Privacy

3/12/02

Privacy and Confidentiality Policy ("Privacy Policy")

GSG will treat any personal information submitted on the YieldAuction web site as confidential. Except as may be required to effectuate transactions initiated through the YieldAuction web site or as may be required by law, GSG will not disclose any personal information submitted on the YieldAuction web site to any third party. As used in this Privacy Policy, the term "personal information" shall mean any information provided by an individual who uses the YieldAuction web site that consists of personal information about such individual, such as the individual’s name, place of employment, employment address and telephone number.

GSG will treat the information submitted on the YieldAuction web site during the course of transactions conducted on the web site (the "information") as confidential. Except as provided in the Guidelines displayed on the YieldAuction web site, as amended from time to time (notice of any amendments to the Guidelines that affect confidentiality issues shall be delivered to all registered users of YieldAuction and amendments shall only apply to information submitted after receipt of such notice), GSG will not disclose or otherwise make available the information in any form to any person except to (i) those employees and agents of GSG who need access to the information to facilitate the effectuation of transactions initiated through the web site; and (ii) those persons to whom disclosure may be required to effectuate transactions initiated through the web site. Nothing herein shall be construed, however, to prohibit GSG from making any disclosures required of GSG pursuant to any legal process or request from any governmental authority having jurisdiction over GSG. The restrictions set forth in this disclaimer will not apply to information that (i) becomes generally available to the public other than as a result of a disclosure by GSG by its directors, officers, employees, agents or advisors, (ii) becomes available to GSG on a non-confidential basis from a source other than the user, provided that such information is not known by GSG to be subject to another confidentiality agreement, (iii) consists of general statistics related to the volume or type of transactions, and the number of entities participating in transactions conducted on the YieldAuction web site; or (iv) consists of solicitations or bids submitted on the web site by a user of the web site so long as the identity of such user is not disclosed in relation to such bids or solicitations.

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