The Internet is rapidly changing the way all of us communicate and interact with each other. While the Internet allows each of us access to a greater array of information and services than has ever been available, these new online activities do raise new challenges, such as the privacy issues addressed in this policy.

ICI Automotive, Inc ("ICI"), is committed to working with public policy organizations, industry groups, and government institutions to understand and address these challenges as they arise.

But most importantly, having a relationship with our customers that is founded on trust is not only good manners, it is also good business. Any feedback you'd like to provide to help us better meet your expectations in this arena is welcome.

Our Commitment To You
ICI wants to make your online experience satisfying and safe. Our data collection policies allow you to choose how much information to provide to us, and to control how we use that information. Our goal is to provide you with a robust online experience while allowing you to control your privacy.

ICI collects information online primarily to make it easier and more rewarding for you to use our services. Depending on the service you are accessing, you could be asked at various times to provide information such as your name, email address, or information about what you like and do not like. On other occasions such as when we provide items for purchase online, we may request your credit card number to conclude the transaction, or your mailing address to ensure proper delivery.

We request this information to provide our strongest value to you - a personalized online experience. Customers who personalize our service come back more often - and it's the customers that visit us often who make us successful - so we do everything we can to make ICI your service with your name on it and to give you just the content you want.

Information collected online is often defined as being either anonymous or personally identifiable:

1. Anonymous Information refers to information that cannot be tied back to a specific individual. For instance, we may know that 10,000 people visit this Privacy Policy today, but we do not necessarily know their names, where they live, or their date of birth.

What we collect from transactions such as this constitutes anonymous information, much like how your hometown's bus service knows how many people take a given route - but doesn't necessarily know who those people are.

Many of the individuals who access our services decline to use the personalization features that are available to them, and therefore those individuals are anonymous to us and the data we collect is similarly anonymous information.

2. Personally Identifiable Information refers to information that tells us specifically who you are, such as your name, phone number, or postal address. In many cases we need this information to provide the personalized or enhanced service that you have requested.

Examples of the use of such information would be our award-winning "My ICI Start Page," which uses your mailing address to customize TV schedules, weather reports, and sports scores; our commerce-enabled services, which allow our partners to ship the products you buy to your door; or our free ICI Mail email service, which uses your name as part of a security mechanism to protect your messages from being read by anyone but you.

We hope that, like many of our customers, you will find it beneficial to judiciously provide Personally Identifiable Information to ICI so that we may provide more valuable free content and products to you.

The amount of Personally Identifiable Information that you choose to disclose to ICI is completely up to you. The only way we know something about you personally is if you register for a personalized service or enter one of our ICI contests. In other words, we will know Personally Identifiable Information about you only if you choose to share this type of information with us.

Our Commitment To Your Family
Like you, we at ICI have children of our own and are concerned about their safety when they use the Internet. We want you and your family to be safe while visiting our Internet sites. That is why we have established the following guidelines for the way we interact with children when they access our services.

ICI will never knowingly request Personally Identifiable Information from anyone under the age of 13 without informing those children that parental consent is needed. Further, if a customer registers with us and their birth date indicates that they are not just under 13, but are in fact any age less than 18, we will:

1. Never knowingly send a copy of a mass emailing to them, even if they gave us permission to email them during registration.

2. Never voluntarily share their Personally Identifiable Information with any third party, even if they gave us permission to share their customer information during registration.

3. Never list them in any directory of ICI members in a manner in which their age can be easily identified.

In summary, the management and employees of ICI are very proud of our industry-leading steps to safeguard the privacy of all minors online. We're doing what we can to ensure that Personally Identifiable Information regarding registered users under the age of 18 won't leave our company for commercial use; and that someone using our site won't be able to easily look up their age.

These protections are a start, but there are some actions we cannot control, and in these areas we need help from the child's parent or guardian as well. For instance, we cannot stop a minor from giving their age in our unmoderated online chat sessions - but parents or guardians can counsel their children against taking such actions.

What can we do about Spam?
In the online world, unsolicited junk email is referred to as "Spam." Nearly all of us at one time or another will find Spam in our email inboxes. Sadly, there is no current solution to completely prevent the delivery of Spam although our ICI Mail team is constantly working on solutions that help.

Your email address can become available to "spammers" in any number of ways. You may have entered your email address at a non-ICI Web site where you signed up for a product or service. Or maybe you posted a message to a discussion board and included your email address - from which it can be automatically plucked by disreputable firms. Or, you might have done nothing at all.

Unfortunately, some spammers send massive amounts of email to various Internet domains. These individuals target large lists of probable email names (like "John") and the resultant email address (like "john@ICI.com"). While these activities are horribly inefficient, they are a common practice that allow spammers to get mail out to people who have not provided their names or addresses. Your best bet is simply to delete such email from your inbox if you find any.

Regrettably, all of us are victims of this behavior. ICI does not condone these activities and is active in pursuing solutions, including supporting the development of new laws and regulations to stem email spamming. ICI is not responsible for this unfortunate activity, and largely cannot stop it from occurring when it originates from domains off of ICI.

We can and will, however, take actions against ICI users who utilize any of our email products as the launching pad for Spam directed towards others, whether those prospective Spam recipients be ICI customers or not.

Sending Spam from any ICI domain is a serious breach of our Terms of Service that can lead to immediate closure of the sender's account.

Finally, ICI does occasionally send outbound email communications to our customers - and we hope you never think of it as Spam. To ensure that this is the case, we have strong policies in place that allow our customers to control the delivery of this content, or to prevent it altogether if that is your preference. For information about the controls that we make available to you, please see the information about unsubscribing from ICI outbound emailings shown below.

What Personal Information is Collected?
In our effort to provide personalization and opportunities for prizes and services, we may at times ask you to submit information such as your name or email address, or to share your interests and hobbies with us.

You never have to answer these questions, and you can decline this exchange of information on any site on the Internet - not just ours - at any time. However, if you should choose to withhold requested information, we may not be able to provide you with some of the services dependent upon the collection of this information, such as a personalized stock portfolio, a sweepstakes entry, or the purchase and shipment of products and prizes to people who visit our network.

When you surf the Internet, your Internet browser (such as Netscape Navigator® or Microsoft Internet Explorer) automatically transmits some information to ICI every time you access content on one of our sites, whether accessing it from direct ICI Internet access service or through another Internet Service Provider (ISP). Examples of such information include the URL of the Web page you were just on (known as the "Refer"), the IP (or Internet Protocol) address of the computer you are using, or the browser version you are using to access our site.

All of this information is collected by ICI and is used to help improve our offerings to you. For instance, from this information we determined that few of our customers use older browser versions. Because of this we recently decided to enhance the quality of content available to all of our customers by using the advanced features of HTML that cannot be accessed from those older browser versions.

All of the information that is automatically submitted to us by your browser is considered Anonymous Information. To enable many of the features available within ICI, we will assign "cookies" to your Internet browser (such as Netscape Navigator or Microsoft Internet Explorer).

A cookie is a small text file that contains a unique identification number stored on your computer. Cookies by themselves cannot be used to find out the identity of any user. This unique identification number automatically identifies your browser - but not you - to our computers whenever you interact on one of our Internet domains.

When you visit our site, a cookie in effect says to our server computers "Hello, I'm Browser #389. What do you do just for me?" Every Web page that you access that includes advertising or content served from ICI will have the contents of your cookie reported in our server logs. But only when you agree to provide Personally Identifiable Information directly to an ICI branded service, such as through registration, will we be able to know anything about you other than the random number that our server computers originally assign to your browser.

There is a lot of confusion about cookies, how they are used, and what they can do. Cookies only contain information that the server computer "knew" in the first place, and can only be read by the serving domain that placed them. For instance, Yahoo! utilizes cookies, but ICI's servers can't read their contents nor can Yahoo!'s servers read ours.

Cookies are an essential part of how the Internet works today, and allow server computers to recognize your computer's browser when you return. If you have ever gone to a Web page that automatically provides personalized content without you having to "sign in," such as your own stock portfolio, this is almost certainly being accomplished with a cookie. Since cookies are only text files, they cannot "run" on your computer and have no ability to search your computer for other information, or transmit it to anyone. Cookies are part of the technology implemented by your Web browser. But don't just take our word for it - read what the companies who wrote the browsers have to say!

For Netscape, please visit:
http://home.netscape.com/security/basics/privacy#cookies

For Microsoft, please visit:
http://www.microsoft.com/insider/internet/articles/security2.htm#cookies

Who Collects the Information? The data you provide in any Internet domain of ICI, including http://www.ICIAutomotive.com is collected by the ICI Automotive, Inc.

How Will the Information Be Used? Our services have been designed to enable ICI to provide personalized content to those customers who wish to receive it. The majority of the services that are provided for free through ICI are the result of advertising revenues.

Our ability to provide enhanced services and content to our customers is dependent on our ability to provide venues for our advertising partners that reach specific demographic segments of our customer base.

Generally, advertisers have little interest in reaching a specific customer of our services - and as a matter of policy we provide no mechanism for an advertiser to reach you or any other specific customer unless you request that contact.

Instead, our advertising partners have the need to reach customers who share common demographic characteristics such as a specific gender or age range. For instance, certain products are more often purchased by men then by women and therefore when advertising those products, in this example the advertiser would prefer to target their messages just to men.

The better job ICI does in providing a mechanism for advertisers to reach specific sub-segments of our users, the more revenue we can generate from advertising and that ultimately is what allows you the consumer to get to the wealth of free content that is available on ICI's various services.

Importantly, at no time is your Personally Identifiable Information used to determine what advertising you receive nor do we use it to determine what type of advertising any other customer of ICI will receive.

Below is a description of some of the uses of the information that we collect and how our visitors and advertisers benefit from these:

1. We provide personalized content in the form of news, advertisements and more to persons who are registered as ICI members.

2. We pay attention to what our customers do and do not use on our service and modify our content appropriately.

3. We match the patterns of usage that our consumers exhibit on any Web site where we serve advertising to create "imputed profiles" about our anonymous customers.

The creation of an imputed profile allows ICI to statistically model the demographic characteristics of an otherwise anonymous customer, without ever knowing that anonymous customer's name or any other Personally Identifiable Information about them. These imputed profiles are used to target advertising - primarily banners - to those anonymous customers, both on ICI domains and any of the other Internet domains where we serve advertising.

Through the use of imputed profiles, ICI can surface advertising to our customers that is more likely to be for products they would want, and sell that advertising in the marketplace for a higher price. This is essential to our ability to provide high quality content to our customers for free.

ICI never matches "Who you are" with "Where you've been" on the Internet because we do not use personal data characteristics such as your name, address or phone number to create these imputed profiles but rather use primary demographic characteristics such as your age or gender.

Finally, imputed profiles present no privacy risk to our customers because they are worthless to third parties; since any potential third party would be unable to read the cookies that we set on our domains, only ICI can create value from these imputed profiles.

4. We provide advertisements that support our customers' specific requests for information through keyword searches and editorial content. Do a search on "cars", for instance, and you'll usually see a banner advertisement from an automobile company.

5. We develop summary - but not individual - reports for our advertisers. An example of a summary report might be "12,000 people clicked on Advertisement 'X' today, and of those people, 35% had previously indicated they had an interest in cars."

Our advertisers, who make it possible for you to use ICI for free, need this information to determine how effective their advertising investments are. We never tell our advertisers who it was that saw or clicked on their advertisements, unless you have specifically told us it is acceptable to do so.

6. If you enter a sweepstakes or a contest, we'll use the information you supplied to contact you. We'll probably also congratulate you!

7. Finally, if we believe that ICI property or an individual's safety or security is at risk, we will disclose this information to proper court or law enforcement agencies.

Information Distribution If you are providing us Personally Identifiable Information, it will only be used within the ICI Internet domains unless you choose to allow third party data sharing (by opting in for such distribution during the registration process).

Should you choose to provide your information to third parties, ICI will share aspects of your information with our valued partners. Some of these transactions will include financial payment to ICI for the information provided but are only undertaken with companies whose privacy practices are consistent with the principles established within this policy and with whom ICI believes that a product that truly benefits our customers can be promoted.

All of our partners help contribute towards many of the free services available on ICI. Although unlikely, ICI may be required by law enforcement or judicial authorities to provide Personally Identifiable Information the appropriate governmental authorities. If requested by law enforcement or judicial authorities, we will provide this information upon receipt of the appropriate documentation.

Other companies that place advertising on our site may collect information about you when you view or click on their advertising or content through the use of cookies (using the same techniques as described above).

Due to the way the Internet technically operates, we cannot control this collection of information - but we can control which companies are allowed to place such advertising on our site.

ICI adheres to the industry standards of acceptable practice for what is known as "Third party ad serving," and as these standards evolve ICI will only accept advertising from third party firms that adhere to those rules of conduct.

In the interim, as the consumer you should contact these advertisers or content providers that place information on ICI directly if you have any questions about their use of the information they potentially collect.

It should be noted that anyone placing advertising on our Web sites can only collect Anonymous Information about you unless you actively provide Personally Identifiable Information to them.

Information that you provide while using products such as Message Boards and Chat is available for all to see. Discretion should be used in entering Personally Identifiable Information within such forums, as it may be collected by third parties, and this is, for instance, a leading source of unwanted email Spam.

ICI does not actively associate the message content entered by our customers in Mail, Message Boards, or Chat products with those customers' registration information. Our server computers will retain this information, however; and it is potentially available for distribution to third parties - most obviously law-enforcement agencies, per the terms of this section of our Privacy Policy.

We do not use this information to target any advertising to our customers, nor is it ever willingly distributed to any third party, such as an advertiser, except if subpoenaed.

And finally, ICI does not control the information collection and distribution policies on Internet domains other than those ICI Internet domains that are part of ICI itself.

Choices Available to You ICI does offer you the ability to control the email communications we make to you. It is our intention to give you as much control over our relationship as possible.

First, as mentioned earlier, the consumer always has the final word on whether ICI - or any Internet company - knows who you are. It is your choice to share Personally Identifiable Information with ICI and we encourage you to consider only sharing information with any site on the Internet if you receive true value in exchange for that information transfer and if you respect the privacy practices of the firm.

If you do choose to share Personally Identifiable Information with ICI, you can control whether we contact you or share the information with third parties, either through declarations you make at the time you share information with us, or through updates to your information.

Any time information is requested from you on an ICI Internet domain, you should see a link to our Privacy Policy and a clear indication of what your information distribution choices are.

ICI will always give you a chance to unsubscribe to any email communication from us - clear directions for doing so will appear in any email message we send to you.

At times, ICI may enter into cobranding arrangements with other companies, and if so, an opt-in question may be present for contact from these firms as well. Their opt-out features are specific to each organization, but you should never receive email from these organizations unless you have indicated that it is acceptable.

All email from ICI, or from cobrand partners who gain your permission to send you commercial email, will include an opportunity to opt out of future communications.

ICI does reserve the right to send a one-time registration confirmation email, and infrequent Service Alert messages to its customers to inform them of specific changes that may impact their ability to use a service they have previously signed up for, regardless of email contact opt-in status.

An example of a Service Alert message would be notification of the impending closing of an account that is believed to be abandoned.

And finally, we also reserve the right to contact you if compelled to do so as part of a legal proceeding or if there has been a violation of our Terms of Service.

ICI is retaining these rights because in limited cases we feel that we may need the right to contact you as a matter of law or regarding matters which will be important to you. These rights do not allow us to contact you to market a new or existing service if you have asked us not to do so, and issuance of these types of communications are rare

Security Procedures
ICI operates secure data networks protected by industry standard firewall and password protection systems. Our security and privacy policies are periodically reviewed and enhanced as necessary, and only authorized individuals have access to the information provided by our customers.

Even your registration account password is encrypted before it is sent to our computers - no one in the company could tell you what your password is even if you asked!

Any other particularly sensitive information, such as a customer's credit card number collected for a commerce transaction, is also encrypted prior to transmission.

You, the consumer, are ultimately responsible for the security of your ICI member name and password. As was stated above, we can't even use your password unless it has been encrypted first.

Please take care to store you ICI Member Name separately from your account password, or better yet, choose a password that you don't need to write down at all.

Correcting any Inaccuracies
ICI provides you with the ability to access and edit the personal information that you have provided to us. To update the information retained about you, or to deactivate your account, please visit our ICI Member Services area.