1 WE RESPECT YOUR PRIVACY!

We respect your privacy. Your privacy is very important to us and you can be assured that our privacy practices are held to high standards. Triple Deal's Mission Statement is to provide the Internet Community with reliable, convenient and affordable systems for safe trading and secure paying. Trust is one of the cornerstones of this Privacy Policy and our products and services. We feel that it is important to trust the parties and the transaction system when doing business on the internet. And therefore we value a high degree of privacy in our operations.

As part of the normal operation of our services we collect some information about you. This Privacy Policy describes the information we collect about you and what may happen to that information. We comply to simple and effective rules of thumb that protect your privacy:

• Any and all information collected at our site will be kept strictly confidential and will not be sold, reused, rented, loaned, or otherwise disclosed.
• Any information you give to Triple Deal will be held with the utmost care, and will not be used in ways that you have not consented to.
• We strive to improve our privacy policy continuously, according to our customers' requirements, legal obligations, and recommendations by leading institutions and our own organization philosophy.

To underline our efforts to make our services safe, we are a member of The Safe Internet Foundation (www.sif.nl). In our Privacy Policy, we will follow the guidelines from the Online Privacy Alliance (www.privacyalliance.org). A more detailed explanation about how we safeguard your personal information is described below.

1.1 A NOTE ON PRIVACY AND INFORMATION SECURITY

We also like to point out that to all information, information systems and data communication facilities the Triple Deal security policy applies. In short, we take every state-of-the-art precaution to protect our users' information. When the wizards on our site asks users to enter sensitive information (such as your credit card number), that information is encrypted and is protected with SSL (Secure Socket Layer) or SET (Secure Encrypted Transaction). While on a secure page, such as all Triple Deal Payment Services pages, the lock icon on the bottom of Web browsers such as Netscape Navigator and Microsoft Internet Explorer becomes locked, as opposed to un-locked, or open, when you are just surfing. We use security technology to prevent our computers from being accessed by unauthorized persons.

We train all of our employees about the importance of privacy, giving them access to information about customers and Merchants only to those who require it to perform their jobs. If you have any questions about the security of the Triple Deal Payment Service, you can send an email to [email protected]. We will not reveal our technical details, but we will be able to elaborate about our norms and controls. Although our Security Policy does not specifically address your privacy issues, we use it as our Guidelines for insuring the important information security issues. That way we strive to guarantee:

• The confidentiality of our information processing, meaning that no other person than the one(s) authorised have access to certain information.
• The integrity of our information processing, meaning that the validity of information is ensured and that data pass through our systems and organization unmodified.
• The availability of our information processing, meaning that information is available to (only) the right user at the right time.

Combining our commitment to privacy protection with 'the CIA of information security' (i.e. confidentiality, integrity and availability), we feel that we can provide a solid basis for safe trading and secure payments.

2 DEFINITIONS

In this Privacy Policy Document, we use the following terms:

3 NOTICE AND DISCLOSURE

In this chapter we describe what kind of information we collect from customer's of the Triple Deal Payment Services in order to handle payment transactions and the disclosure of that information. In the course of processing a payment transaction, we usually receive from the Merchant or a financial institution information related to the transaction. This normally includes information about the payment that the consumer has furnished the Merchant or financial institution in placing the order. In short:

• We only collect data necessary for executing payment transactions. We do not collect any other information. Triple Deal is the sole owner of the information collected through its system.
• We use your data only for payment transactions purposes. We will not sell, share, or rent this information to others in ways different from what is disclosed in this statement.
• An exception is made for legal purposes: when we learn of or suspect any illegal transaction we will inform the legal authorities and give them full access to personal details of all persons involved in the supposedly illegal transaction and full access to the transaction details of that transaction. We will do so after notifying all parties involved by e-mail, using the e-mail address used in our registration.

The privacy practices of this Privacy Policy apply to the www.tripledeal.com domain. Generally all of our business partners (such as www.interpay.nl, www.visacards.nl, www.mailstreet.nl, www.abnamro.com) and investors (www.docdatapayments.com, www.conclusion.nl) operate under similar privacy practices as described in this Privacy Policy. We recommend that you review their privacy policies if you have any questions or suggestions regarding your privacy.

3.1 INFORMATION WE COLLECT

Our primary goal in collecting personal information from you is to provide you with a smooth, efficient, and customized transaction process. The personally-identifiable information we acquire in processing payment transactions varies according to the nature of the transaction and the way in which Merchants, some Triple Deal business partners or financial institutions are using our payment services. It may include the amount of the transaction, the customer's name, bank account number or billing address. Triple Deal nor the Merchant will store your credit card details, while you will communicate these directly to the Credit Card Clearing company.

Triple Deal collects four types of information:

1. Personal information, such as name, address, country and e-mail address; Your personal information is stored on the secure Triple Deal servers for the purpose of processing payment transactions.
2. Bank details, such as bank account and name of user; Your bank details are stored on the secure Triple Deal servers for the purpose of processing payment transactions.
3. Transaction details, such as Transaction ID and Payment ID; Your transaction details are stored on the secure Triple Deal servers for the purpose of processing payment transactions and providing our Merchants with a complete administration.
4. Payment details, such as the amount of the transaction and the Payment Method; Your transaction details are stored on the secure Triple Deal servers for the purpose of processing payment transactions and providing our Merchants with a complete administration. Details such as credit card numbers and its expiry dates are never stored by Triple Deal.

Most of these information items are mandatory to fill in, because the payment process needs this information, both for the Merchant and for the Triple Deal Payment Services.

Below you find some more details about the information items we collect. If you want to know of any specific type of information you think we might collect, and you can not find it in the table below, please do not hesitate to contact us. A member of our helpdesk will help you with your questions.

3.2 OUR USE AND DISCLOSURE OF INFORMATION

We will use the information we collect for the purpose of processing your payment transactions and the administration necessary. When you subscribe to our newsletter, we will use your information to send you the letter. That means:

1. Personal information, such as name, address, country, e-mail address; Your personal information is shown on the site when necessary for the completion or for the payment transaction and sometimes used by business partners of Triple Deal for processing the payments. An example is our business partner Mailstreet.
2. Bank details, such as bank account and name of user; Your financial details are used only by our financial staff and partner financial institutions in order to process your payment. Examples are banks and our business partner Mailstreet.
3. Transaction details, such as Transaction ID and Payment ID; These details are generated by the Merchant together and by Triple Deal. They will be shown for your information and to keep track of your payment transaction in the administration of the Merchant. Also some of our business partners may need these details for the payment process.
4. Payment details, such as the amount of the transaction and the Payment Method; These details are generated by the Merchant together and by Triple Deal. They will be shown for your information and to keep track of your payment transaction in the administration of the Merchant. Also some of our business partners may need these details for the payment process.

Moreover, all disclosure of information is bound to the conditions of our General Conditions.

A more detailed overview of information disclosure is shown in the table below.

We use your email address in order to inform you about payment facilities Triple Deal occasionally handles for Merchants. We also offer a Newsletter for which you can subscribe on the Triple Deal website. If you do no longer wish to receive these communications, you always have the ability to opt out.

We can disclose any information about you to law enforcement or other government officials as we, in our sole discretion, believe necessary or appropriate, in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose us to legal liability.

4 CONTACT US

If you have any questions, or if you feel that we are not specifically clear about certain privacy issues, or if you think that we do not comply to our own policy, please do not hesitate to let us know. We will respond to your mail as soon as possible and let you know when we fix a possible problem.