1. Introduction

Your privacy is important to us. We are StarCite, Inc. ("StarCite" or "we" or “us”). We post this privacy statement (the “Privacy Statement”) so that you are aware of the information we collect, how it is handled and with whom it is shared.

This Privacy Statement relates to the following websites: www.starcite.com, www.seeuthere.com, www.mpoint.com www.regweb.com, (together, the “StarCite Websites”) and services provided through StarCite Websites or StarCite-Powered Websites (“StarCite Services”). A “StarCite-Powered Website” shall mean a website not owned by StarCite but which has a license from StarCite to utilize certain StarCite technologies. A “User” means any individual who has access to or uses a StarCite Website or StarCite-Powered Website, including buyers of StarCite Services, attendees of meetings organized through a StarCite Website or StarCite-Powered Website, visitors to Public Websites, and other employees and agents of corporate clients and Suppliers.

Changes in this Privacy Statement

If we decide to change our privacy policy, we will post those changes to this privacy statement, the home page, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by email, or by means of a notice on our home page.

Testimonials

We post customer testimonials on our web site which may contain personally identifiable information such as the customer's name. We do obtain the customer's consent prior to posting the testimonial to post their name along with their testimonial.

Job Site References

StarCite may ask you for third party Personally Identifiable Information (PII), such as your name, for job references purposes only and that PII is not used for any other purpose.

What Is Covered in this Privacy Statement.

This Privacy Statement contains information on how StarCite processes certain categories of data relating to individual persons:-

• If you are a visitor to the portions of StarCite Websites or a StarCite-Powered Website, that can be accessed without a password (our "Public Website"), and are not a resident of any European Union member state, please see the section "Public Website Privacy" below for a comprehensive description of our data processing practices with respect to data about you. We refer to you as a "Public Website Visitor" in this Privacy Statement.
• If you are a User and are not a resident of any European Union member state, please see the section "User Privacy" below for information on our data processing practices with respect to data about you held by StarCite.
• If you are a User or Public Website Visitor, and are a resident of any European Union member state, please also see the section "EU Safe Harbor Privacy Statement" below for a comprehensive description of our data processing practices with respect to data about you in reference to the EU Safe Harbor Principles. We refer to data relating to you as an identifiable individual as "EU Personal Data."

What Is Not Covered in this Privacy Statement.

We cover only our data processing practices described in this Privacy Statement. Without limitation, this Privacy Statement does not cover data that we collect offline, on businesses or legal entities or on our employees.

How You Can Contact Us.

If you have questions or concerns regarding this Privacy Statement, you should first contact us by email at privacy@starcite.com. You can also write to us at Attention: Director of Information Security, StarCite Inc., 1650 Arch Street, 18th Floor, Philadelphia, PA 19103, USA. StarCite will respond to personal information change requests within 30 days of receiving such requests.

What to Do If You Do Not Get A Satisfactory Response.

We will try our best to see that you will always get a satisfactory response from us. As part of this effort, we also offer you recourse to TRUSTe®, an independent, nonprofit organization dedicated to enabling individuals and organizations to establish trusting relationships based on respect for personal identity and information in the evolving networked world. StarCite is a licensee of the TRUSTe Privacy Program. This Privacy Statement covers the URL’s www.starcite.com, www.seeuthere.com, www.mpoint.com www.regweb.com. TRUSTe's certification covers the gathering and dissemination of information described in this Privacy Statement, but not any of our other data processing practices. If you do not receive an acknowledgment of an inquiry sent to StarCite, or if your inquiry has not been satisfactorily addressed, you may then contact TRUSTe at http://www.truste.org/consumers/watchdog_complaint.php. TRUSTe will then serve as a liaison with StarCite to resolve your concerns.

2. Overview of StarCite Services

2.1 Suppliers of Services to Corporate Clients

StarCite provides access to its applications via StarCite Websites and/or StarCite-Powered Websites to suppliers of services to corporate clients (“Suppliers”). These Suppliers include hotels, convention and visitors bureaus, and destination management companies.

2.2 Buyers of Services for Corporate Clients

Individuals and companies (“Buyers”) use StarCite’s technology via StarCite Websites or StarCite-Powered Websites on behalf of corporate clients to manage meetings, and to purchase services for these meetings and events from Suppliers. The term “User” means any individual who has access to or uses a StarCite Internet-based system, including Buyers, attendees, and other employees and agents of corporate clients and Suppliers.

2.2 Attendees of Meetings Planned by Corporate Clients

Attendees use StarCite Services when invited by a corporate client to attend a meeting. They do so by viewing a StarCite-Powered Website that contains questions created by the corporate client. By responding to these questions, the attendee gives the corporate client information about the attendee’s plans for attending that specific meeting.

3. Public Website Privacy Statement

What Is Covered by This Section. The paragraphs in this section describe how StarCite uses and disseminates information collected about Public Website Visitors through our Public Website; it does not cover any other data processing activities.

Your Use of the Public Website Implies Your Consent.

Your use of a Public Website signifies your acceptance of this Privacy Statement. If you do not agree or are not comfortable with any policy described in this Privacy Statement, your remedies are to discontinue your use of the Public Website or to follow the other instructions described elsewhere in this Privacy Statement.

If You Don't Volunteer Any Personal Data, We Won't Collect Any Through the Public Website.

We use cookies and various traffic tracking technologies to monitor the use of our Public Websites. We collect such data related to Internet Protocol (“IP”) addresses, browser type, and cookies but do not link it to any personally identifiable information (such as names and email addresses) that you may voluntarily submit to us through other means.

Use of Cookies.

Disclosure to Third Parties.

In the course of our normal business activities, we do not share personally identifiable data about Public Website Visitors with any independent third parties. In particular, we are not in the business of renting or loaning personally identifiable information to independent third parties.

Nevertheless, StarCite may have to disclose such information to third parties when required by law or under the good-faith belief that such disclosure is necessary in order to conform to applicable law, comply with legal process served on StarCite, or to protect the property or interests of StarCite, its agents and employees, or the personal safety of others, or the public. Under such circumstances, StarCite may be prohibited by law, court order or other legal process from providing notice of the disclosure. In addition, where permitted by law, StarCite reserves the right to not provide such notice in its sole discretion.

As its business evolves, StarCite may sell, transfer or otherwise share some or all of its assets, including personally identifiable information, in connection with a merger, reorganization, or sale of assets, or in the event of bankruptcy.

Security of Data.

The security of your personal information is important to us. When you enter sensitive information (such as credit card number and/or social security number) on our registration or order forms, we encrypt that information using secure socket layer technology (SSL). (To learn more about SSL, go to http://en.wikipedia.org/wiki/Secure_Sockets_Layer).

We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

If you have any questions about security on our Web site, you can send email us at security@starcite.com.

4. User Privacy Statement

4.1 Suppliers of Services to Corporate Clients

4.1.1 General Information

If you are an employee or agent of a Supplier and are a User, the following terms are applicable to you:

• We will only use your personal information for the purposes of [(a) providing StarCite Services; (b) facilitating communications between you and third parties; (c) our marketing activities; and (d) all credit and other financial checks in relation to any payments made by you for StarCite Services]. StarCite does not resell or transfer e-mail addresses or any other personal user information to third parties without that User's permission.
• Users have a right to access personal information about them that StarCite holds. Users have the right to correct, amend, or delete that information where it is inaccurate, except where the burden or expense of providing access would be disproportionate to the risks to the individual's privacy in the case in question, or where the rights of persons other than the individual would be violated.
• Registering to use [a StarCite-Powered website [or] StarCite Website] requires Users to give us contact information (like your name, phone number, street and e-mail address). We use this customer contact information to send you Requests For Proposals (RFP) and other requests for goods and services from our corporate clients, as well as information about StarCite. Your contact information is also used to contact you when necessary. You may opt-out of receiving future mailings; please see the “Opting Out” section below.
• Users can update their records in the StarCite system by accessing the user information administration feature in the system or by sending an email to privacy@starcite.com. You can also write to us at Attention: Director of Information Security, StarCite Inc., 1650 Arch Street, 18th Floor, Philadelphia, PA 19103, USA.

4.1.2 Opting Out

Users must opt in to receive special offers and other messages from StarCite or its partners. However, at any time, Users may opt out of such messages by updating their profile or sending an e-mail to privacy@starcite.com to change information previously provided, remove your information from our database, cancel any future communications or to cancel StarCite Services. You can also write to us at Attention: Director of Information Security, StarCite Inc., 1650 Arch Street, 18th Floor, Philadelphia, PA 19103, USA.

4.2 Buyers of Services for Corporate Clients

4.2.1 General Information

If you are a User who is a Buyer, the following terms are applicable to you:

• We will only use your personal information for the purposes of [(a) providing StarCite Services; (b) facilitating communications between you and third parties; (c) our marketing activities; and (d) all credit and other financial checks in relation to any payments made by you for StarCite Services]. StarCite does not resell or transfer e-mail addresses or any other personal user information to third parties without that User's explicit permission prior to any such transfer.
• The corporate clients are expected to ensure all information related to the Users are collected and processed in accordance with the European legislation regarding data protection or in accordance with the European Union - United States Safe Harbor Principles. As a result, the corporate clients have informed StarCite that the Users gave their explicit consent to have their sensitive data processed. StarCite will be providing analysis and reports based on aggregated User data to other third parties as a natural course of doing business. These reports and analysis of aggregated data will never include individual personal or company names.
• Users have a right to access to personal information about them that StarCite holds. Users have the right to correct, amend, or delete that information where it is inaccurate, except where the burden or expense of providing access would be disproportionate to the risks to the User's privacy in the case in question, or where the rights of persons other than the User would be violated.
• Registering to use StarCite Services requires Users to give us contact information (like your name, phone number, street and e-mail address). We use this contact information to allow Suppliers to send proposals to you in response to Requests For Proposal (RFP) that you have sent. We will also use this contact information to send you information about our systems and StarCite. Your contact information is also used to contact you when necessary (for example, following up on a request from you for technical support). You may opt-out of receiving future communications; please see the “Opting Out” section below.
• Users can update their records in the StarCite system by accessing the user information administration feature in the system or by sending an email to privacy@starcite.com. You can also write to us at Attention: Director of Information Security, StarCite Inc., 1650 Arch Street, 18th Floor, Philadelphia, PA 19103, USA.

4.2.2 Opting Out

Buyers must opt in to receive special offers and other messages from StarCite or its partners. However, at any time, Buyers may opt out of such messages by updating their profile or sending an e-mail to privacy@starcite.com to change information previously provided, remove your information from our database, cancel any future communications or to cancel our service. You can also write to us at Attention: Director of Information Security, StarCite Inc., 1650 Arch Street, 18th Floor, Philadelphia, PA 19103, USA.

4.3 Attendess of Meetings Planned by Corporate Clients

Attendees use StarCite Services when invited by a corporate client to attend a meeting. They do so by viewing a [StarCite Website [or] StarCite-Powered Website] that contains questions created by the corporate client. By responding to these questions, the attendee gives the corporate client information about the attendee’s plans for attending that specific meeting.

If you are an attendee using StarCite Services to register for a meeting planned by a corporate client, the following are applicable to you:

4.3.1 General Information

• Your personal information, certain financial information and other pertinent information will be collected when you register for an event on a [StarCite-Powered Website [or] StarCite Website]. Any information that you provide will be stored on a system managed by StarCite.
• The information you provide is the property of the corporate clients to whom you have provided the information. The corporate client is regarded as the Data Controller.
• The information is completely accessible by our corporate clients and its employees or agents. Each StarCite corporate client has it own privacy statement, which can be viewed by clicking on the appropriate links. By providing your personal information to StarCite for use by a corporate client or a Supplier (e.g. to make reservations with a particular hotel) you consent to StarCite providing a copy of your personal information to that corporate client or supplier for collection, processing and any further transfer in accordance with the privacy statement (if any) of that corporate client or supplier. StarCite in not responsible for any actions of its corporate clients or Suppliers.
• Your data is purged from the StarCite system by our corporate clients based on their procedures and needs. The corporate clients have agreed with StarCite that they will not keep the data for longer than is necessary for the purposes for which your data were collected or for which your data are further processed.
• The corporate clients have agreed with StarCite that they collect only adequate, relevant and not excessive data in relation to the purposes for which they are collected and/or further processed.
• The corporate clients have agreed with StarCite that all information related to attendees are collected and processed in accordance with the European legislation regarding data protection or in accordance with the Safe Harbor Principles. As a result, the corporate clients informed StarCite that the Users gave their explicit consent to have their sensitive data processed. StarCite may provide analysis and reports based on aggregated user data to other third parties as a natural course of doing business. These reports and analysis will never include individual personal or company names.
• Some of our corporate clients may process credit cards manually. Their employees or agents will access the StarCite system to obtain such information to do the processing.

4.3.2 Opting Out

StarCite corporate clients may use various opt-out methods, depending upon the individual corporate client’s needs and the requirements for each specific meeting. Corporate clients may include in their registration web site an opt-out question, an unsubscribe email reply, or other means when removal from the invitee or attendee list is an option. Sometimes opt-out is not an option where collected data and meeting attendance is mandatory (e.g. for collecting data from attendees at an internal corporate meeting). StarCite does not sell or distribute any attendee data to any third party (other than to the applicable corporate clients and Suppliers) without their explicit authorization to do so.

5. EU Safe Harbor Privacy Statement

5.1 General Information

What Is Covered by this Section. The paragraphs in this section describe how StarCite collects, uses, and disclose EU Personal Data, which is certain personally identifiable information that StarCite receives in the United States about individuals resident in the European Union (the "EU"). StarCite complies with the US-EU Safe Harbor Privacy Principles as set forth by the U.S. Department of Commerce ("the Principles"), with respect to the collection, use, and retention of data from the EU. Compliance with the Principles may be limited, however in certain cases to the extent necessary to meeting national security, public interest or law enforcement requirements.

For further background and information about the EU Safe Harbor, please refer to the U.S. Department of Commerce's website at http://www.export.gov/safeharbor.

5.2 Definitions used in this EU Safe Harbor Privacy Statement

“Adequate” or “adequacy” shall have the meaning ascribed in the EU Directive on Data Processing 95/46/EC.

“Data Controller” shall mean the controller who transfers Personal Data as defined by the EU Directive on Data Processing 95/46/EC

"Personal Data" means data that is (a) transferred to the United States from the EU, (b) is about, or relates to, an identified or identifiable individual, (c) can be linked to that individual, and (d) is recorded. Personal data may include, among other things, an individual's name, address, phone number, e-mail address, financial and banking details, or social security or national health insurance or an equivalent number. For further clarity, the term "Personal Data" does not include data that pertains to a specific individual, but from which that individual cannot reasonably be identified. Unless otherwise indicated, references herein to Personal Data include sensitive Personal Data (as defined below).

"Sensitive Personal Data" is a subset of Personal Data that indicates an individual's medical or health condition, racial or ethnic origin, political opinions, religion, union membership, sexual orientation, or actual or alleged criminal activity.

“Users” shall have the definition set out in section 1 above and, in addition, be deemed to include Public Website Visitors.

5.3 Notice

StarCite collects Personal Data from and about individuals via StarCite Websites and StarCite-Powered Websites for the purposes of [(a) providing StarCite Services; (b) facilitating communications between you and third parties; (c) our marketing activities; and (d) all credit and other financial checks in relation to any payments made by you for StarCite Services].

StarCite may disclose Personal Data to third parties when such disclosure is necessary or appropriate for StarCite' provision of such StarCite Services to its clients or otherwise for StarCite' operation of its business. StarCite may also disclose Personal Data to third parties in circumstances described in the "Onward Transfer to Third Parties" section below.

Any complaints or questions should be first sent to us by email at privacy@starcite.com. You can also write to us at Attention: Director of Information Security, StarCite Inc., 1650 Arch Street, 18th Floor, Philadelphia, PA 19103, USA. StarCite will respond to personal information change requests within 30 days of receiving such requests.

When StarCite receives Personal Data from the EU merely for processing purposes and does not control the collection of the Personal Data, StarCite may not provide notification of this EU Safe Harbor Privacy Statement to the Users to which such Personal Data relates. In such event, StarCite reserves the right to process Personal Data in the course of providing StarCite Services to Buyers, Suppliers or other of its clients or otherwise for StarCite' operation of its business without the knowledge of the Users involved.

5.4 Choice

Except as provided below, StarCite gives Users from whom it collects Personal Data the opportunity to opt out from allowing StarCite to disclose his or her Personal Data to a third party or to use it for a purpose incompatible with the purpose for which it was originally collected. For Sensitive Personal Data, StarCite requires such User to affirmatively opt in and give consent if the data is to be disclosed to a third party or used for a purpose other than its original purpose.

Users desiring to exercise their opt-out rights should first contact us by email at privacy@starcite.com. You can also write to us at Attention: Director of Information Security, StarCite Inc., 1650 Arch Street, 18th Floor, Philadelphia, PA 19103, USA. Users from whom Sensitive Personal Data is sought will be advised of how to opt in and give the required consent at the time the data is collected, if the data is to be disclosed to a third party or used for a purpose other than its original purpose.

When StarCite receives Personal Data merely for processing purposes and does not control the collection of the Personal Data, StarCite may not provide such choices to the Users to whom such Personal Data relates.

5.5 Onward Transfer to Third Parties

StarCite may disclose Personal Data to a third party if (a) StarCite has received the applicable User's permission to make the disclosure, (b) the disclosure is required by law, (c) the disclosure is reasonably related to the sale or other disposition of all or part of StarCite' business, (d) the information in question is publicly available, and/or (e) the disclosure is reasonably necessary for the establishment of a legal claim.

Additionally, StarCite may disclose Personal Data to a third party if the disclosure is to a StarCite affiliate or to persons or entities providing services on behalf of StarCite, a StarCite client, or the individual (each a "transferee"), consistent with the purpose for which the information was obtained, if the transferee, with respect to the Personal Data in question (a) is subject to law providing an adequate level of privacy protection including, without limitation, transferees that are located within the EU or transferees that are otherwise subject to an adequacy, finding (b) has agreed in writing to provide an adequate level of privacy protection, and/or (c) subscribes to the Principles.

5.6 Security

StarCite takes security measures designed to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures designed to guard against unauthorized access to systems where we store Personal Data.

StarCite restrict access to Personal Data to StarCite employees, contractors, customers and partners who need to know that information in order to operate, develop or improve our services. These individuals and third parties are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

5.7 Data Integrity

StarCite takes reasonable steps to ensure that Personal Data is reliable, accurate, complete, current and relevant for the purposes for which it was collected.

5.8 Access

Upon request and consistent with any applicable client commitments, StarCite will permit Users to access their Personal Data and to correct any erroneous information. The User may need to provide sufficient identifying information, such as, without limitation, name, address, birth date, and social security or national health insurance or an equivalent number. Such access may be denied or limited by StarCite if providing such access is unreasonably burdensome, expensive under the circumstances, and/or if in giving such access would violate another person's rights. In some circumstances, StarCite may charge a reasonable fee for access to Personal Data. Users can contact the StarCite customer services team at service@starcite.com to request access to change personal information.

5.9 Enforcement

StarCite will conduct an annual self-assessment to ensure that this Statement is published and disseminated within StarCite and on its website and that it conforms to the Principles. In addition, StarCite has deployed internal processes to monitor StarCite' compliance with the Principles and to address all questions or complaints. StarCite will also self-certify annually with the U.S. Department of Commerce as being in compliance with the Principles. [StarCite participates in TRUSTe's EU Safe Harbor Seal Program, which verifies our compliance with the Principles.]

Users may raise any concerns or complaints regarding their Personal Data directly with StarCite by first contacting us by email at privacy@starcite.com. You can also write to us at Attention: Director of Information Security, StarCite Inc., 1650 Arch Street, 18th Floor, Philadelphia, PA 19103, USA. If a User raises such a concern or complaint, StarCite will investigate the matter and attempt to resolve all issues to the satisfaction of the individual raising the concern or complaint.

What If You Do Not Get A Satisfactory Response.

We will try our best to see that you will always get a satisfactory response from us. As part of this effort, we also offer you recourse to TRUSTe®, an independent, nonprofit organization dedicated to enabling individuals and organizations to establish trusting relationships based on respect for personal identity and information in the evolving networked world. StarCite is a licensee of the TRUSTe Privacy Program. This EU Safe Harbor Privacy Statement covers the URL’s www.starcite.com, www.seeuthere.com, www.mpoint.com www.regweb.com. TRUSTe's certification covers the gathering and dissemination of information described in this EU Safe Harbor Privacy Statement, but not any of our other data processing practices. If you do not receive an acknowledgment of an inquiry sent to StarCite, or if your inquiry has not been satisfactorily addressed, you may then contact TRUSTe at http://www.truste.org/consumers/watchdog_complaint.php. TRUSTe will then serve as a liaison with StarCite to resolve your concerns.

5.10 Modification and Amendment

StarCite may modify or amend this EU Safe Harbor Privacy Statement from time to time by posting a revised statement on the web at www.starcite.com, www.seeuthere.com, www.mpoint.com www.regweb.com. If StarCite amends this EU Safe Harbor Privacy Statement, the new statement will apply to Personal Data previously collected only insofar as the rights of the individuals affected are not reduced. So long as StarCite adheres to the Principles, StarCite will not amend this EU Safe Harbor Privacy Statement in a manner inconsistent with the Principles.