This document sets out the OPTIO Online Privacy Policy (the "Privacy Policy") for this Web site, www.optio.co.uk (the "Site") and the OPTIO Interactive Financial Planner. If you have objections to the Privacy Policy, you should not access, use, or send personal information to this Site or the IFP. This Privacy Policy does not govern privacy practices associated with other activities or OPTIO web sites.

What data do we hold about you?

We need to collect and use two types of information about you in order to operate.

The first type of information is the personal data provided by you during the voluntary registration process ("registration data"). We hold this data in order to be able to identify you as a user and, if necessary, contact you. We may also hold additional personal data provided by you in relation to certain services on the Site, so that you do not need to re-enter this data when you next require the service. Clearly, the more complete and accurate the personal data we hold about you, the better our service will be. Your email address and password are unique to you as a registered user. You should take great care of them and keep them safe at all times.

The second type of information is the data about your personal finances which is recorded in your OPTIO personal file as you use the Interactive Financial Planner. This file is held on your local PC and is not copied to or held on our web site unless you choose to send it to a financial adviser. When you do this the file is encrypted, using strong 128-bit encryption and then sent to our web site. We then send it on, still in its encrypted form, to your chosen adviser. The file can only be decrypted and opened if you give a password to your adviser, authorising him to open the file. None of the personal financial data in your file is held in unencrypted form on our website at any stage.

Where is your data stored?

Optio Development Ltd. is the registered data controller of your personal data for the purposes of the Data Protection Act 1998. All registration and personal data provided by you is held securely and in confidence by us in our computerised records. You have a right to inspect the data we hold about you at any time. If you wish to do so, you should write to our data protection compliance officer whose details are set out below. If anything in the data is inaccurate or out-of-date, let us know and either we will amend our records or you can do it yourself on-line.

The Site contains links to other sites at which personal information is collected. In such instances, unless expressly provided to the contrary, the collection and use of your personal information will be governed by the privacy policy applicable to that site. That privacy policy should identify the entity that is collecting your personal information.

How do we use your data?

The nature of our service means that from time to time we may to share your registration data with our business partners who provide the products and services that you request. For instance, if you want to apply for a particular financial product after using a comparison service or simply require more information about it, we may pass your relevant registration data to the product provider in order to fulfill your request. When you use the Site, OPTIO or third parties authorised by OPTIO may also collect certain technical and routing information about your computer to facilitate your use of the Site and its services. For example, we may log environmental variables, such as browser type, operating system, CPU speed, and the Internet Protocol ("IP") address of your computer. We use these environmental variables to facilitate and track your use of the Site and its services and to help us support you if a technical issue shoud occur.

Most browsers are initially set to accept cookies. You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether to accept it. (For some Web pages that require an authorisation, cookies are not optional. Users choosing not to accept cookies will probably not be able to access those pages.)

While OPTIO uses cookies to track your visit to our website, and our Web servers automatically log the IP/lnternet address of your computer, OPTIO does not generally use this information to identify you personally. However, if you expressly provide consent for OPTIO to "remember" the unique identifier that you select when you register for various activities on the site, that unique identifier will be stored in a cookie on your computer, linked to your registration data, and your navigation path around the site will be tracked. We associate this data to understand how our site and services are being used so we can understand our customers and offer appropriate products and services.

We also extract certain information from your registration data for the purpose of generating statistics for our own internal purposes but it is not possible to identify you from these statistics.

How do we keep your data secure and confidential?

We use encryption and authentication procedures to protect any sensitive data we hold about you. In addition, all our staff have a responsibility for maintaining user confidentiality. We provide training and education to all our staff to remind them of their obligations, which are fully supported by our internal policies and procedures. We only pass your personal data to third parties where security and confidentiality is assured.

E-mail

E-mail addresses are required in order to register for some features on the Site. Occasionally, we will send you special e-mail newsletters that may contain the latest financial information or keep you up-to-date with developments on the Site or the services we offer.

In any e-mail we send, there are instructions that allow you to "unsubscribe" to this service should you not wish to receive e-mails in the future.

Telephone Calls

If you call our Contact Centre, calls may be recorded or monitored for training purposes.

Transfer of the Site

Notwithstanding anything else that has been agreed or represented (in this Privacy Policy, in the Terms of Use or otherwise) if the Site is transferred to another provider, we may transfer your personal data to the new provider provided the new provider undertakes (in terms which are enforceable by you) to hold it in accordance with the Privacy Policy.

Contact details

Our Data Protection compliance officer is James Cotton and he can be contacted by writing to Optio Development Ltd., 72, New Bond Street, London W1S lRR.