Your Privacy Rights

This privacy policy (“Privacy Policy”) applies to information collected on the Ports America website located at http://portsamerica.com (the “Website”) as well as other websites maintained by Ports America through the “Client Access” drop down list on the Website and other links on the Website (“Client Access Websites”). This policy does not apply to information we may collect in other forums, including through emails or offline. In the event of a conflict between the privacy policy of a Client Access Website and this Privacy Policy, the privacy policy of the Client Access Website will prevail. As used herein, the terms “you”, “your” and “yours” refer to the user or registered user using this Website. The terms “Ports America”, “we”, “us” and “our” refer to Ports America, Inc. and its related or affiliated companies.

The Information We Collect and How it is Used

Certain features on the Website or Client Access Websites may request personally identifiable data from you ( “Personal Information”), which may include your name, e-mail address, company name, or other personal information such as your address, fax or telephone number. In addition, our web server automatically stores your IP address and your domain (where possible) when you log onto the Website or Client Access Websites, the e-mail addresses of those who communicate with us via e-mail, and your navigation through the Website or Client Access Websites; and aggregate information about what pages on our site you visit or access.

We use the information you submit to respond to your request, or to otherwise help us in processing your request. We also use the information you submit for other business purposes, including, from time to time, using your email address to send you information about developments or events in which we believe you may be interested, or to let you know when new information in your interest area(s) has been posted to the Website or Client Access Websites. Personal Information is used by Ports America to assist in serving you more effectively and to improve the content of the Website or Client Access Websites.

While we are not in the business of selling personally identifiable information, we may share information you provide with our affiliates. We will also share information: (a) with vendors providing services on our behalf; (b) with third parties with whom we partner to offer you products and services; (c) to protect the security of the Website and Client Access Websites and our rights under our Terms and Conditions of Use; (d) to protect ourselves against liability; (e) in response to legal process, subpoena, or law enforcement agency or official’s request; (f) if we believe in good faith that the law requires it; or (g) in connection with a sale of our business or company.

Security

Ports America uses standard security measures to protect information submitted on this site. We cannot guarantee, however, that our standard measures will not prevent a third party from circumventing our security measures and unlawfully intercept or access transmissions or private communications, or where an error may occur in the administration of the Website or Client Access Websites.

Your Choices

At any time you may request to correct your Personal Information or request that Ports America delete your Personal Information and no longer contact you either by e-mail, telephone, regular mail, or by any other means. To make any request described above, contact us through the “Contact Us” link at the bottom of every page of the Website or Client Access Websites. When contacting us, please be sure to provide us with your exact e-mail address, name, address and/or telephone number(s) in order to be sure we handle your request correctly.

If you have an established business relationship with us, and are a resident of California, you have the right to request from us a list of the categories of personal information we have disclosed to third parties, for those third parties’ marketing purposes, and a list of all third parties to whom we have shared that information. We will include in that list the information required by California law, namely the names and addresses of the third parties who received the information and used it (or whom we believe may have used it) for their own marketing purposes. To exercise your rights, you may make one request each year by contacting us through the “Contact Us” link at the bottom of every page of the Website or Client Access Websites. Indicate that you are making a “California Shine the Light” inquiry. Responses to requests will be provided within 30 days.

Third Party Sites and Sponsors

While the Ports America site occasionally will provide a hyperlink to a third party’s site, Ports America is not responsible for the privacy practices of these sites, and encourages you to read the site’s privacy policy before submitting any personally identifiable information.

International Visitors

Privacy laws differ across the globe. If it is necessary for the purposes for which you have shared personal information with us for us to share your information within our global operations, we will do so consistent with this Policy.

This site is hosted in the United States and is intended only for United States visitors. If you are visiting from the European Union or other regions with laws governing data collection and use that may differ from United States law, please note that you are transferring your personal data to the United States and by providing your personal data you consent to that transfer. When you provide personal data to us or our service providers or vendors, you consent to the processing of your data in the United States as the site is operated in the United States.

Changes to the Privacy Policy

By using the Website or Client Access Websites, you are agreeing to the terms set forth in the Privacy Policy. Ports America reserves the right, at its discretion, to change, modify, add, or remove portions of the Privacy Policy at any time. If Ports America changes the Privacy Policy it will post the updated version here and may post it on some or all of the Client Access Websites as well. Please check this page periodically for changes. Your continued use of the Website or Client Access Websites following the posting of changes to this policy will mean that you accept those changes. Such changes will not apply to you retroactively. In the event that any provision or portion of this Privacy Policy shall be deemed to be unenforceable or invalid for any reason, in whole or in part, the remaining provisions of this Privacy Policy shall be unaffected thereby and shall remain in full force and effect.

Effective Date

This policy is effective as of July 2, 2009.