to all information gathered for and on behalf of DBMG, whether in writing, verbally or electronically, through any website operated by or on behalf of DBMG, including, but not limited to, www.dbmgroup.com, together with any and all future websites that are operated by or on behalf of DBMG. By using www.dbmgroup.com, or participating in any program or service managed by DBMG, you consent to the data collection and use practices described in this Privacy Policy. If you have questions about this Privacy Policy or the protection of your information, please contact the Privacy Officer.

BY SUBMITTING PERSONAL INFORMATION TO DBMG, AND/OR BY ACCESSING AND USING THE WEBSITE, YOU AGREE THAT DBMG MAY COLLECT, USE AND DISCLOSE SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY AND THE TERMS AND CONDITIONS AS PERMITTED OR REQUIRED BY LAW.

In addition to consenting to this Privacy Policy and the Terms and Conditions, including any relevant supplemental policies, you expressly consent to DBMG sharing the information that you have provided, as described herein. DBMG may share information with companies that provide support services to it, such as credit card processors, technical support providers, or other service providers or for enforcing or investigating transactions or business operations, because these companies may need information about you in order to perform their functions. These companies are not authorized to use the information DBMG shares with them for any other purpose, but DBMG does not control these companies. You agree that DBMG and those with whom it shares information (the "Recipients") may disclose and transfer your information worldwide, including in and outside the United States, Canada, and other jurisdictions serviced by DBMG, for any purpose relating to DBMG’s operations and programs.

If DBMG or a Recipient is required to provide notice of unauthorized access of certain security systems, you agree that DBMG, or the Recipient, may do so when required or voluntarily by posting notice on the Website or sending notice to any email address DBMG or the Recipient has for you, in the good faith discretion of DBMG or the Recipient. You agree that notice to you will count as notice to any other individual for whom you are acting and agree to provide the notice to any such individual.

DBM Group’s Commitment: Adhering to the 10 Privacy Principles

In Canada, "Fair Information Practices" regarding your personal information are reflected in a series of 10 Privacy Principles developed by the Canadian Standards Association and incorporated into Canadian federal privacy legislation, the Personal Information Protection and Electronic Documents Act ("PIPEDA"). DBM Group adheres to the 10 Privacy Principles as follows:

Principle 1 — Accountability

DBMG is responsible for personal information under its control and has designated a Privacy Officer who is accountable for DBMG’s compliance with this Privacy Policy and the applicable privacy legislation for Canada and its provinces.

Principle 2 — Identifying the Purposes for collection of Personal Information

DBMG will identify the purposes for which your personal information is collected at or before the time the personal information is collected. Some of the identified purposes for which DBMG collects, uses, and discloses your personal information are described below in this Privacy Policy. If we intend to collect, use or disclose your personal information for additional purposes, we will seek your consent.

Principle 3 — Consent for Collection, Use of Disclosure of Personal Information

DBMG will obtain your informed consent for the collection, use, or disclosure of your personal information, except as permitted by law.

Principle 4 — Limiting Collection of Personal Information

DBMG will limit the collection of personal information, both the amount and the type of information, to that which is necessary for the purposes identified by DBMG. DBMG will collect your personal information by fair and lawful means, and not by misleading or deceiving you about the purpose for which information is being collected.

Principle 5 — Limiting Use, Disclosure, and Retention of Personal Information

DBMG will not use or disclose personal information for purposes other than the identified purposes for which it was collected, except with your consent or as required or permitted by law. DBMG will retain your personal information only as long as necessary to fulfill the identified purposes.

Principle 6 — Accuracy of Personal Information

DBMG will attempt to make sure that your personal information will be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.

Principle 7 — Security Safeguards

DBMG will protect your personal information by security safeguards appropriate to the sensitivity of the information.

Principle 8 — Openness Concerning Policies and Practices

DBMG will make readily available to you specific information about our policies and practices relating to the management of personal information.

Principle 9 — Individual Access to Personal Information

Upon written request, subject to certain exceptions, DBMG will inform you of the existence, use, and disclosure of your personal information and will give you access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

Principle 10 — Challenging Compliance

You have the right to address a challenge concerning compliance with this Privacy Policy to DBMG’s Privacy Officer.

Type of Information We May Collect

DBM Group’s websites are designed as business marketing tools for affiliate organizations. Users are asked to create accounts with their business contact information. Non-personal information is information that is already a matter of public record or knowledge. Business contact information is considered non-personal information and not subjected to special protection and it can be routinely shared with anyone inside or outside of the business. Business contact information shall include but is not limited to: business name, business address, business telephone number, and is not considered personal information in certain jurisdictions.

Personal Information is defined as any information concerning the personal or material circumstances of an identified or identifiable individual. Personal Information shall include but is not limited to: name, home address, home zip code, home telephone number, mobile phone number, or email address.

Internet Users - Cookies, Aggregate Information

Cookies - we use data collection devices such as "cookies" on certain web pages to help analyze our web page flow and measure site effectiveness. Cookies are pieces of information a website sends to an individual’s hard drive while they are viewing the website. Cookies allow the website to remember important information that will make your visit to the site more useful. We use cookies to help improve your future visits. If you do not wish to receive a cookie or if you wish to set your browser to warn you each time a cookie is being sent, or if you wish to turn off all cookies, use the options on your browser to assist you. Please note that by turning cookies off, you will not have access to many features available on our website.

Aggregate Information – is used to measure the visitors’ interest in, and use of, various areas of the Website and the various programs that DBMG administers, DBMG will rely upon aggregate information, which is information that does not identify you, such as statistical and navigational information. With this aggregate information, DBMG may undertake statistical and other summary analyses of the visitors' behaviors and characteristics.

Children and Data Collection

DBMG websites are business-to business websites and are not intended to be utilized by children or in any way encourage participation of any minor. DBMG adheres to the United States Federal Privacy Protection standards as stated in the Children's Online Privacy Protection Act (“COPPA”). We care about the safety of children. We will not knowingly allow anyone under 13 to provide us any personally identifying information. Children under 13 years of age are required to obtain the express permission of a parent or guardian before submitting any Personal Information about themselves (such as their names, e-mail address, and phone number) over the Internet. If a child has provided us with personally-identifiable information without the consent of a parent or guardian, the parent or guardian of that child should contact the Privacy Officer immediately. We will use reasonable efforts to promptly delete the child's information from our servers.

Our Use of Your Information

We use your Personal Information to facilitate the services you request. We have tailored our Privacy Policy to adequately inform you of the use of your Personal Information.

Sharing of Personal Information

We may share Personal Information for internal business purposes. Except as described in this Privacy Policy, DBMG will not share Personal Information with a third party, unless a customer requests, consents to such disclosure, or disclosure is required or authorized by law. DBMG reserves the right to disclose Personal Information to a third party if a law, regulation, search warrant, subpoena, or court order legally requires or authorizes us to do so.

Security

We endeavor to protect your Personal Information using physical, electronic or procedural security measures appropriate to the sensitivity of the information in our control. These measures include safeguards to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use and modification.

We safeguard your Personal Information on the Internet by using industry-standard practices. Although "guaranteed security" does not exist either on or off the Internet, we make commercially reasonable efforts to make the collection and security of such information consistent with our Privacy Policy and all applicable laws and regulations. We maintain physical, electronic and procedural safeguards as appropriate to safeguard your Personal Information.

Currently, our website utilizes a variety of different security measures designed to protect Personal Information of users both inside and outside DBMG, including the use of encryption mechanisms (e.g., Secure Socket Layers or SSLs), password protection, internal data encryption, firewalls, intrusion dection systems and other security measures to help prevent unauthorized access to your personally identifiable information. This helps maintain the confidentiality, privacy, and integrity of your transactions, and helps to protect your confidential information - such as credit card numbers, online forms, and historic order information from loss, misuse, interception and hacking.

Phishing

Identity theft and the practice currently known as “phishing” are of great concern to DBMG. Accordingly, safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your account ID, login password, Social Security Number or National Identification numbers in a non-secure or unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website.

Storage, Retention and Accuracy of Personal Information

DBMG ensures that Personal Information is safeguarded against loss, access, use, modification, disclosure or other misuse. All reasonable steps are taken to prevent unauthorized use or disclosure of your Personal Information.

DBMG will retain your Personal Information only for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws, and your consent to such purpose(s) remains valid after termination of our relationship with you.

We take all reasonable steps to ensure that your Personal Information is accurate, up-to-date, complete, relevant and not misleading.

Access, Control and Update Information About You

We want to be sure that we keep only the most accurate and up-to-date Personal Information in our records. Therefore, whenever you believe that your Personal Information needs to be updated, you can contact us through the "contact us" section on www.dbmgroup.com to update your contact information. You may choose at any time to remove your name, telephone numbers, and postal and email addresses from the lists we use to send marketing notices by sending us an email.

To protect your privacy, we will take reasonable steps to help verify your identity before granting access or making changes.

Contact Information

You may contact thePrivacy Officer to access, correct or delete your Personal Information.

If you have any questions or complaints, please contact the Privacy Officer. The Privacy Officer can be reached by telephone at: 1-714-727-0800; by Fax at: 714-838-0327; or by mail at DBMG, Attn: Privacy Officer, 5 Peters Canyon Rd., Suite 150, Irvine, CA 92606. We will address your concern and attempt to resolve any problem.

Social Media and Online Engagement

DBMG uses a variety of new technologies and social media options to communicate and interact with consumers. These sites and applications include popular social networking and media sites, open source software communities and more. To better engage the public in ongoing dialog, DBMG uses platforms including Twitter. These technologies are not exclusively operated or controlled by DBMG.

When interacting with the DBMG presence on those websites, you may reveal certain personal information to DBMG or to third parties. Except when used by DBMG employee’s for the purpose of responding to a specific message or request, DBM Group will not use, share, or retain your personal information.

Twitter: DBM Group uses Twitter to send short messages (up to 140 characters) or 'Tweets' to share information about DBMG programs with visitors, and respond to comments and inquiries sent via Twitter to DBMG related Twitter accounts. While visitors may read the DBMG Twitter feeds without subscribing to them, visitors who want to subscribe to (or follow) DBMG Twitter feeds must create a Twitter account at www.twitter.com. To create an account, you must provide some personal information, such as name, user name, password and email address. Visitors have the option to provide additional personal information including a short biography, location or a picture. Most information you provide for a Twitter account is available to the public, but you can modify how much of your information is visible by changing your privacy settings at the Twitter.com Web site. DBMG staff members monitor the number of subscribers and respond to comments and queries via Twitter, but the staff never takes possession of the personal information belonging to Twitter followers. DBMG does not collect, maintain, disclose or share any information about people who follow DBMG’s Twitter accounts. The Twitter privacy policy is available at: http://twitter.com/privacy.

Changes to our Privacy Policy

DBMG will update this Privacy Policy occasionally. When DBMG posts changes to this Privacy Policy, we will also revise the "Last Updated" date below on DBM Group’s Privacy Policy. If there are material changes to this Privacy Policy, DBMG will notify you b a notice on our home page. DBMG encourages you to review this Privacy Policy periodically to be informed of how DBMG is protecting your information and to be aware of any changes to the Privacy Policy. Your continued use of the site after the posting of any amended Privacy Policy shall constitute your agreement to be bound by any such changes. This Privacy Policy is incorporated into any Terms and Conditions governing the various websites and any programs or services operated or managed on or behalf of DBMG. Any changes to this Privacy Policy are effective immediately after being posted by DBMG.

Last Updated 10/23/2012