Rev 06/11

You must be a least 18 years of age to use this web site. This web site is not intended for, nor intentionally made available to persons under the age of 18. This site is intended for the responsible use of adults engaged either directly or indirectly in the work of installing and removing nuts and bolts on industrial equipment in a workplace environment.

This Privacy Policy applies to the information collected and tracked through the websites owned by IMPERIAL-Newton Corp and its affiliates (collectively referred to as “INC”). The websites included under this policy are: www.imperial-newton.com and www.impactsockets.com (collectively referred to as the “Site”). This policy is meant to cover all information that may be collected on the Site as a whole, although the information collected on each individual website may be more limited.

Please be advised that the practices described in this Privacy Policy only apply to information gathered through the Site and do not necessarily reflect our practices with respect to information gathered offline. IMPERIAL-Newton Corp is committed to providing the highest degree of privacy to our Site visitors. INC is applying for certification to the Safe Harbor Framework, as promulgated by the United States Department of Commerce to comply with European Union privacy protection requirements. Accordingly, INC adheres to the Safe Harbor principles. To learn more about Safe Harbor, please visit www.export.gov/safeharbor.

We will keep any and all information collected at this Site strictly confidential and will not trade, sell, or otherwise convey collected information regarding its users or viewers to outside parties, except as stated in this Privacy Policy.

If you have any questions or concerns about this Privacy Policy, please contact our Privacy Agent at: IMPERIAL-Newton Corp, Attn: Privacy Agent and Legal Department, PO Box 3313, Englewood, Colorado, USA, 80155; Phone: (+1) 303-500-8881; Email: privacy@imperial-newton.com

INFORMATION COLLECTION AND USE

We collect information about your use of the Site. This information falls into two categories: Personally Identifiable Information* (hereafter “PII”), and Non-Personally Identifiable Information** (hereafter “NPI”). We want you to be informed about what information is collected, when it is collected, and what we do with the information. Unless otherwise stated, we do not share any of this information with third parties.

PII may be collected when you register on the Site, use certain features of the Site, request information about products or services, register for an event, answer a survey, inquire about employment, correspond with us, or engage in certain other activities on the Site.

We use this PII for purposes such as sending you information about products or services, responding to requests for technical or customer support, processing your transactions, tracking compliance with the Site’s rules and regulations, and other related purposes. Furthermore, we use this information to help us improve the Site, understand who uses the Site, and other associated statistical analyses.

Because INC is a globally active corporation headquartered in the United States, your PII may be transferred throughout the world to other INC offices and to third parties as stated in this Privacy Policy. By providing your information, you consent to the collection and/or transfer of your PII as described in this Privacy Policy, regardless of the geographic location in the world.

More specifically, browser information is collected when you are using the Site through log files and third party scripts that automatically collect information that may include IP addresses, browser type, internet service provider, referring/exit pages, number of clicks, location of clicks, date/time stamp, and other similar information. Log files and third party scripts may also collect general demographic information. We use these log files and third party scripts to help us analyze trends and to improve the value of the Site and services. Finally, we may also use third party scripts to collect NPI that is necessary to optimize effectiveness of our advertisements appearing on other parties’ sites, as applicable.

We also collect NPI which involves cookies, action tags, and web beacons. Cookies are stored on your computer’s hard drive and identify your web browser and the activities of your computer on the Site and other websites. Most browsers accept cookies automatically, but you may disable them. Cookies help us facilitate efficient site navigation and improve your experience on the Site. In addition, cookies may be used to store calling information if you elect to use our ‘Click to Call’ services.

Action tags, also known as web beacons or single pixel GIFs, are a web technology used to help track website usage information, such as how many times a specific page has been viewed. Action tags are not displayed on the page in a visible form. Any portion of the Site, including advertisements or emails sent on our behalf, may contain action tags. Action tags can be used to count Site users, to deliver co-branded services, or to determine whether email messages have been opened or acted upon. Action tags may be used to conduct research on behalf of certain customers, to compile statistics for advertising purposes, for auditing purposes, or to report certain aggregate information.

By using cookies and action tags together, we are able to gather information to improve the Site and measure the effectiveness of our advertising and marketing campaigns, as applicable.

Embedded URLs allow use of the Site without cookies and we may utilize them as a tracking tool to collect NPI. Embedded URLs are exhibited as plain text or encoded extensions to the URL that appear in the browser address or location toolbar. They provide limited NPI about navigation on the Site during the current session.

SECURITY

To help ensure the integrity and privacy of the PII that you provide to us, we encrypt that information using secure socket layer technology (SSL). To learn more about SSL, see the link here http://en.wikipedia.org/wiki/Transport_Layer_Security. We follow generally accepted industry standards to protect the PII submitted to us, both during transmission and once we receive it. However, there is always some risk involved in transmission of information over the internet or method of electronic storage. Therefore, we cannot guarantee absolute security of your PII.

THIRD PARTIES

At the present time we do not allow any third parties to advertise on the Site or collect information via such activities. However, you should be aware that any third-party advertisers may place or recognize unique cookies on your browser to collect NPI for the purpose of providing advertising-related services, if applicable. Third parties may also use their own cookies or action tags when you click on their advertisement or link to their websites or services on or from the Site. This Privacy Policy does not govern the use by such third-party websites or services/providers of third-party advertising.

Outside merchants may offer additional information or offer for purchase certain content, products or services. We are not responsible for the information collection or privacy practices of outside merchants. We encourage you to be aware of when you leave the Site and link to that of an outside merchant.

Except as set forth in this Privacy Policy, or as specifically authorized by you, we will not disclose to third parties any information we gather from you on the Site.

In the event of a sale, merger or other transfer of all or substantially all of the assets of INC, we reserve the right to transfer information to any such third party who acquires all or substantially all of the assets of INC by sale, merger, or transfer, or any of its divisions or business units.

We may disclose PII or NPI to our affiliates or partners which includes any person or entity that by ownership or otherwise, is controlled by INC, is under common control with INC, is acting on behalf of INC, or that directly/indirectly controls INC. Any information relating to you that we provide to our affiliates or partners will be treated pursuant to this Privacy Policy’s terms.

If we believe that we are required to disclose PII or NPI to comply with a statute, law, subpoena, search warrant, court order, or other legitimate legal process, we may do so. In our sole discretion, if we believe that disclosing PII is necessary to protect or defend our rights or property, or to protect the safety or security of our users, INC, or the general public, we may disclose PII under these circumstances.

We may provide third parties with information about you that does not allow you to be identified or contacted. Such information may be combined with similar information of other Site users. For example, we might inform third parties regarding the number of unique users who visit the Site, or the demographic breakdown of our registered Site users. The third parties to whom we may provide this information may include advertisers, commercial partners, licensees, researchers, and other similar parties.

We may employ outside contractors, such as independent contractors, vendors and suppliers, to provide specific services and products related to the Site. Such services and products may include hosting or maintaining the Site, providing credit card processing and fraud screening, providing or developing Site applications, and other similar services. In the course of providing products or services to us, the outside contractors may have limited access to information collected on the Site, including your PII. We may also provide your PII to our partners in some instances, for example, to follow up on a sales inquiry.

LINKS TO OTHER SITES

The Site contains links to other sites. Please be aware that INC is not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave the Site and to read the privacy statements of each and every website. This Privacy Policy applies solely to information collected by this Site.

UPDATE INFORMATION AND OPT-OUT CHOICE

If you wish to update your information, to change or correct it, or to no longer receive our communications, you may email our Privacy Agent at privacy@imperial-newton.com . Such updates will not have an effect on other information that we maintain, or information that we have provided to third parties in accordance with this Privacy Policy before such update. Due to the distributed nature of our business and systems, we cannot guarantee that your web-based change request will update your information immediately in all INC systems.

Please be aware that it is not reasonably possible to remove each and every record of the information you have provided to us. The need to back-up our systems to protect information from inadvertent loss means that a copy of your PII may exist in a form that will be difficult for us to locate. After receiving your update, PII stored in databases we actively use and other readily searchable media will be appropriately updated, as soon as reasonably practicable.

DISPUTE RESOLUTION

If you believe we have used your PII in violation of this Privacy Policy, you may contact us at privacy@imperial-newton.com . If after 30 days you still believe your complaint has not been satisfactorily resolved, you may require that the matter be settled by a binding independent recourse mechanism.

As an independent recourse mechanism, we recommend the American Arbitration Association (“AAA”). The AAA provides dispute resolution services using a neutral arbitrator which will provide case resolution under the applicable AAA rules. Written notice of arbitration should be delivered to INC at the email address above and such arbitration will take place in Denver, Colorado, USA, or other location agreed to by INC. Each party will bear its own costs of arbitration. The arbitrator will have no authority to award punitive damages. For more information on the AAA and the dispute resolution services, please see http://www.adr.org/drs

DISCLAIMER

By using the Site, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, you should not use the Site. You must be a least 18 years of age to use this web site. This web site is not intended for, nor intentionally made available to persons under the age of 18. This site is intended for the responsible use of adults engaged either directly or indirectly in the work of installing and removing nuts and bolts on industrial equipment in a workplace environment. We may revise this Privacy Policy at any time and such revisions may result in additional uses or disclosures of your PII or NPI. We will post the effective policy on the Site. Your continued use of the Site following the posting of changes will mean that you accept those changes.

Notations
*Personally Identifiable Information (“PII”): PII is information that can be used to identify or contact you. Such information may include your name, address, email, telephone number, fax number, company, Site user name, Site password, billing or credit card information, or other similar information.

**Non-Personally Identifiable Information (“NPI”): NPI is information that cannot alone be used to identify or contact you. Such information may include browser information, demographic information such as age, profession or gender, domain names, and other anonymous statistical data related to use of the Site. This information may be used to monitor user traffic patterns and Site usage. We may link some of this NPI to PII for purposes such as personalizing and improving your experience on the Site and for general Site evaluation.