Privacy Policy and Internet Privacy Statement

At PrimePay we appreciate your concerns about privacy and confidentiality. Our clients have trusted us with their payroll needs since 1986, and it is important for us to maintain a high level of integrity. We want you to understand how we protect your privacy.

Information Collection

With few exceptions, the information of yours that we collect or handle is information that you give us so that we can provide the services you desire from PrimePay, i.e., employee and payroll data. In addition, certain services may require us to request a standard credit report on your business from a credit reporting agency or specific credit references. In some instances you may contact PrimePay or our Web site, or PrimePay may contact you, as a result of a referral from a co-branded business partner who may supply us with limited contact information pursuant to a national program offering special benefits to you. In other cases, we may get your publicly available contact information from sources such as the Internet, professional or business organizations, or the Yellow Pages, or as a result of a personal referral from your accountant or bookkeeper, from another PrimePay client or from any other person. Finally, our Web site may retain certain personally identifiable or non-personal information from visitors to the site for internal maintenance and research purposes, which is discussed more fully below.

General Privacy Policy

Practically all of the services PrimePay provides you (our "client") involve the handling or processing of your contact information, employee compensation, withholding and benefits data, and in many cases individual client and employee banking information. It is also possible that, during the course of performing our services, talking to you, visiting your offices, or receiving information or communications from you over the Internet, we may encounter other information relating to your business that is proprietary or confidential. For purposes of this Statement we will refer to all of this information as "Client Information." We understand how sensitive this information is to you and are committed to protecting it and safeguarding your privacy.

Subject to the exceptions listed below, PrimePay will safeguard your Client Information with the same level of care and diligence with which we safeguard our own confidential information. All PrimePay employees are subject to a strict Confidentiality and Non-Disclosure Agreement and all understand that it can and will be strictly enforced. PrimePay is committed to handling your Client Information with high standards of information security and will take reasonable technical, physical and operational precautions to protect your data and other Client Information. If you would like further information concerning our technological safeguards, please contact a PrimePay representative or write to us at the following address:

• PrimePay, Inc.
• Attn: Information Security
• 1487 Dunwoody Drive
• West Chester, PA 19380

PrimePay does not sell or rent your Client Information to third parties.

Client Information - Confidentiality Conditions

PrimePay's undertaking to keep all of your Client Information confidential is subject to several standard legal and common sense exceptions. These are listed below:

• PrimePay may disclose Client Information to our own employees, affiliates, or service providers who have a need to know in order for PrimePay to provide the services you have asked us to provide. All of these parties will be subject to confidentiality restrictions comparable to those in effect with our own employees.
• PrimePay will disclose Client Information when you explicitly authorize us to do so. Example: in order to provide our tax filing and payment service, you will have to provide us with a Power of Attorney authorizing us to sign your employment tax returns and speak to the taxing authority if the need arises.
• PrimePay will disclose Client Information when your consent to disclosure is implied by the nature of your request for services from us. Example: if you ask us to get you a quote on your worker's compensation insurance, we will have to share certain Client Information with the insurance company and possibly a licensed broker.
• While not a standard business practice, PrimePay legally:
• -   may disclose any information already lawfully in its possession without any obligation of confidentiality;
• -   may disclose any information that is developed independently by PrimePay or procured from sources other
  than you without obligation of confidentiality;
• -   may disclose any information that is publicly available when received by PrimePay, or which becomes
  publicly available through no fault of PrimePay;
• -   may disclose any information that you disclose to another without obligation of confidentiality;
• PrimePay may disclose Client Information in limited circumstances when we in good faith believe that disclosure is required under the law. Example: we may be required to disclose Client Information to cooperate with regulators or law enforcement authorities, to comply with a specific legal process such as a court order, subpoena, or search warrant, or to comply with a law enforcement request.

Third Party Relationships

We have limited relationships with third parties to assist us in servicing you, for example, by making certain specialized knowledge bases available to our clients. These service providers are contractually required to maintain the confidentiality of the information we provide them.

Additionally, we have business partners that provide services, some of which are co-branded. We clearly identify partner services and sites. When you request any of these products or services, you are permitting us to provide your contact or limited Client Information necessary to the partner to fulfill your request or to verify your participation in the partner's special or other program involving PrimePay. Other than such instances in which the client has a preexisting relationship with PrimePay's business partner, PrimePay does not sell, rent, share or disclose its clients' identities to other parties for marketing or promotional purposes.

Web Technologies

We use, or may in the future use, a variety of technologies on our Web site. Hits to our primepay.com, primeperks.com portals or other PrimePay landing site are tracked on our Web server only for purposes of managing our traffic and bandwidth usage, but are not linked to any name or personally identifiable login information.

On the other hand, if you choose to submit your sensitive payroll data via our Internet PrimePay Web interface, such data is only accepted on a secure, data-encrypted Web page behind a firewall, and your identity will necessarily be established both by secure login procedures as well as through cookies which identify your computer. Cookies are pieces of information that our Web site provides to your browser. Cookies allow us to track overall site usage and determine areas users prefer. Cookies also allow us to customize your visit to our Web site by recognizing you when you return. You can choose to decline cookies while at our Web site, however, this may limit your ability to access certain areas of the Web site. Most browsers accept and maintain cookies by default. Check the "Help" menu of your browser to learn how to change your cookie preference.

When we track activity on any PrimePay Web site, we collect information such as your IP address, browser type and version, and pages you view. We may also keep track of how you get to our sites and any links you click on to leave our sites. We do not track non-PrimePay URLs that you type into your browser, we do not track you across the Internet once you leave our sites, and we do not disclose your URL to other parties - this information is used for internal purposes only. We only use your Web site activity to assist you by, aiding security, reducing the need to re-enter your data and/or to help us resolve technical support issues. We may also use this information to offer you a personalized Web experience or to tailor our offerings to you.

You control whether you receive PrimePay promotional materials and may always opt out by clicking on the icon or checkbox that indicates you do not want to receive any promotional materials.

To provide you with a seamless experience, we may occasionally use framing or provide links to non-PrimePay Web sites. Though your browser may indicate you are at a PrimePay site, you may be on a partner's site. Also, you may be on a PrimePay regional or specialized site created for certain customers or purposes. To determine which site you are on, right-click on the site and then select "properties."

When visiting a partner's Web site or any non-PrimePay linked Web site, you will be subject to the privacy policies in effect with respect to that site. PrimePay has no control over that Web site's security or privacy policies. If you have questions about a Web site's practices, please review that Web site's privacy policy.

Changes to this Policy

This privacy policy may be changed, refined or updated from time to time without prior notice, so feel free to check periodically to make sure you are aware of PrimePay's most up to date privacy policies.