Privacy is of paramount importance to Birinyi Associates, Inc. We recognize that our clients and subscribers are especially concerned about the privacy accorded to them and to information that may be identified to them personally. As a result, we have developed this privacy policy.

The purpose of this privacy notice is to inform our clients who are subscribers to our web-based services of our policies and procedures relating to the management of the information we obtain.

Collection and Use of Customer Information. We collect only relevant information about you and our other clients that the law allows us to have in order to conduct our business and that enables us to properly service your accounts. We collect financial and other personal information about you from the following sources:

• Information you provide on applications or other forms, and through oral, written or electronic communications with us. (e.g., your name, address, telephone and fax numbers, email address, etc.).

• Information derived from your transactions with us, our affiliates or others.

No one who merely visits our website needs to supply any information, but once you provide information to us, for example so that we can provide you with information, a subscription or a particular service, we do maintain the information you give us indefinitely.

We maintain a private permanent record of all clients past and present in our database. The information we hold includes the information described below: name, address, telephone and fax numbers, email address, etc. We keep record of payment transactions, as well as the user names and passwords of those who have subscribed to our service.

Use of Personal and Financial Information by Third Parties and Us. We do not disclose any nonpublic personal information about our customers or former customers to anyone, except as permitted by law. As permitted by law, we may share nonpublic personal information about you with our affiliates and with other third parties who provide services for your accounts. The information we share may include but is not limited to:

• Information you provide on applications or other forms, and through oral, written or electronic communications.
• Information derived from your transactions with us such as, but not limited to: method and amount of payment, account balance, and user name and password.

In particular, we do not share our mailing lists with any third parties, except to the extent described above in connection with the provisions of services. We do not share information about individual subscribers or clients with any third party unless we have the subscriber’s or client’s consent. In addition, we only divulge information as necessary to comply with state and federal laws and regulations.

From time to time a subscriber or client may wish to opt out of certain services or benefits, or may wish to opt out of providing certain types of information. Subject to the terms of agreement with us, we will give this option whenever possible.

Limiting Employee Access to Information. We limit access to nonpublic personal information about you to only those employees with a business reason to know that information. We train our employees to respect customer privacy and to recognize the importance of confidentiality. Those who violate our privacy policy are subject to disciplinary action.

Keeping Information Secure. We maintain physical, electronic and procedural safeguards to protect your financial and other nonpublic personal information. We regularly assess new technology with the aim of adding additional safeguards to those we have in place, or in upgrading existing safeguards and procedures, as appropriate.

However, while our site is encrypted to protect your privacy (as with, for example payments online), we urge you to remember that typical email is often not secure. Therefore, sending by email any credit card information or other information that is nonpublic would not be secure. You are urged to make payments, address adjustments, etc. by logging into the website, or by telephone, fax, or mail to us directly.

Maintaining Customer Privacy in Business Relationships. We do not share nonpublic personal information about you with anyone who does not agree to keep your information confidential. If you believe we have shared your information inappropriately, please contact us.

How Gathered Information can be Corrected, Changed or Canceled. Information may be corrected or changed at any time and as often as necessary by contacting us by mail or by telephone. A subscription may be cancelled in the same way. Contracts for service may be cancelled in accordance with the terms of the contract.

Again, we do strive to maintain the utmost privacy for all our clients and continually research methods on how to upgrade the existing safeguards. This is our privacy policy as of July 1, 2001. It supersedes all other policies and we reserve the right to change any or all of the principles, along with related provisions at any time.