The Red Flag Group - Solutions: SME

Privacy Statement Effective as of July 1, 2009

The Red Flag Group Limited ("RFG" or the "Company") is committed to protecting the privacy of your information. This Privacy Statement describes RFG’s information practices.

1. Web Sites Covered

This Privacy Statement covers the information practices of Web sites that link to this Privacy Statement: http://www.redflaggroup.com; http://www.integrityportal.com; http://www.compliancedesktop.com; and (collectively referred to as "RFG’s Web sites" or "the Company's Web sites").

RFG’s Web sites may contain links to other Web sites. RFG is not responsible for the information practices or the content of such other Web sites. The Company encourages you to review the privacy statements of other Web sites to understand their information practices.

2. Personal Information Collected

RFG offers a variety of services that are collectively referred to as the "Service". RFG collects information from individuals who visit the Company’s Web sites ("Visitors") and individuals who register to use the Service ("Customers").

When expressing an interest in obtaining additional information about the Service or registering to use the Service, RFG requires you to provide the Company with contact information, such as name, company name, address, phone number, and email address ("Required Contact Information"). When purchasing the Service, RFG requires you to provide the Company with financial qualification and billing information, such as billing name and address, and the number of employees within the organization that will be using the Service ("Billing Information"). RFG may also ask you to provide additional information, such as company annual revenues, number of employees, or industry ("Optional Information"). Required Contact Information, Billing Information, and Optional Information are referred to collectively as "Data About RFG Customers".

As you navigate the Company’s Web sites, RFG may also collect information through the use of commonly-used information-gathering tools, such as cookies and Web beacons ("Web Site Navigational Information"). Web Site Navigational Information includes standard information from your Web browser (such as browser type and browser language), your Internet Protocol ("IP") address, and the actions you take on the Company’s Web sites (such as the Web pages viewed and the links clicked).

3. Use of Information Collected

The Company uses Data About RFG Customers to perform the services requested. For example, if you fill out a “Contact US” Web form, the Company will use the information provided to contact you about your interest in the Service.

The Company may also use Data About RFG Customers for marketing purposes. For example, the Company may use information you provide to contact you to further discuss your interest in RFG, the Service, and to send you information regarding the Company and its partners, such as information about promotions or events.

RFG uses Web Site Navigational Information to operate and improve the Company’s Web sites. The Company may also use Web Site Navigational Information in combination with Data About RFG Customers to provide personalized information about the Company.

4. Web Site Navigational Information

RFG uses commonly-used information-gathering tools, such as cookies and Web beacons, to collect information as you navigate the Company’s Web sites (“Web Site Navigational Information”). This section describes the types of Web Site Navigational Information the Company may collect and how the Company may use this information.

RFG uses cookies to make interactions with the Company’s Web sites easy and meaningful. When you visit one of the Company’s Web sites, RFG’s servers send a cookie to your computer. Standing alone, cookies do not personally identify you. They merely recognize your Web browser. Unless you choose to identify yourself to RFG, either by responding to a promotional offer, opening an account, or filling out a Web form (such as a "Contact Us"), you remain anonymous to the Company.

There are two types of cookies: session-based and persistent-based. Session cookies exist only during one session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you close your browser or turn off your computer.

If you have chosen to identify yourself to RFG, the Company uses session cookies containing encrypted information to allow the Company to uniquely identify you. Each time you log into the Service, a session cookie containing an encrypted, unique identifier that is tied to your account is placed your browser. These session cookies allow the Company to uniquely identify you when you are logged into the Service and to process your online transactions and requests. Session cookies are required to use the Service.

RFG may use information from session and persistent cookies in combination with Data About RFG Customers to provide you with information about the Company and the Service.

IP Addresses

When you visit RFG’s Web sites, the Company collects your Internet Protocol (“IP”) addresses to track and aggregate non-personally identifiable information. For example, RFG uses IP addresses to monitor the regions from which Customers and Visitors navigate the Company’s Web sites.

RFG also collects IP addresses from Customers whey they log into the Service as part of the Company’s "Identity Confirmation” and "IP Range Restrictions” security features.

5. Sharing of Information Collected

RFG may share Data About RFG Customers with the Company’s agents so that these agents can contact Customers and Visitors who have provided contact information on our behalf. RFG may also share Data About RFG Customers with the Company’s agents to ensure the quality of information provided. RFG does not share, sell, rent, or trade personally identifiable information with third parties for their promotional purposes.

RFG reserves the right to disclose personally identifiable information of the Company’s Customers or Visitors if required by law or if the Company reasonably believes that disclosure is necessary to protect the Company’s rights and/or to comply with a judicial proceeding, court order, or legal process.

6. Communications Preferences

RFG offers Customers and Visitors who provide contact information a means to choose how the Company uses the information provided. You may manage your receipt of marketing and non-transactional communications by clicking here or by clicking on the "unsubscribe" link located on the bottom of the Company’s marketing emails. Additionally, you may send a request specifying your communications preferences to support@redflaggroup.com. Customers cannot opt out of receiving transactional emails related to their account with RFG or the Service.

7. Correcting and Updating Your Information

Customers may update or change their registration information by editing their user or organization record. To update a user profile in the ComplianceDesktop application, please login to http://www.complianceDesktop.com with your username and password and click "Setup".

8. Customer Data

RFG Customers use the Service to host data and information ("Customer Data"). RFG will not review, share, distribute, or reference any such Customer Data except as provided in the RFG Master Subscription Agreement, or as may be required by law. Individual records of Customer Data may be viewed or accessed only for the purpose of resolving a problem, support issues, or suspected violation of the RFG Master Subscription Agreement, or as may be required by law. Customers are responsible for maintaining the security and confidentiality of their RFG usernames and passwords.

9. Security

RFG uses robust security measures to protect Customer Data from unauthorized access, maintain data accuracy, and help ensure the appropriate use of Customer Data. When the Service is accessed using Internet Explorer version 6.0 or later, Firefox version 2.0 or later, or Safari version 3.0 or later, Secure Socket Layer ("SSL") technology protects Customer Data using both server authentication and data encryption. These technologies help ensure that Customer Data is safe, secure, and only available to the Customer to whom the information belongs and those to whom the Customer has granted access. RFG also implements an advanced security method based on dynamic data and encoded session identifications, and the Company hosts its Web sites in a secure server environment that uses firewalls and other advanced technology to prevent interference or access from outside intruders.

Because the Company uses the Service to maintain Data About RFG Customers, this information is secured in the same manner as described above for Customer Data.

10. Changes to this Privacy Statement

RFG reserves the right to change this Privacy Statement. RFG will provide notification of the material changes to this Privacy Statement through the Company’s Web sites at least thirty (30) business days prior to the change taking effect.

11. Contacting Us

Questions regarding this Privacy Statement or the information practices of the Company’s Web sites should be directed to RFG Privacy by e-mailing lane@redflaggroup.com.

Corporate Fraud Investigation and Prevention 2010

16-18 March 2010, Singapore
3rd Anti-Corruption China

27-29 April 2010, Hong Kong

The Red Flag Group is a Governance, Risk & Compliance advisory & technology firm, and not a law firm nor CPA firm. We do not provide legal advice nor provide attest services, audits, or other engagements in accordance with the AICPA's Statements on Auditing Standards.