PRIVACY POLICY

Information Management Systems Statement of Privacy Principles

PREAMBLE Information Management Systems ("IMS") is a technology service company that serves markets primarily in North Dakota and Minnesota, as well as other areas where it holds offices. At Information Management Systems we strive to enhance our relationship with consumers. Collecting personal information about consumers is vital to this effort. This Statement of Privacy Principles describes the policies and procedures of Information Management Systems for the collection, use and dissemination of personally identifiable information about U.S. consumers in both the online and offline worlds. The Principles are based on the concepts of consumer notice and choice. Information Management Systems is actively involved in the ongoing privacy debate and is continually monitoring privacy developments. Accordingly, from time to time we may modify these Privacy Principles to reflect changes in the law, self-regulatory initiatives and technology.

COLLECTION Information Management Systems obtains personally identifiable information only if we believe the information is relevant to our relationship with a consumer or to assist us in creating a relationship with a consumer. We obtain personally identifiable information about consumers directly from consumers whenever possible, primarily in the course of providing them with products, information and services. When IMS obtains personally identifiable information from third-party sources, we use only reputable sources. In those instances where our information collection activities involve children, IMS provides special privacy protections.

NOTICE When IMS collects personally identifiable information from consumers, we inform them about who is collecting the information, why it is being collected, how it is being collected, the types of uses we will make of the information, whether we will disclose the information to third parties and the types of third parties to whom we will disclose the information, and consumers' options regarding the use of their information.

CHOICE IMS provides consumers with an opportunity to choose whether the business unit that collects their personally identifiable information may use it for purposes that are other than those for which the information was submitted, and whether the information may be shared with third parties.

USE OF PERSONAL INFORMATION Inside IMS, we use personally identifiable information only in a manner consistent with these Privacy Principles. Personally identifiable information is available only to our employees, agents and contractors who have a business reason to have access to such information. IMS uses personally identifiable information to respond to our customers and to make decisions about the goods and services that IMS or its business partners provide or hope to provide to consumers. Subject to the exercise of consumer choice, personally identifiable information may be used for different purposes, or shared with our business partners. An IMS business entity may disclose PII without providing consumers with a choice in order to protect the rights of the companies within IMS or their respective employees, agents and contractors; to protect the safety and security of visitors to web sites operated by IMS companies; to protect against fraud or for risk management purposes; or to comply with the law or legal process. In addition, if an IMS entity sells all or part of one of its businesses, makes a sale or transfer of assets or is otherwise involved in a business merger or transfer, PII may be transferred to a third party as part of that transaction.

SECURITY IMS uses reasonable administrative, technical, personnel, and physical measures to safeguard personally identifiable information in its possession against loss, theft and unauthorized use, disclosure or modification.

ACCESS, CORRECTION AND DELETION Whenever possible, each IMS business unit permits consumers to have a right to see the personally identifiable information that it has collected from them, to correct any information that is incorrect and to instruct the business unit to delete the information from its files.

REMEDIES Consumers may contact a privacy officer at each IMS business unit regarding privacy complaints and disputes.

COMPLIANCE Each IMS company will take appropriate measures to ensure compliance with these Privacy Principles.

Revised as of: November 12, 2009

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