April 2, 2007

At BixBot - a division of Modus Novus - we recognize that privacy is important. This Policy applies to all of the products, services and websites offered by BixBot, Modus Novus. or its subsidiaries or affiliated companies (collectively, Modus Novus "services").

Modus Novus adheres to the US safe harbor privacy principles of Notice, Choice, Onward Transfer, Security, Data Integrity, Access and Enforcement.

Information we collect and how we use it:

We offer a number of services that do not require you to register for an account or provide any personal information to us, such as the BixBot store search. In order to provide our full range of services, we may collect the following types of information:

• Information you provide - When you sign up for a BixBot Account or other Modus Novus service or promotion that requires registration, we ask you for personal information (such as your name, email address and an account password). For certain services, such purchasing products in our store, we also request credit card or other payment account information which we maintain in encrypted form on secure servers. We may combine the information you submit under your account with information from other Modus Novus services or third parties in order to provide you with a better experience and to improve the quality of our services. For certain services, we may give you the opportunity to opt out of combining such information.
  
  
• Modus Novus cookies - When you visit Modus Novus, we send one or more cookies - a small file containing a string of characters - to your computer that uniquely identifies your browser. We use cookies to improve the quality of our service by storing user preferences. Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some Modus Novus features and services may not function properly if your cookies are disabled.
  
  
• Log information - When you use Modus Novus services, our servers automatically record information that your browser sends whenever you visit a website. These server logsmay include information such as your web request, Internet Protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser.
  
  
• User communications - When you send email or other communication to Modus Novus, we may retain those communications in order to process your inquiries, respond to your requests and improve our services.
  
  
• Affiliated sites - We do not share your information with any other sites with which we may be affiliated.
  
  
• Links - Modus Novus may present links in a format that enables us to keep track of whether these links have been followed. We use this information to improve the quality of our product offerings, customized content and advertising.
  
  
• Other sites - This Privacy Policy applies to web sites and services that are owned and operated by Modus Novus. We are not affiliated with other sites that may link to us, and we do not share our information with those sites.

Modus Novus only processes personal information for the purposes described in the applicable Privacy Policy and/or privacy notice for specific services. In addition to the above, such purposes include:

• Providing our products and services to users, including the display of customized content and advertising;
• Auditing, research and analysis in order to maintain, protect and improve our services;
• Ensuring the technical functioning of our network; and
• Developing new services.

Modus Novus processes personal information on our servers in the United States of America. We do not process personal information on any servers outside your own country. We may process personal information to provide our own services. We do not process personal information on behalf of or under the instructions of third parties.

Choices for personal information

When you sign up for a particular service that requires registration, we ask you to provide personal information. If we use this information in a manner different than the purpose for which it was collected, then we will ask for your consent prior to such use.

If we propose to use personal information for any purposes other than those described in this Policy and/or in the specific service notices, we will offer you an effective way to opt out of the use of personal information for those other purposes. We will not collect or use sensitive information for purposes other than those described in this Policy, unless we have obtained your prior consent.

You can decline to submit personal information to any of our services, in which case Modus Novus may not be able to provide those services to you.

Information sharing

Modus Novus only shares personal information with other companies or individuals outside of Modus Novus in the following limited circumstances:

• We provide such information to our subsidiaries, affiliated companies or other trusted businesses or persons for the purpose of processing personal information on our behalf. We require that these parties agree to process such information based on our instructions and in compliance with this Policy and any other appropriate confidentiality and security measures.
• We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable Terms of Service, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against imminent harm to the rights, property or safety of Modus Novus, its users or the public as required or permitted by law.

If Modus Novus becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, we will provide notice before personal information is transferred and becomes subject to a different privacy policy.

We may share with third parties certain pieces of aggregated, non-personal, such as the number of users who searched for a particular item, for example, or how many users clicked on a particular product. Such information does not identify you individually.

Please contact us at the address below for any additional questions about the management or use of personal data.

Information security

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store personal data.

We restrict access to personal information to Modus Novus employees, contractors and agents who need to know that information in order to operate, develop or improve our services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

Data integrity

Modus Novus processes personal information only for the purposes for which it was collected and in accordance with this Policy or any applicable service-specific privacy notice. We review our data collection, storage and processing practices to ensure that we only collect, store and process the personal information needed to provide or improve our services. We take reasonable steps to ensure that the personal information we process is accurate, complete, and current, but we depend on our users to update or correct their personal information whenever necessary.

Accessing and updating personal information

When you use Modus Novus services, we make good faith efforts to provide you with access to your personal information and either to correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. Some of our services may have different procedures to access, correct or delete users' personal information. We will provide the details for these procedures in the specific privacy notices or FAQs for these services when it deviates from the procedures listed here.

Enforcement

Modus Novus regularly reviews its compliance with this Policy. Please feel free to direct any questions or concerns regarding this Policy or Modus Novus's treatment of personal information by contacting us through this web site or by writing to us at Privacy Matters, c/o Modus Novus Inc., PO Box 70, Westminster, MD 21158, USA. When we receive formal written complaints at this address, it is Modus Novus's policy to contact the complaining user regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between Modus Novus and an individual.

Our Commitment To Children's Privacy

Protecting the privacy of the very young is especially important. For that reason, we never collect or maintain information at our website from those we actually know are under 13, and no part of our website is structured to attract anyone under 13.

BBB OnLine Privacy Program

Modus Novus participates in the Council of Better Business Bureau’s BBBOnLine Privacy Program and we have made a commitment to meet the program’s strict requirements regarding how we treat your information and have it verified by BBBOnLine. Further information about this program is available at www.bbbonline.org.

All BBBOnLine Privacy Program participants are required to work with the program's dispute resolution process. The Privacy Program will only accept complaints regarding the misuse of personally identifiable information by a website operator. If you desire more information about the Privacy Program dispute resolution process visit www.bbbonline.org/privacy/dr.asp.

Changes to this policy

Please note that this Privacy Policy may change from time to time. We will not reduce your rights under this Policy without your explicit consent, and we expect most such changes will be minor. Regardless, we will post any Policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Policy changes). Each version of this Policy will be identified at the top of the page by its effective date, and we will also keep prior versions of this Privacy policy in an archive for your review. (There are currently no prior versions.)

If you have any additional questions or concerns about this Policy, please feel free to contact us any time through this web site.