All of your information is protected by industry-standard security technology. OTC Digest™ is owned and operated by Equity Media, Inc. (EMI) a California corporation, and as such we respect your privacy. This statement of our Privacy Policy explains what information we gather from you and how we use that information. We consider the information you have shared with us strictly confidential and will use that information only as specified in this Privacy Policy or to the extent necessary to comply with applicable law.

Information We Gather and How We Use It

We collect certain information from you in order to provide you with the most interesting and useful Web site possible. We use your IP address to identify you, and other log file data to gather demographic information that helps us understand how you and our other subscribers use our Web site, and to administer our Web site. These log files are not tied to any personal information.

Our Complimentary Newsletter and Weekly Commentary registration form requires you to give us a name, username and password, and your email. Premium service forms may ask for additional contact information (like your name, phone number, and mailing address), demographic information (like your age, occupation and income level) and profile information (like your investment experience) purely at the subscriber's option. We use your contact information to contact you about our Web site and provide you with information and promotional material from our advertisers. We use various other portions of your information to target advertising, and to personalize our Web site by showing you content that we think you might be interested in and displaying the content according to your preferences.

We may conduct or sponsor surveys and contests on our Web site. If you elect to participate, we may ask you for contact, demographic and other information as part of these offerings, purely at the subscriber's option. We would use this information to analyze and report on the results of surveys, to provide you with the results of the surveys and contests, and to send you information about our company and promotional material from our partners and advertisers. Participation in surveys and contests is completely voluntary.

Agents

We use third party service providers to provide all of our credit card processing on our site to bill you for our Premium Focus List services only. This company does not retain your personally identifiable information for any other purpose.

Information We May Disclose

We share demographic, profile and other general information about you and our other subscribers with our advertisers on an aggregate basis. This means that we tell our advertisers general information about the characteristics of our subscriber base such as how many female visitors and registered users we have within a certain postal code, but we do not specifically identify a particular female visitor or provide her contact information to our advertisers.

Our advertisers or clients may ask us to e-mail you updates or promotional information tailored to specific interests that you selected. We will only send you information from advertisers where you either requested specific information from that specific advertiser, or you signed into one of our clients "Corporate Guestbook's" and requested general updates and additional information or materials on that specific company.

We may disclose your contact information or other specific information about you to third parties 'ONLY' in conjunction with advertising, contests or new service offerings 'THAT YOU ELECT TO PARTICIPATE IN'.

Under all other circumstances we do not share your contact information with strategic partners, affiliates of the Company, or any other companies.

Since the OTC Digest™ has both the Premium Focus List database, and the Complimentary Newsletter database and, in most cases, separate client databases as a result of requests for more information from our members, we want to make it understood that under no circumstances do we ever co-mingle any of these databases.

As we continually look for ways to improve our business, we may buy, sell or merge with a company. If we buy or sell a business, the personally identifiable information collected will likely be transferred as a part of the sale. However, if we buy or merge with a business, we will honor all current requests that subscribers have made regarding e-mail communications. In the event that we sell the business, we will guarantee that the e-mail communications requests you have made of us are honored. For more information see the "Additional Information" section below.

We reserve the right to disclose your personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served on our Web site.

We may release your contact and other information to third parties when we believe that such release is reasonably necessary to (i) comply with state and or federal law, (ii) cooperate with state and federal regulatory agency investigations, (iii) comply with the terms of the Subscriber Agreements with NASDAQ and the New York Stock Exchange, (iv) enforce the terms of our User Agreement or License Agreement, or (v) protect the rights of the OTC Digest™, it's owner and operator Equity Media, Inc., or others.

Cookies

Our Web site uses both session ID and persistent "cookies" which deposit certain record keeping information in your hard drive. For members only, identifiable information is tied to the cookie so that we can save your username only and you don't have to re-enter it each time you visit our site. The cookie also keeps track of your preferences, your portfolio if you choose to create one, and keeps track of your order status for the purpose of automatic re-billing, as described in the Premium Focus List "terms of Use".

For complimentary users we only keep track of your movements on the OTC Digest™ and log information such as the type of web browser you use and your IP address so that we can constantly improve our web site to suite the majority of users. The cookies for Complimentary users cannot read data from your hard drive or read cookie files created by other sites or applications, and do not record or store any personally identifiable information.

In some cases our Web site may display ads sold by us or by outside advertising agencies. These ads may contain cookies, which will be deposited in your hard drive if you click on the ads. Information generated from cookies deposited on your hard drive by our advertisers is collected by our advertisers and we do not have access to this information.

Most browsers are set to accept cookies unless you reconfigure your browser to refuse them or to notify you when you have received one. If you do not accept cookies, you will not be able to use certain features of our site.

Subscriptions and Purchases

You may subscribe for a fee to certain services through our Web site or purchase publications and merchandise through advertisers links. If you subscribe for services, which require payment of a fee or place an order with us through an order form, we will need your contact information and certain financial information such as your credit card number. Any financial information we collect will be used solely to bill you for the services and items you have purchased and to fullfil your purchase by sending you email alerts in the case of the Premium Focus List. Currently the OTC Digest does not offer any retail items that would be shipped.

Public Forums

Chat rooms, Blogs, forums, message boards, and/or news groups may be made available to you in the future through our Web site. Please remember that any information disclosed in any chat room, regardless of the web site, becomes public information. If you post personal information online that is accessible to the public, you may receive unsolicited responses. You should exercise caution when deciding to disclose any of your personal information in a public forum.

Security

The security of your personal information is important to us. When you enter sensitive information (such as credit card number) for premium services, we encrypt that information using secure socket layer technology (SSL) provided by Network Solutions. To view the SSL certificate information click on the SiteSafe™ icon on the left side nav bar of all pages.

We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use the highest commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

If you have any questions about security on our Web site, call us at 1-877-OTC-DIGEST inside the US. You may also contact us by sending an email to us using the contact us form located on otcdigest.com. It is best to call if you would like an immediate response.

Links to Other Web Sites

Our Web site contains links to other sites. OTC Digest™ is not responsible for the privacy practices or the content of such sites. You may wish to review the privacy policies of these sites.

Your Options

You may opt-out of receiving all communications from us and/or our partners. This includes:

Opting to not receive promotional materials from our advertisers and, any newsletters, notices about new services or any other content from OTC Digest™.

You may opt-out at any time from our Free Complimentary newsletter after registering by visiting http://www.otcdigest.com/unsubscribe.html or contact us using the contact us form located on otcdigest.com. The unsubscribe funtion is in real-time however, if you unsubscribe within 20 minutes of one of our mailings it is possible you may receive one final email. After that, you will no longer receive any emails. Further, when unsubscribing an email verification is sent to you for your records. The free complimentary newsletter and Market Commentary are in no way to be confused with the Independent Premium Premium Focus List.

Every e-mail we send to you will provide you with the email you used to join and a link to unsubscribe with real-time instant verification so that you can be sure you will not receive any future emails. This information is found at the bottom of all our emails.

Independent Premium Premium Focus List Members who wish to stop their membership, change or correct information, must call our offices during normal business hours - Pacific Standard Time. Focus List members are required to physically click a box(s) agreeeing to this terms of use and as a requirement to even access the Focus List subscription page and then to enter your payment information prior to becoming a member. We make it abundantly clear there is a strict no refund policy prior to accessing the secure payment form page. If you are unsure or have questions prior to making the transaction call us first at 1-877-OTC-Digest.

Correct or Update Your Information

You may change or update your email address by simply unsubscribing your current email address at: http://www.otcdigest.com/unsubscribe.html and then subscribing your new email  using the Subscription Form link located at: http://www.otcdigest.com/Create-an-Account.html

To insure delivery of our verification email add the email address bb@ otcdigest.com to your email safe list prior to subscribing so you can activate your subscription. This is to protect your privacy further. If you do not receive the verification email within a few minutes please call us or use our contact us form. Once you receive the verification email you must follow the instructions to activate your account otherwise your email will be purged within two weeks if you do not verify. You will receive one reminder email only.

For Premium Focus List Members who wish to change or update information, you must call our offices during normal business hours - Pacific Standard Time. You may leave a message with your phone number and name and we will return your call.

You CANNOT unsubscribe from the Independent Focus List through our online unsubscribe feature. This feature is only for Complimentary Newsletter subscribers. You are encouraged to be a member of both services but, the 'Premium Independent Focus List' is never to be confused with the 'Free Complimentary OTC Digest™ Newsletter'. Both have their own very detailed disclaimers at the bottom of all pages located at http://www.otcdigest.com/Focus_List_Terms.html and http://www.otcdigest.com/disclaimer.html

If you have any questions about the Independent Focus List prior to signing up please call us anytime or use our contact form. If our phones lines are busy and you reach voice mail, please leave your name, a phone number and the reason for your call and your call will be returned promptly.

Contacting Us

If you have any questions about this privacy statement, the practices of this site, or your dealings with this Web site, you can contact the Web Site Administrator at:

Equity Media, Inc.
6994 El Camino Real
Suite 205-D
Carlsbad, CA 92009
877-OTC-Digest (877-682-3443) or email support[at]otcdigest.com

Additional Information

Please also refer to the OTC Digest™ ''Disclaimer'' located at: http://www.otcdigest.com/disclaimer.html for additional user/subscriber related information. For general information about Internet privacy issues, you may wish to visit the Web site hosted by the Federal Trade Commission at www.ftc.gov/privacy.

If we decide to change our privacy policy, we will post those changes to this privacy statement, the homepage, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by email, or by means of a notice on our home page.

This statement of our Privacy Policy was last revised on Jan 2008. The only changes made were to clarify the option to cancel your Focus List membership by telephone only due to emails unreliable nature and the addition of a new toll free phone number, addition of a text version of our unsubscribe hyperlink, and additional language reflecting our new return email path to be used for your email safe list or address book to ensure delivery of all our emails.

All data and information is provided through OTC Digest™ for your enjoyment and for informational purposes only, and is not intended for the purpose of trading securities. Neither the OTC Digest™ nor any of its data or content providers shall be liable for any errors or delays in the content, or for any actions taken in reliance thereon. By accessing the OTC Digest™ site, you have agreed to all the terms and conditions of the OTC Digest™ as stated in the "Privacy Policy" and Main Disclaimer which is easily located at the bottom of all pages and can be found at the following link: http://www.otcdigest.com/disclaimer.html