PLEASE READ THIS PRIVACY POLICY CAREFULLY.

By accessing or otherwise using this sortuv.com site, you agree to be bound contractually by this Privacy Policy.

SORTUVA PRIVACY POLICY
Effective Date: November 11th, 2008

Click here for a listing of material modifications to this Privacy Policy and their effective dates.

1. Privacy Statement; Collection of Personally Identifiable Information ("personal information").

1.1 Sortuva Company ("Sortuva") operates this website. All references to "we", "us", this "website" or this "site" shall be construed to mean Sortuva.

1.2 We understand that visitors to this website are concerned about the privacy of information. The following describes our privacy policy regarding information that we collect through this website, including OUR COLLECTION, USE, TRANSFER, AND SHARING OF PERSONAL INFORMATION THAT MAY IDENTIFY YOU.

2. Modification of Privacy Policy.

2.1 We reserve the right to modify this Privacy Policy at any time, and without prior notice, by posting an amended Privacy Policy that is always accessible by clicking on the "Privacy Policy" link on this site's home page. Your continued use of this site indicates your acceptance of the amended Privacy Policy. You should check the Privacy Policy through this link periodically for modifications by clicking on the link provided near the top of the Privacy Policy for a listing of material modifications and their effective dates.

2.2 Regarding personal information, if any modifications are materially less restrictive on our use, transfer, or sharing of the personal information previously disclosed by you, we will obtain your consent before implementing such revisions regarding your information.

3. Collection of Anonymous, Passive Information. We reserve the right to monitor your use of this site. As you navigate through this site, certain anonymous information may be passively collected (that is, gathered without your actively providing the information) using various technologies. Click here a listing and a brief explanation of passive information collection methods which we may use from time to time to better understand how this site is being used.

4. Use and Sharing of Anonymous, Passive Information. This site may make full use of passively collected anonymous information through the collection methods linked above for our own internal operational purposes, including without limitation the right to use such information to provide better service to site visitors, customize the site based on your preferences, compile and analyze statistics and trends, and otherwise administer and improve this site for your use. We reserve the right to transfer and share this information in the same manner as provided below for personal information.

5. Use of 3rd Party Cookies. This site reserves the right to use web analytics services provided by third parties. These services use cookies (sometimes referred to as 3rd party cookies) which are text files placed on your computer, to help us analyze how users use this site. The information generated by the cookie about your use of this site (including your IP address) will be transmitted to and stored by the service provider. The will use this information for the purpose of evaluating your use of this site, compiling reports on website activity for website operators, and providing other services relating to website activity and internet usage. These services may also transfer this information to third parties where required to do so by law, or where such third parties process the information on the service's behalf. These services will not associate your IP address with any other data. You may refuse the use of cookies by selecting the appropriate settings on your browser; however, please note that if you do this you may not be able to use the full functionality of this site. By using this site, you consent to the processing of data about you by third party analytics services in the manner and for the purposes set out above.

6.1 We will ask you when we need to collect personal information that could identify you. Personal information which we collect may vary depending on the benefits and/or services you select, and may include one or more of the following categories of information: name, physical address, an email address, phone number, and credit card information including credit card number, expiration date, and billing address.

6.2 Where we collect personal information from an identifiable person, we will inform the person of the category of information collected, the purposes for collection and use, the types of non-agent third parties to which we may disclose the personal information, and the choices and means, if any, we may offer the individual person for limiting the use and disclosure of their personal information.

6.3 We will provide notice in clear and conspicuous language when identifiable persons are first asked to provide their personal information, or as soon as practicable thereafter, but in no event before we use their personal information for a purpose other than which it was originally collected.

7. Use, Transfer, and Sharing of Personal Information.

7.1 Permitted Transferees; General Policy. Except for the permitted transferees listed here, the policies described below apply to our use, transfer, and sharing of personal information that may identify you. WE WILL NEVER UNDER ANY CIRCUMSTANCES (i) TRANSFER OR SHARE PERSONAL INFORMATION WITH THIRD PARTIES FOR PURPOSES OF DIRECT MARKETING, OR (II) COMBINE PASSIVELY COLLECTED INFORMATION WITH YOUR PERSONAL INFORMATION.

7.2 Your California Privacy Rights. California Civil Code Section 1798.83 permits our registrants who are California residents to request certain information regarding our disclosure of your personal information to third parties for their direct marketing use. As stated above, we do not share personal information with third parties for their direct marketing purposes. You may request further information about our compliance with California Civil Code Section 1798.83 at the following email address: compliance.officer@sortuva.com. Please note that we are only required to respond to one request per registrant each year, and we are not required to respond to requests made by means other than through this the address provided above.

7.3 Choice.

7.3.1 We will not process personal information collected by us from an identifiable person for purposes other than those for which the information was originally collected or subsequently authorized by that person, unless the person affirmatively and explicitly consents (“opt-in”) to the processing, or unless an exception applies.

7.3.2 We also provide identifiable persons with the opportunity to withdraw consent at any time (“opt-out”) from the processing for which their information was collected by us, in which case their personal information will not be further processed.

7.4 Data Integrity.

7.4.1 We undertake reasonable measures to ensure that information collected by us from an identifiable person is kept accurate, complete, current, and otherwise reliable in relation to the purposes for which the information was collected. The personal information we collect from identifiable persons is accurate, relevant, and not excessive for the purposes for which it is to be processed.

7.4.2 Identifiable persons whose personal information we collect have the responsibility to assist us with maintaining accurate, complete, and current information about them.

7.5 Access; Making Changes To personal information. Registered users may make changes to their personal information. [---Click here---] for instructions regarding how to make these changes.

7.6 Security.

7.6.1 We have adopted a security policy to protect personal information from loss, misuse, unauthorized access, disclosure, alteration and destruction. This policy includes technical and organizational security measures, including without limitation, password protections for online information systems, restricted access to personal information, and industry standard technical security measures. Our Security Officer is responsible for conducting investigations into any alleged computer or network breaches, incidents or problems, and promptly instituting any required remediation.

7.6.2 Our employees are notified periodically of their responsibilities in connection the security policy. Our Security Officer is responsible and ensuring that appropriate disciplinary action is taken against those who violate our security policy.

7.7 Onward Transfer of personal information Outside Your Country of Residence. Any personal information which we may collect on this site will be stored and processed in our servers located only in the United States. By using this site, if you reside outside the United States, you consent to the transfer of personal information outside your country of residence to the United States.

8. European Union Privacy Laws; Safe Harbor.

8.1 The European Union ("EU") maintains strict privacy laws. These rules differ significantly from United States laws. To reconcile these differences, the US and the EU have created a Safe Harbor that defines mutually acceptable privacy operations. We are in the process of completing our certification for adherence to the Safe Harbor principals. For more information see www.export.gov/safeharbor.

8.2 Transfer of Personal Information to Permitted Transferees. If and when we transfer personal information to permitted transferees, we require these permitted transferees either: (i) to subscribe to the EU Safe Harbor Principles, the EU Data Protection Directive, or another adequacy finding; or (ii) to enter into a written agreement with us requiring them to provide the same level of protection that we provide.

8.3 Audit, Enforcement, And Dispute Resolution.

8.3.1 We will conduct compliance audits of our security policy to verify compliance with this EU Safe harbor Policy and the US Department of Commerce Safe Harbor Principles.

8.3.2 If you have any questions regarding this EU Privacy Policy or your dealings with this website, please contact us at:

Sortuva Company
Attn: Privacy Policy Officer
2505 3rd Avenue, Suite 324N
Seattle, WA, 98121
Email: compliance.officer@sortuva.com
Telephone: 206.905.4749
Facsimile: 206.299.9666

8.3.3 Individuals who wish to file a complaint regarding this EU Safe Harbor Privacy Policy should contact our Compliance Officer at the above address. Our Compliance Officer will explain the process to be followed when filing a complaint, and will investigate and attempt to resolve complaints in accordance with the principles contained in this EU Safe Harbor Privacy Policy.

8.3.4 Any other controversy or claim arising out of or relating to this Policy, or the breach thereof, shall be settled by arbitration administered by the American Arbitration Association ("AAA") in accordance with its applicable commercial rules as well as the Safe Harbor Enforcement Principle; provided, further, that any arbitrator shall be either an attorney or retired judge having significant and recognized experience with and knowledge of privacy issues and information technology. In addition, the exclusive location for such arbitration shall be Seattle, Washington. All decisions of the arbitration panel shall be final and binding on the parties, which waive any right to further appeal the arbitration award, to the extent an appeal may be lawfully waived.

8.3.5 We are also subject to the jurisdiction of the U.S. Federal Trade Commission. The Federal Trade Commission may be contacted as the following address:

Federal Trade Commission
Attn: Consumer Response Center
600 Pennsylvania Avenue NW
Washington, DC 20580
www.ftc.gov

9. Email From This Site; Opt-Out Rights. If you supply us with your e-mail address you may receive periodic messages from us with information specific to the site and required for the normal functioning of the site as well as for new products or services or upcoming events. If you prefer not to receive periodic email messages, you may opt-out by following the instructions on the email.

10. Links To Other Sites Including Online Ads. This website may contain links to other websites with whom we have a business relationship. These links may include online advertisements that we deem to be appropriate. The privacy practices of these websites are not covered by our privacy policy, and we are not responsible for the privacy practices or the content of these sites. Additionally, if you register with any of these sites for any purpose or purchase from any of these sites, any information that you provide in the process of registration or purchase, such as your credit card number and other personal information, will be transferred to these sites. These sites have separate data collection, data privacy, and data security policies and practices, and we have no responsibility or liability for these independent policies and practices; however, we have entered into agreements with these websites which provide that UNLESS YOU SPECIFICALLY AGREE OTHERWISE (ii) they will use your personal information only for the purpose of providing the products or services that you may request, and (ii) they will share your personal information only as required to fulfill your request for products or services. You should be careful to review any privacy policies posted on any of these sites before providing information to them.

11. Children’s Online Policy. We are committed to preserving online privacy for all of its website visitors, including children. This site is a general audience site. Consistent with the Children's Online Privacy Protection Act (COPPA), we will not knowingly collect any information from, or sell to, children under the age of 13. If you are a parent or guardian who has discovered that your child under the age of 13 has submitted his or her personally identifiable information without your permission or consent, we will remove the information from our active list, at your request. To request the removal of your child's information, please send contact our site as provided below under “Contact Us”, and be sure to include in your message the same login information that your child submitted.

12. Email And Other Messages Through This Site; ECPA Notice. This site treats email messages and other electronic messages that are sent through this site and not viewable by others as confidential and private, except as required by law, including without limitation, the Electronic Communications Privacy Act of 1986, 18 U.S.C. Sections 2701-2711 (the "ECPA"). The ECPA permits this site's limited ability to intercept and/or disclose electronic messages, for example (i) as necessary to operate our system or to protect our rights or property, (ii) upon legal demand (court orders, warrants, subpoenas), or (iii) where we receive information inadvertently which appears to pertain to the commission of a crime. This site is not considered a "secure communications medium" under the ECPA.

13. USA Patriot Act Notice. The federal USA Patriot Act ("USA Patriot Act") provides generally for the operator of a communication host and law enforcement to be able to monitor any content, upon request of the operator. We anticipate fully complying with all our obligations, and availing ourselves of all our rights, under the USA Patriot Act.