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Moody's Economy.com Privacy Policy

Effective: April 10, 2008

This privacy policy and the Terms of Service govern your use of the Economy.com web site and the other web sites that form part of the Moody's Economy.com network of web sites, as listed in the Terms of Service (each a "Web site" and together the "Web sites"). You must read and accept the terms of the Terms of Service and this privacy policy before you will be allowed to register as a user of the Web sites. If you do not register as a user, you will not be able to visit all sections or use all features of the Web sites.

TRUSTe Statement

Moody's Economy.com is a licensee of the TRUSTe Privacy Program. TRUSTe is an independent, non-profit organization whose mission is to enable individuals and organizations to establish trusting relationships based on respect for personal identity and information by promoting the use of fair information practices. Because Moody's Economy.com wants to demonstrate its commitment to its users' privacy, it has agreed to disclose (in relation to the www.economy.com site only) its information practices and have its privacy practices reviewed for compliance by TRUSTe. The www.economy.com web site complies with the EU Safe Harbor framework as set forth by the Department of Commerce regarding the collection, use and retention of data from the European Union.

By displaying the TRUSTe trustmark, this web site has agreed to notify you of:

What personally identifiable information Moody's Economy.com collects.
What personally identifiable information third parties collect through the web site.
The organization collecting the information.
How Moody's Economy.com uses the information.
With whom Moody's Economy.com may share information.
What choices are available to you regarding collection, use and distribution of the information.
What types of security procedures are in place to protect the loss, misuse or alteration of information under the control of Moody's Economy.com
How users can correct any inaccuracies in the information.

Personally identifiable information, or personal data as it is sometimes known, is information relating to you which can be used to identify you or contact you. If you have questions or concerns regarding this privacy policy, you should first contact the Privacy Coordinator at:

Privacy Coordinator
Moody's Economy.com
121 North Walnut Street, Suite 500
West Chester, PA 19380-3166
(610) 235-5000
privacy@economy.com

If you do not receive acknowledgment of your inquiry or your inquiry has not been satisfactorily addressed, you should then contact TRUSTe through the TRUSTe Watchdog Dispute Resolution Process:

http://www.truste.org/consumers/watchdog_complaint.php

TRUSTe will then serve as a liaison with Moody's Economy.com to resolve user concerns.

The TRUSTe program covers only information that is collected through www.economy.com (rather than any of the other Web sites), and does not cover information that may be collected through software downloaded from the site. By displaying the TRUSTe trustmark, Moody's Economy.com has agreed to notify users of:

Information Collection

We at Moody's Economy.com recognize the importance of protecting your personal and financial information. We respect your privacy and your concerns about how the information you provide might be used. Moody's Economy.com is the controller of the information collected on the Web sites. (Users accessing Freelunch.com, Nofreelunch.com and the Dismal Scientist are actually redirected to www.economy.com subsections (www.economy.com/freelunch or, in the case of the Dismal Scientist, the www.economy.com homepage). Information collection practices for the Web sites are identical. Moody's Economy.com collects information from our users at several different points on the Web sites:

Registration

In order to use the Web sites, a user must first complete the registration form. During registration a user is required to give contact information (name, organization, email address, postal code, position title, country, postal code, and age). We also may ask for organization address, organization phone number, type of organization, size of organization (sales and number of employees), gender, marital status, income, presence of children, home address, and home phone number (although the user is not required to give any of this information). We use this information to tailor any contact we make with the user about services on the Web sites for which he/she has expressed interest.

Orders/subscriptions

For some products and services we may also ask for your credit card information and billing address. This information is used to process and fulfill product orders and/or subscriptions and to provide support. If we have trouble processing an order, the information is used to contact the user.

Email a Colleague Feature

If you use the Email a Colleague feature, we will ask for a name and email address for the purpose of sending an email message on your behalf. We ask for this information for the sole purpose of sending this one-time email message and tracking the success of this feature.

Information Use

Profile

We store the information that we collect through cookies, log files, clear gifs, and/or third parties to create a profile of our users. A profile is sorted information that we keep on individual users that details their viewing preferences and habits. Consequently, collected information is related to the user's personal identifiable information to provide offers and improve the content of the site for the user. This profile is used to customize and personalize a user's experience to our web site, and to direct pertinent marketing promotions to them. We will share your profile with pre-screened third parties ONLY if you request to receive offers of interest from these organizations when you register as a new user. Please be aware that your profile and your personally identifiable information may be shared if you request to receive these offers of interest.

Other Moody's Economy.com organizations

For the purposes of providing services under the Websites, Moody�s Economy.com may from time to time pass along personally identifiable information to its parent organization, Moody�s Analytics, Inc. and its affiliates. This information is used for the support of Moody�s Economy.com products only; it will not be used for promotional purposes. All use by these organizations will be in accordance with the terms set out in this privacy policy.

Purchases

When users purchase products from any of Moody's Economy.com's content partners (a current list of which may be found at http://www.economy.com/store/provider.asp), we may share names and other contact information with that partner for support and administrative purposes on behalf of Moody's Economy.com. The content partners are not allowed to use personal data except for the purpose of providing these services.

Cookies

A cookie is a piece of data stored on the user's computer which identifies that computer during current and subsequent visits to a web site. We use both session ID cookies and persistent cookies. For the session ID cookie, once users close the browser, the cookie simply terminates. A persistent cookie is a small text file stored on the user's computer for an extended period of time. Persistent cookies can be removed by following your Internet browser's help file directions. Internet Explorer users can use the following link for additional information on managing cookies:

http://www.microsoft.com/windows/ie/using/howto/privacy/config.asp

Cookies are used to automate the login process and store user site preferences. If a user rejects certain cookies, their ability to use the Web sites will be significantly degraded and the Web sites may not function at all. Persistent cookies enable us to track and target the interests of our users to enhance their experience of our site. Personally identifiable information is stored and encrypted within either session or persistent cookies. We do link the information we store in cookies to personally identifiable information you submit while using our site.

Log Files

Like most users of standard web site servers we use log files. This includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks to analyze trends, administer the site, track users' movement in the aggregate, and gather broad demographic information for aggregate use. IP addresses, etc. are linked to personally identifiable information. We use Google Analytics and AWStats, software packages that use log files to analyze user activity.

Clear Gifs (Web Beacons/Web Bugs)

We employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that helps us better manage content on our Web sites by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. The main difference between the two is that clear gifs are invisible on the page and are much smaller, about the size of the period (full stop) at the end of this sentence. Clear gifs are not tied to users' personally identifiable information.

Clear Gifs can "work with" existing cookies on a computer if they are both from the same web site or advertising company. That means, for example, that if a person visited "www.companyX.com", which uses an advertising company's clear gif, the web site or advertising company would match the clear gif's identifier and the advertising company's cookie ID number, to show the past online behavior for that computer. This collected information would then be given to the advertising company or web site.

In addition, we use clear gifs in our HTML-based emails to let us know which emails have been opened by the recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. If users would like to opt-out of these emails, please see the Opt-out section.

Communications from the Site

Special Offers and Updates

We send all new members a welcoming email to verify password and username. While agreeing to the Terms and Services of the site, users may �opt-out� of receiving information on products, services, special deals, and a newsletter. If the user does not choose to �opt-out� at this time, they can �opt-out� later by logging into the site and choosing Alerts/Newsletters. Out of respect for the privacy of our users, we leave it to users to decide whether to 'opt-out' of receiving these types of communications. Please see the Choice and Opt-out sections.

Newsletters

If a user wishes to subscribe to any of our newsletters, we ask for contact information such as name and email address. Out of respect for the privacy of our users, we leave it to users to decide whether to 'opt-out' of receiving these communications. Please see the Choice and Opt-out sections.

Service Announcements

On rare occasions it is necessary to send out a service-related announcement. For instance, if our service is temporarily suspended for maintenance we might send users an email. Generally, users may not opt-out of these communications, although they can deactivate their account. However, these communications are not promotional in nature. To deactivate their account, the user should contact Client Services at help@economy.com, or contacting us by telephone or postal mail at the contact information listed below.

Customer Service

We communicate with users on a regular basis to provide requested services and in regards to issues relating to their account we reply via email or phone, in accordance with the user's wishes.

Sharing

Legal Disclaimer

Although we make every effort to preserve user privacy, we may need to disclose personal information when required by law, such as where we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process served on our Web sites.

Aggregate Information (non-personally identifiable)

We share aggregated demographic information with our partners and advertisers. This is not linked to any personally identifiable information.

These are the instances in which we will share users' personal information with third parties:

Third Party Partners

We use third parties for the specific services below. These third parties are prohibited from using your personally identifiable information for any other purpose other than what is specified below.

SalesForce.com

Moody's Economy.com partners with SalesForce.com to organize requests for Sales contacts. If you request that a member of our Sales team contact you, we send your contact and other information to our account at SalesForce.com. SalesForce.com is an application service provider that many companies use to organize call-back requests, etc. They are prohibited from using your personally identifiable information for any other purpose. SalesForce.com participates in the TrustE Privacy Seal program. To learn more about SalesForce.com's privacy policies:

SalesForce.com Frequently Asked Questions:
http://www.salesforce.com/products/faq.jsp

SalesForce.com Privacy Policy:
http://www.salesforce.com/statements.jsp?file=privacy&src=web

Third Party Intermediaries

We use an outside credit card processing company to bill users for goods and services. This company does not retain, share, store or use personally identifiable information for any secondary purposes.

Third Party Content Providers

We partner with other third party content providers to offer specific products and services. When the user signs up for these particular products or services, we share names, or other contact information (address, phone number, email address) that is necessary for the third party to provide support for these products and services. These third parties are not allowed to use personally identifiable information except for the purpose of providing support.

Organizational Subscribers

Where an organization subscribes to our products, we share aggregated and detailed account usage information for that organization's named user accounts with the main customer contact for that organization. This information aids the subscribing organization in determining the appropriate number of user accounts, allocations of products, and overall utility of those products.

Choice/Opt-out

Our users are given the opportunity to 'opt-out' of having their information used for purposes not directly related to our site at the point where we ask for information. For example, our registration form has an 'opt-out' mechanism so users who register with us, but do not want any marketing material, can keep their email address off of our lists.

Users who no longer wish to receive our newsletter and promotional communications may opt-out of receiving these communications by visiting the My Account section of our web site or may email optout@economy.com with their preferences.

Users of our site are always notified when their information is being collected by any outside parties. We do this so our users can make an informed choice as to whether or not they should proceed with services that require an outside party.

Links

The Web sites contain links to other sites. Please be aware that we, Moody's Economy.com, are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of each and every web site that collects personally identifiable information. This privacy statement applies solely to information collected by the Web sites.

Surveys

Our site requests information from users via surveys. Participation in these surveys is completely voluntary, and the user therefore has a choice whether or not to disclose this information. The requested information typically includes contact information (such as name and shipping address), and demographic information (such as zip code). Survey information will be used for purposes of monitoring or improving the use and satisfaction of this site. Users' personally identifiable information is not shared with third parties unless we give prior notice and choice. Although we may use an intermediary to conduct these surveys, they may not use users' personally identifiable information for any secondary purposes.

Email a Colleague

If a user elects to use our referral service for informing a colleague or other business associate about our site, we ask them for that person's name and email address. Moody's Economy.com will automatically send the person a one-time email inviting them to visit the site . Moody's Economy.com stores this information for the sole purpose of sending this one-time email and tracking the success of our referral program. The person may contact Moody's Economy.com at optout@economy.com to request the removal of this information from our database. Please note that this referral service should only be used in respect of employees in their business or professional capacities - it should not be used in respect of individuals. Before you pass onto us the e-mail address of any third party, you should be satisfied that the third party consents to being contacted in this way.

Chat Rooms, Message Boards, and Public Forums

Please keep in mind that whenever you voluntarily disclose personal information online - for example on message boards, through e-mail, or in chat areas - that information can be collected and used by others. In short, by posting personal information online that is publicly accessible, you may receive unsolicited messages from other parties in return.

VeriSign Secure Site

This confirms that Moody's Economy.com is a VeriSign secure site. VeriSign's Seal was voted the #1 Sign of trust on the Internet.

Security

This web site takes every precaution to protect our users' personally identifiable information. When users submit financial information (such as a credit card number) via the web site, their information is protected both online and off-line.

When our registration/order form asks users to enter financial information (such as a credit card number), that information is encrypted and is protected with industry leading encryption software - SSL. While on a secure page, such as our order form, the lock icon on the bottom of web browsers such as Mozilla Firefox and Microsoft Internet Explorer becomes locked, as opposed to unlocked, or open, when users are just 'surfing'.

While we use SSL encryption to protect financial information online, we also do everything in our power to protect users' information off-line. All of our users' personally identifiable information, not just the financial information mentioned above, is restricted in our offices. Only employees who need the information to perform a specific job (for example, our billing clerk or a customer service representative) are granted access to personally identifiable information. Our employees must use password-protected screen-savers when they leave their desk. When they return, they must re-enter their password to re-gain access to user information. Furthermore, ALL employees are kept up-to-date on our security and privacy practices. Every year, as well as any time new policies are added, our employees are notified and/or reminded about the importance we place on privacy, and what they can do to ensure our users' personally identifiable information is protected. Finally, the servers that store personally identifiable information are in a secure environment.

If users have any questions about the security at our web site, users can send an email to privacy@economy.com.

Correcting/Updating/Deleting/Deactivating Personal Information

If a user's personally identifiable information changes (such as zip code, phone, email or postal address), or if a user no longer desires our service, we provide a way to correct, update or delete/deactivate users' personally identifiable information. Updating or correcting information can usually be done by logging onto http://www.economy.com, clicking on My Economy and then going to the "Edit Profile" link; by contacting Client Services at help@economy.com, or contacting us by telephone or postal mail at the contact information listed below. Deleting or deactivating an account can only be handled by contacting Client Services at help@economy.com, or contacting us by telephone or postal mail at the contact information listed below. All requests will be handled with 30 days of reception.

Notification of Changes

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 our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

If, however, we are going to use users' personally identifiable information in a manner different from that stated at the time of collection, we will notify users via email and by posting a notice on our web site for 30 days.

Children's Online Privacy Protection

The safety of children is important to us. Moody's Economy.com's web sites are general audience sites and are not directed to children under the age of 13. Similarly, Moody's Economy.com services are not directed to nor intended for anyone under the age of 13. Moody's Economy.com will not knowingly accept, collect or maintain personally identifiable information from or about anyone under the age of 13 years. Moody's Economy.com relies on the truthfulness of individual registrant certifications when accepting this information. In the event that Moody's Economy.com receives information that establishes that a registrant is under the age of 13 years, Moody's Economy.com reserves the right to eliminate that person's information from its database. If you believe Moody's Economy.com has any information from or about anyone under age 13, please contact us at privacy@economy.com.

Contact Information

If users have any questions or suggestions regarding our privacy policy, please contact us at:

Privacy Coordinator
Moody's Economy.com
121 North Walnut Street, Suite 500
West Chester, PA 19380-3166
610.235.5000
privacy@economy.com