Privacy Principles

Privacy is the number one concern impacting Prime Prospects delivery of technology and information products. Our privacy principles guide the way we do business every day.

Prime Prospects respects the privacy of every individual about whom it holds information. Prime Prospects and its UK associates (employees) pledge to conduct our business according to the following principles.

Compliance - Prime Prospects is registered with the Information Commissioner and has implemented internal controls and procedures designed to ensure compliance with the Data Protection Act of 1998.

Notice, Access and Choice

Prime Prospects recognises that consumers have rights over the use and dissemination of information about themselves. Prime Prospects conforms to all legal and self-regulatory guidelines for providing a consumer notice, access and choice. To understand what information Prime Prospects holds, and how it is used and to learn how to exercise choice and access, please read the information on Notice, Access and Choice.

Ethical Relationships - Prime Prospects pledges to conduct our relationships with both clients and other data information providers in an ethical and professional manner. Prime Prospects includes in our client and supplier contracts a commitment that any data sent to us has been legally obtained and that the client's subsequent use of any data received from us will be in compliance with all data protection laws, as well as with applicable industry information practices.

Prime Prospects includes in our information provider contracts a commitment that the data we receive has been legally obtained for the uses to which it will be put. Furthermore, we agree to comply with any restrictions that these information providers place upon the data.

If Prime Prospects has reason to believe that a client or an information provider is not in compliance with these commitments, we will terminate our relationship with them.

Accuracy - Prime Prospects maintains strict quality control procedures to ensure our information is as accurate as possible. Our quality-control procedures are designed to assure that the information we compile and process is both accurate and complete. Prime Prospects responds promptly to any question about the accuracy of information from our clients and the consumer.

Security - Prime Prospects maintains strict security procedures that ensure information will not be made available to any unauthorised person or business.

Consumer Benefits - Prime Prospects offers services and information products that provide benefits to both consumers and businesses. Consumers benefit from Prime Prospects services through the realisation of the lower prices that result from our clients' more efficient marketing approach. Consumers are receiving communications more relative to their interests and needs.

Notice, Access and Choice

Prime Prospects is a reseller of a number of databases. These are some of the core databases and others are added according to a client's needs.

The Acxiom InfoBase^® Marketing Products:

Acxiom develops and maintains databases containing information on most of the households in the UK for companies to use in their marketing efforts. The databases are developed from many different sources including:

• Publicly Available Information:
  Including Electoral Roll information and Companies House information where companies are obliged to register certain details.
• Data from Other Sources:
  Including demographic information and survey information (i.e. lifestyle surveys)These databases do not include credit or medical

Privacy Practices for Information Products:

All data suppliers use the Direct Marketing Association's (DMA) Mailing Preference and Telephone Preference Services screening files in the development of these databases. These databases are provided to qualified businesses for marketing purposes only. The information can be used to enhance customer files and provide lists for prospecting purposes.

If individuals do not wish for their information to be made available to any company they have purchased from or otherwise done business with (so that that company can better understand their needs as a valued customer) Prime Prospects data suppliers will be happy to remove their names.

Likewise if individuals do not want to receive unsolicited marketing information from companies they do not currently deal with, either via mail, e-mail or telephone, Prime Prospects will ensure removal of their name from these products.

Consumers may request an Opt-Out Form by sending an e-mail to Andrew@primeprospects.co.uk alternatively, consumers can write to Andrew Webster, Prime Prospects Ltd. 47 Wetherby Mansions, Earl's Court Square. London SW5 9BH.

Prime Prospects will also be happy to provide an individual with a copy of the information that is held on the databases for a fee of £10.00. Consumers may request a supplier Consumer Information Report Request Form as above.

In addition to these rights, the Data Protection Act of 1998 gives individuals certain other rights as follows. After making a REQUEST IN WRITING and paying the fee, the individual is entitled to:

• Be informed if the list supplier or anyone on the list suppliers' behalf is processing that individual's personal data. If this is the case, the individual has the right to be given a description of the personal data and to be told of the purpose of the processing. The applicant must also be given details of the recipients or possible recipients of the data.
• Have any information that identifies them communicated in a form that is easily understood. An individual is also entitled to be told about the sources of the data and where such information is readily available.
• Request that Prime Prospects and the data supplier do not process their data for direct marketing purposes. If processing has already started, individuals can request that this is stopped within a reasonable time.
• Require Prime Prospects (or anyone acting on Prime Prospects behalf) to ensure that no significant decisions are made regarding that individual (e.g. evaluating credit worthiness or job performance) solely on the basis of automatic processing.
• Be informed of the logic used regarding data processed by automatic means for the purposes of evaluating matters of significant importance.
• Stop (or not begin) processing of personal data if that processing will cause substantial damage or distress to that individual, at the end of a reasonable time period.

Prime Prospects and the data suppliers we use, support industry self-regulation and believe such actions are the best way to protect privacy. We support all legislation and regulatory efforts to introduce fair and workable guidelines that protect the privacy of the consumer and also allow the consumer to continue receiving the benefits that sophisticated marketing techniques and services provide.