COMMERCIALDEALS.COM PRIVACY STATEMENT

Last Updated: September 9, 2008

LopinYukelis Corp., together with any of its subsidiaries, affiliates, successors and assigns (collectively, "we," "us," "our" or "CommercialDeals"), takes the privacy of its users seriously. We are committed to safeguarding the privacy of our users while providing a personalized and valuable service. This Privacy Policy statement explains the data processing practices of CommercialDeals and describes how CommercialDeals and its websites, including CommercialDeals.com, and the listing tools and other web products and services provided there (collectively, "CommercialDeals Web"), treat personal information that CommercialDeals Web collects and receives.  Personal information is information about you that is personally identifiable - like your name, address, email address, or phone number - and that is not otherwise publicly available (also referred to as your "Data").  References to Data also include any non-publicly available financial information provided by you through CommercialDeals Web.

This privacy policy does not apply to the practices of companies that CommercialDeals does not own or control (by way of example, external websites you may link to from or through CommercialDeals Web, such third party advertisers). While we try to link only to sites that share our high standards and respect for privacy, CommercialDeals is not responsible for the content, security or privacy practices employed by other sites. We encourage our users to read the privacy policies of all websites. This privacy policy also does not apply to people or entities that CommercialDeals does not employ or control, such as borrowers, lenders, brokers or other intermediaries that use CommercialDeals Web.  Because the lenders and intermediaries that may connect to you through CommercialDeals Web may retain or use your personal and financial Data (whether or not you qualify for or obtain a loan or other loan-related services from them), you should contact these parties directly concerning their privacy and information sharing practices. This privacy policy only applies to CommercialDeals Web.

If you have any requests concerning your personal information or any queries with regard to these practices please contact our Privacy Officer by e-mail at feedback@commercialdeals.com.

By visiting CommercialDeals WEB you are accepting the TERMS AND CONDITIONS AND CONSENTING TO THE DATA COLLECTION AND USAGE PRACTICES described in this Privacy Policy, in addition to the CoMMERCIALDEALS WEB TERMS OF USE.

Information Collected
We may collect Data from you when you register or subscribe for an account with CommercialDeals Web (a "CommercialDeals Account") or use the CommercialDeals Web software or services.  Elements of Data may include your name, email address, billing address, phone and fax number, credit card information, and various optional information (such as company name and work experience) that you may choose to provide.  In posting listings, you will also be asked to provide certain financial Data.  If you do not elect to provide all the requested Data, CommercialDeals Web may not be able to provide you will all available services, including those services requested by you. 

CommercialDeals Web may also collect information about your transactions with us and with some of our business partners. This information might include market research data, as well as information necessary to process payments due to us from you, such as your credit card number.

When you send email or other communication to CommercialDeals, including through the subscriber registration process, Contact Us and feedback sections of CommercialDeals Web, we may retain those communications in order to process your inquiries, respond to your requests and improve CommercialDeals Web.

We also collect information automatically about your visit to our sites. Please see the IP Address and Use of Cookies sections for more details.

Use and Disclosure of Personal and Financial Information

When you provide personal and financial information through or using CommercialDeals Web you are sharing your Data with CommercialDeals and its affiliated entities. The use of your Data by these organizations is subject to this policy.
We may use your Data for the following purposes:

• delivering products and services requested by you
• providing users with a personalized service
• matching prospective borrowers with potential lenders and intermediaries
• facilitating loan-related communications between users
• processing orders for subscription services
• responding to registration requests and questions
• conducting market research surveys and running competitions
• providing you with information about products and services offered by CommercialDeals
• sharing your Data with third party organizations who offer products or services which you have requested or that we feel may be of interest to you  (provided that you do not elect to opt-out of such sharing)
• managing our business
• verifying your identity
• enforcing the CommercialDeals Web Terms of Use
• other purposes we describe to you at the time your Data is collected.

CommericialDeals Web may provide your Data to lenders, brokers and other intermediaries (as CommercialDeals does not act as your lender, broker or intermediary itself).  The lenders, brokers and other intermediaries that participate in CommercialDeals Web are subject to applicable federal, state and local laws and regulations and are regulated by federal and state agencies.

In the course of operating our business it may be necessary or appropriate for us to provide access to your Data to other third parties, such as our service providers, contractors and select vendors so that we can operate and improve CommercialDeals Web and our business. Unless it is not commercially reasonable, we generally seek to obtain confidentiality agreements that are consistent with this policy or otherwise limit the use or disclosure by others of the information you have shared.

CommercialDeals Web may use or share your personal information where it is necessary to complete a transaction (such as processing credit card payments and managing billing), to operate or improve the technical functionality of CommercialDeals Web, or to do something that you have asked us to do.

CommercialDeals Web may share your personal information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Use or other applicable policies, or as otherwise required by law.
We may also disclose your information to business partners, successors to our business, or in accordance with a properly executed court order or as otherwise required to do so by law.

In addition, we may share with third parties certain pieces of aggregated, non-personal information, such as the number of users who accessed a particular area of CommercialDeals Web, for example, or how many users clicked on a particular link or used particular features. Such aggregated information will not identify you individually.  Among other things, aggregate information may be used by CommercialDeals Web to build up marketing profiles, to aid strategic development, to improve CommercialDeals Web functionality, to manage our relationship with advertisers and to audit usage of the CommercialDeals Web sites.

We usually will use the email and contact Data you provide to us only to respond to your inquiry or to process your request (such as receiving certain marketing information or ordering our products and services) or in accordance with your stated preferences.   However, we reserve the right to send you certain communications relating to CommercialDeals Web, such as service announcements and administrative messages that are related to your use of CommercialDeals Web and maintenance of your CommercialDeals Account, without offering you the opportunity to opt-out of receiving them.

Security Policy
CommercialDeals takes the privacy of its users seriously.  However, no data transmissions over the Internet can be guaranteed to be one hundred percent secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk. Once we receive your Data transmission, we make efforts to ensure security on our systems.  We use physical, electronic, and procedural safeguards and other appropriate measures to protect personal information about you and to protect your Data against unauthorized access or use, alteration, unlawful or accidental destruction and accidental loss.

If you have registered for subscriber services, your CommercialDeals Web account information will be password-protected.  It is important for you to protect against unauthorized access to your user name, password and to your computer.  Be sure to log off from CommercialDeals Web when finished using a shared computer.  Areas of CommercialDeals Web where you are requested to input personal information use industry-standard Secure Sockets Layer (SSL)-encryption to protect the data you input. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software.

If CommercialDeals learns of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using CommercialDeals Web or providing Data to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of those sites, products and services.

User Content

Although CommercialDeals reserves the right refuse to post any or all content submitted by you in our sole discretion, when you post a message or other content to or through CommercialDeals Web, including in a blog or forum, you may have the ability to include personally identifiable information about yourself.  If you choose to make your own personally identifiable information available online (through a hyperlink or otherwise) such that is accessible to the other CommercialDeals Web users, you may receive unsolicited messages from other parties in return.

Please be reminded that any content or links posted by you must comply with the CommercialDeals Web Terms of Use. Any violation by any user may result in immediate termination of such user's account and access to CommercialDeals Web, and may also subject such user to criminal penalties among other legal consequences.

Transfer of Data

The Internet is a global environment. Using the Internet to collect and process personal data necessarily involves the transmission of data on an international basis. This means that your information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. Therefore, by browsing CommercialDeals Web and communicating electronically with us you acknowledge and agree to our processing of your personal data in this way, and agree to be bound by the applicable privacy laws that CommercialDeals is governed by as well as the jurisdiction and venue provisions of the CommercialDeals Web Terms of Use.

Links to Other Sites

CommercialDeals Web contains links to other websites. If you choose to visit an advertiser by "clicking on" a banner ad or other type of advertisement, or click on another third party link, you will be directed to that third party's website. The fact that CommercialDeals Web displays a link to a third party website or presents a banner ad or other type of advertisement for goods or services of a third party is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of that third party's privacy or information security policies or practices.  CommercialDeals does not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other sites follow different rules regarding the use or disclosure of the personal information submitted to them.  We strongly encourage you to read the privacy policies or statements of the other websites you visit.

User Access and Control of Data

If you wish to amend any of the Data which we hold about you, or update your marketing preferences, please contact feedback@commercialdeals.com or visit the “My Profile” page on our website where you will be able to edit the information you have previously submitted.

You may also cancel your registration and terminate your account with CommercialDeals Web, in which case your CommercialDeals Account information will generally be deleted from CommercialDeals Web.  However, some Data, primarily your contact and billing information, may remain in our records to the extent necessary to protect our legal interests or document compliance with any applicable legal or regulatory requirements, and we may elect to retain any aggregate and non-personally identifiable information related to your CommercialDeals Account indefinitely. All Data we retain will continue to be subject to the terms of the CommercialDeals Web privacy policy that you previously agreed to when you used CommercialDeals Web."

Opting Out

CommercialDeal Web users will be given the choice to opt-out of receiving communications from us and our affiliates and marketing partners. To "opt-out" you may either use the "opt-out" or "unsubscribe" option contained within any email message delivered to you, or by emailing your opt-out request to feedback@commercialdeals.com with the word “unsubscribe” in the email subject line.  Users should allow a reasonable time (but not more than 10 days) for the opt-out request to be processed. Please be aware that your opt-out choice may mean that certain CommercialDeals Web services will no longer be available to you.

Use by Minors

Persons under age 18 are not eligible to use CommercialDeals Web.  Without limiting this restriction, in particular, we do not knowingly collect or store any information on children under 13 years of age.  We will undertake to delete any details of such users where a parent or guardian has notified us that any such details have been obtained.

Contacting CommercialDeals

If you have a privacy concern regarding CommercialDeals Web or this policy, and if you cannot satisfactorily resolve it through CommercialDeals Web, please address your concern to CommercialDeals at feedback@commercialdeals.com.
If you object to any sharing of your Data that may be permitted under this policy, you may do so by writing us at the above email. We will take reasonable steps to accommodate your requests. In some instances, honoring your requests may interfere with or preclude your ability to use the CommercialDeals Web or may require us to terminate your CommercialDeals Account and our relationship with you.

Changes to this Policy

From time to time we may make changes to this privacy policy statement to reflect any changes to our privacy practices in accordance with changes to legislation, best practice or website enhancements.
We will endeavor to notify you about any material changes in the way we treat Data by placing a notice on CommercialDeals Web, and, in some circumstances, CommercialDeals reserves the right to also send a notice of such material changes to the primary email address specified in your CommercialDeals Account.

Use of Cookies and Other Tracking Devices

We use cookies to help personalize your use of our sites.  A cookie is a small amount of data that often includes an anonymous unique identifier that is sent to your browser from a web site's computers and stored on your computer's hard drive.

This data may include information relating to your use of our sites, information about your computer such as the computer's IP address and browser type, demographic data and, if you arrived at our site via a link from third party site, the URL of the linking page. If you are a registered user or subscriber this may include your name and email address for verification purposes.
We use information from cookies for purposes which may include:

• identifying returning users, registrants and subscribers and to allow subscribers to be presented with a personalized version of the site
• enabling you to move more easily around our site
• tracking your use of our site to better develop our sites in accordance with your requirements
• building up a demographic profile

Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent.  However, some CommercialDeals Web features and services may not function properly if your cookies are disabled.  For example, if you choose to reject all cookies, you may not be able to use services or sites on CommercialDeals Web that require you to "log in," and you may not be able to take full advantage of all of the CommercialDeals Web features.
Further information on how to prevent cookies from being stored on your computer refer to the help menu within your Internet browser.

From time to time we may permit third party companies to set cookies on CommercialDeals Web sites for purposes which may include market research, serving advertisements, revenue tracking or to improve functionality of the site.
Any external websites you link to through or in connection with CommercialDeals Web use of their cookies subject to their own privacy policies, and not this policy. Advertisers or other entities do not have access to CommercialDeals Web cookies. We encourage our users to read the privacy policies of all websites. This privacy policy applies only to information collected by CommercialDeals.

IP Address

Every computer connected to the Internet is given a set of numbers that serve as that computer's Internet Protocol or "IP" address. The IP address reveals nothing personal about you other than the IP address from which you have accessed CommercialDeals Web.  CommercialDeals Web may occasionally obtain IP addresses from users depending upon how you access our web sites. When you request a page or access a search result from any page within CommercialDeals Web, our servers automatically recognize your IP address.  IP addresses, browser and session information may be used for various purposes, including to:

• Diagnose and prevent service or technology problems reported by our users or engineers that are associated with the IP addresses controlled by a specific web company or ISP.
• Estimate the total number of users visiting CommercialDeals Web from specific organizations or geographical regions
• Help determine which users have access privileges to certain content, services or resources that we offer.
• Monitor and prevent fraud and abuse.

Your IP address may also be recorded when you post content on CommercialDeals Web.