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PRIVACY POLICY

May 21, 2008

Delphi VIM, Inc. ("Delphi," "we," "us" or "our") is committed to respecting the privacy rights and concerns of all users of the Delphi website (the "Site") (we refer to the Site and the services made available through the Site, collectively, as the "Delphi Features").  As such, we have established and implemented this Privacy Policy to inform visitors to the Site and users of the Delphi Features how we use and protect the information we collect through the Site.  By visiting the Site or using any of the Delphi Features, you consent to Delphi's collection, use, storage, deletion and disclosure of information relating to you as set forth in this Privacy Policy.  This Privacy Policy is effective as of the date set forth above and is only applicable to the Site and not to any other website that you may be able to access from the Site which may have its own data collection and use practices and policies.

This policy answers the following questions:

·What information do we collect about you and how do we use it?

·Will we share your personal information with third parties?

·What choices do you have about the collection and use of your personal information?

·What security measures do we take to safeguard your personal information?

Information We Collect

Delphi does not collect personal information unless you voluntarily provide it to us.  We do, however, collect certain types of information and ask for personal information in certain circumstances, such as when you set up a user account.  The following sections describe the type of information we collect and how we collect it.

·Information You Give Us:  In order to use the Delphi Features, you may be asked for, or you may choose to provide, certain personally identifiable information ("PII") such as your name, email address, mailing address, phone number, credit or debit card and similar information. We will not collect PII from you while you use the Delphi Features unless you voluntarily provide it to us or authorize us to collect such information.  Upon activating an account, you will select a user name and a password for use in accessing and maintaining your account.

·Delphi Features: Certain Delphi Features allow you to utilize online organizational tools to create a records archive of personal financial, legal, medical and other information about you and your family.  The information you store can be entered by filling out forms provided by Delphi or by uploading documents, photos or files into specified organizational areas of the Site.  Access to information stored on the Site may require an additional level of registration and authentication, and we may verify your identity before you can store or retrieve information on the Site.

·Cookies:  Like many websites, we employ "cookies" in certain areas of the Site to allow us to provide information which is targeted to your interests and to make your online experience more convenient.  Cookies are small bits of electronic information that a website sends to a visitor's browser and are stored on the visitor's hard drive.  We do not receive or record any personal information in the cookies we use.  Although most web browsers automatically accept cookies, you may choose to change your browser to block cookies or to notify you when you are sent a cookie.  

·Log Information:  Our servers automatically record information that your browser sends whenever you visit the Site.  This information includes your Internet Protocol address, your browser type and version, which Delphi Features you use and when and how long you use them.  We use this information to monitor and analyze how users use the Delphi Features and to maintain and improve the Site.

Third Parties Who Receive Your Information

You will be informed if any other party is involved in collecting information from you through the Site.  In such situations, you can elect not to share the requested information.

This Privacy Policy does not cover the information practices of third party websites linked to the Site.  Although we encourage such third parties to adopt and follow their own privacy policies, we are not responsible for their collection and use of your personal information.  You should refer to the privacy policies and statements of other websites or contact the respective webmasters of those websites to obtain information regarding their information collection, use and disclosure policies.

Sharing of Information

We may use personal information that you provide to us to send (i) messages to you in response to your request to perform an activity in connection with your use of any of the Delphi Features or (ii) updates of the Delphi Features to you.  We may also use your personal information to contact you when necessary.    

In addition, we will share the personal information we collect from you under the following circumstances:

·Protection of rights.  We will share personal information if we have a good faith belief that (i) access, use, preservation or disclosure of such information is reasonably necessary to satisfy any applicable law, regulation, legal process, such as a court order or subpoena, or a request by law enforcement or governmental authorities, (ii) such action is appropriate to enforce the Terms of Service for the Site, including any investigation of potential violations thereof, (iii) such action is necessary to detect, prevent, or otherwise address fraud, security or technical issues associated with the Delphi Features, or (iv) such action is appropriate to protect the rights, property or safety of Delphi, its employees, users of the Delphi Features or others.

·Asset transfers.  If we become involved in a merger, acquisition or other transaction involving the sale of some or all of Delphi's assets, user information, including personal information collected from you through your use of the Delphi Features, could be included in the transferred assets.  Visitors to the Site will be notified via a prominent notice on the Site for thirty (30) days prior to a change of ownership or control of user information held by us.

·Service Providers.  We may share your personal information with service providers that we engage for the purpose of processing information on our and your behalf.  We require these entities to comply with this Privacy Policy and appropriate confidentiality and security measures.

In addition, we may share with third parties user information in the form of aggregated non-personal information.  This non-identifying information may include, for example, the patterns, trends, preferences, and other collective characteristics of our users.  Disclosure of this information serves to help us and our marketing partners evaluate and tailor our communications, advertisements, services and general business practices to the needs of users of the Delphi Features.

Control of Your Information

You may request us to correct, update or delete any of the information we have collected from you by sending an email to us at info@delphivim.com and we will attempt to fulfill your request.  We may choose not to fulfill any request that we determine is unreasonable, unduly burdensome or impractical or that constitutes a threat to the privacy or rights of others.

Security

The personal information that you provide to us is stored on servers, which are located in secured facilities with restricted access, and protected by protocols and procedures designed to ensure the security of such information.  In addition, we restrict access to personal information to Delphi employees, independent contractors and agents who need to know this information in order to develop, operate and maintain the Delphi Features.  All Delphi personnel who have access to this information are trained in the maintenance and security of such information.  However, no server, computer or communications network or system, or data transmission over the Internet can be guaranteed to be 100% secure.  As a result, while we strive to protect user information, we cannot ensure or warrant the security of any information you transmit to us or through the use of any of the Delphi Features and you acknowledge and agree that you provide such information and engage in such transmissions at your own risk.  Once we receive a transmission from you, we will endeavor to maintain its security on our systems.

Children's Privacy

The Site is a general audience website and no portion of the Site is directed to children under the age of 13.  We do not collect personal indentifying information from any person we actually know is a child under the age of 13.

Notification of Changes

This Privacy Policy may change from time to time and we will post all changes on this page.

Mediation

You also agree that, in the event any dispute or claim arises out of or relating to your use of the Site or the Delphi Features or this Privacy Policy that you and Delphi will attempt in good faith to negotiate a written resolution of the matter directly between the parties.  You agree that if the matter remains unresolved for forty-five (45) days after notification (via certified mail or personal delivery) that a dispute exists, all parties shall join in mediation services in Los Angeles, California with a mutually agreed mediator in an attempt to resolve the dispute.  Should you file any arbitration claims, or any administrative or legal actions without first having attempted to resolve the matter by mediation, then you agree that you will not be entitled to recover attorney's fees, even if you would otherwise be entitled to them.

Questions?  Contact Us

If you have any questions about our privacy practices or this Privacy Policy, please contact us by email at info@delphivim.com or you can contact us by mail at:

Customer Care - Privacy Policy Issues

Delphi VIM, Inc.

17328 Ventura Blvd, Suite 163

Encino, CA 91316

Terms of Service

Please read the Terms of Service governing the use of the Site and the Delphi Features.

Testimonials

"The Delphi Vital Information Manager (LifeCloud)) is a supremely valuable system that captures your vital information to which everyone needs immediate access. VIM is easy to use and is essential for everyone!"

-Dr. A. Afifi, Dean Emeritus
UCLA, School of Public Health

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