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Revised: June 1, 2007

The Mirachem Corporation (“Mirachem”) has adopted the following Online Privacy & Security Policy (“Policy”) to govern the use of information and data (“Online Information”) processed through its web sites, email systems, online applications, user communities and/or other online venues (“Online Properties”). This policy governs how employees and agents of Mirachem store and use Online Information, as well as the rights and responsibilities of users submitting Online Information (“Users”).

 1.    General Data Privacy and Security Standards
       In addition to the specific requirements on this policy relating to Online Information, Mirachem has long-standing and well-      
       documented policies concerning the use, storage and distribution of private or secure information. In general, these policies
       require all employees and agents of Mirachem to:

1. Always value the trust of our business contacts and respect the importance of keeping personal, financial and other confidential information secure.
2. Provide information to interested parties on Mirachem’s policies and standards regarding the use, storage and distribution of confidential information 
3. Consider all private information, such as names, address, billing information, credit card or banking account details, to be confidential information, and handle it according to our strict policies governing such information
4. Adhere to the highest standards of conduct in ensuring the security and proper use of confidential information.
5. Follow procedures designed to maintain accurate information and respond in a timely manner to requests to change or correct information.
6. Use a combination of safeguards, including physical, electronic and procedural security, to protect our business contacts from the criminal use of their private information and to prevent unauthorized access to this data.
7. Require other companies with which we do business to abide by our privacy and security policies and to maintain the security of confidential information.

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2.  User Responsibilities and Best Practices
It is considered a best practice to review the privacy and user policies of any website visited. We encourage Users to review Mirachem’s Online Privacy & Security Policy before using our Online Properties or submitting any information to us. By using our Online Properties and/or submitting information, Users are accepting the provisions and practices of this Policy. Users should also review Mirachem’s Online Acceptable Use Policy for additional information on Mirachem’s Online Properties.

Users should also be aware that this Policy applies only to Mirachem Online Properties and not to other websites. This may include websites that are linked to or from one of our Online Properties. All Mirachem properties will be identified, at a minimum, by information contained in the footer of each web page. We endeavor to author all online content in such a fashion that external links (web links that do not lead to Mirachem Online Properties) open in a separate browser window to assist Users in knowing that they have left a Mirachem property, however, we cannot guarantee that this will be true in all cases.

Another best practice when conducting online activity is to adopt safe browsing habits. These include an awareness of the possibility of encountering various risks and vulnerabilities including viruses, malicious scripts, “phishing” schemes or online “forgeries”.  Users who are unfamiliar with these terms and their associated risks are encouraged to learn more about these threats and the steps necessary to minimize them.

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3.   Changes to this Policy
This Policy may be changed at any time. Any changes will be posted online and be available by other means as described in this Policy. However, changes will only apply to activities and information on a go-forward basis and will not be applicable retroactively or to previously-submitted Online Information. Users are encouraged to review the privacy policy whenever they visit the site to make sure that it understood how any personal information provided will be used.

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4.    Information that we Collect and How We Use It
There are five types of Online Information that we collect and use. These types of data progress in the level of confidentiality from that which is accessible to most Mirachem personnel, to that which is restricted to a need-to-know basis. These types of data are:

              i.        Automatically Gathered Background Data (“AGBD”)

             ii.        User-Submitted Information (“USI”)

            iii.        Personal and/or Organizational Information (“POI”)

            iv.        Transaction Data (“TD”)

             v.        Financial Information (“FI”)

Please note that not all of these types of information will be collected from each user and/or with each visit to an Online Property.

              i.        Automatically Gathered Background Data (“AGBD”)
We routinely collect information about each use of our Online Properties. However, this information is not personally identifiable and is not attached to specific Users, nor is it used to track individual-specific traffic.  Such information may include the internet protocol (IP) address, browser software, operating system, site referral information, time, date and viewing history of each User. This information is used to understand the usage of our Online Properties, evaluate the effectiveness of content delivered to Users, monitor the results of marketing efforts and improve the overall online experience for our Users.

             ii.        User-Submitted Information (“USI”)
Users may choose to submit information to us. This is often done via an online form or email. The information collected varies widely dependant on the nature of the communication. Common examples of this type of information include product inquiries, requests for service, comments and opinions or responses to surveys. This information is used to respond to User requests, facilitate the sales and customer support processes, continue Mirachem’s quality improvement efforts and other business functions as may be appropriate. USI may also include data that is of another type listed above and which we will handle accordingly. 

            iii.        Personal and/or Organizational Information (“POI”)
This type of information includes details necessary to communicate effectively. This includes names, mailing, physical and email addresses, telephone and fax numbers, website addresses and other personally and/or organizationally-identifiable information. This information is only collected via a voluntary submission, which may occur in a variety of formats including phone conversation, fax transmission, email, written communication or online communication. POI is used to facilitate reliable and effective communication between Mirachem and its business contacts.

            iv.        Transaction Data (“TD”)
Transaction Data includes the specifics of product and service transactions that occur between Users and Mirachem. This may include product information, details of customer use of our products, payment methods, shipping and logistics data, order history and payment history.TD may be used to provide customer service and technical support, monitor and evaluate Mirachem’s marketing programs, identify potential areas of interest and opportunity for customers, facilitate Mirachem’s sales efforts and support Mirachem’s account administration activities.

            vi.        Financial Information (“FI”)
Financial Information includes all data relating to the processing of payments and handling of financial transactions. This may include banking information, Mirachem credit account information, credit card / debit card data, letters of credit or financial statements. FI is used to process payments and to facilitate Mirachem’s collection of open accounts.         

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5.     How We Protect Information that We Collect
      Mirachem uses multiple security measures to protect data against unauthorized access and illicit use. These include a   
      variety of physical, electronic and procedural safeguards.

              i.        Physical Security
Mirachem’s physical facilities are organized and secured in such a fashion that data is physically segregated under lock-and-key to prohibit unauthorized access. Increasing levels of physical security exist as the level of confidentiality of the data increases.

             ii.        Electronic Security
Mirachem’s data networks utilize user-specific access control. Security is enforced on a user-by-user basis, ensuring that individuals have access to only that data which is required for their job function. Mirachem also utilizes a series of hardware and software security measures to minimize risk from viruses and other online threats, and conducts frequent systems audits to screen for vulnerabilities. Mirachem complies with the Payment Card Industry (PCI) standards of security and employs a third-party vendor to perform external electronic threat assessments.

            iii.        Procedural Security
Users with access to Mirachem’s internal operations are trained in the importance information security and are routinely audited to ensure compliance with Mirachem’s standards. These audits cover a variety of topics including data handling and filing, best practices for working online, privacy and security policies, legal obligations and customer service standards.  
        
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 6.     How We Share Information that We Collect
       Mirachem is opposed to the practice of selling, renting or otherwise distributing confidential or private information to
       third parties for marketing or other for-profit purposes. We do share certain types of data under certain circumstances as
       outlined below.

              i.        Automatically Gathered Background Data (“AGBD”)
This information is routinely used by Mirachem personnel and its third-party contractors in development of our Online Properties and other sales/marketing efforts. This data may also be used in the aggregate to develop general Internet usage statistics.

             ii.        User-Submitted Information (“USI”)
User-Submitted Information may be shared on an anonymous basis with Mirachem’s third-party contractors as relevant to a specific project or assignment. Any USI that contains Personal and/or Organizational Information will be handled according to our policies regarding that type of information.

            iii.        Personal and/or Organizational Information (“POI”)
Access to POI by Mirachem employees is restricted to those with a need to know.

 We provide POI to our third party contractors, agents or partners who work on our behalf to provide certain products or services. These third parties do not have the right to use POI beyond what is necessary to fulfill their obligations to Mirachem, and are contractually obligated to maintain the confidentiality and security of this information.

 Mirachem may use POI, and share it with applicable contractors, when trying to protect against or prevent actual or potential fraud or unauthorized transactions, or when investigating fraud or unauthorized access which has taken place.

 We may release POI when we believe, in our good judgment, that such release is reasonably necessary to comply with applicable law, enforce or apply the terms of any of our policies or agreements, or to protect the rights, property or safety of The Mirachem Corporation, our Users, or others relevant parties.

 We may also share POI under other circumstances with the prior consent of the applicable business contact.  

            iv.        Transaction Data (“TD”)
Access to TD by Mirachem employees is restricted to those with a need to know.

We provide TD to our third party contractors, agents or partners who work on our behalf to provide certain products or services. These third parties do not have the right to use TD beyond what is necessary to fulfill their obligations to Mirachem, and are contractually obligated to maintain the confidentiality and security of this information

Mirachem may use TD, and share it with applicable contractors, when trying to protect against or prevent actual or potential fraud or unauthorized transactions, or when investigating fraud or unauthorized access which has taken place.

We may release TD when we believe, in our good judgment, that such release is reasonably necessary to comply with applicable law, enforce or apply the terms of any of our policies or agreements, or to protect the rights, property or safety of The Mirachem Corporation, our Users, or others relevant parties.

We use TD, without the inclusion of Personal and/or Organizational Information, for developing customer and technical support, as well as for our sales and marketing programs.  

We may also share TD under other circumstances with the prior consent of the applicable business contact.

             v.        Financial Information (“FI”)
Access to FI by Mirachem employees is restricted to those with a need to know.

We must share certain FI with third party service providers such as credit card processors and merchant banks to process applicable financial transactions. 

Mirachem may use FI, and share it with applicable contractors, when trying to protect against or prevent actual or potential fraud or unauthorized transactions, or when investigating fraud or unauthorized access which has taken place.

We may release FI when we believe, in our good judgment, that such release is reasonably necessary to comply with applicable law or to enforce or apply the terms of any of our policies or agreements.

Mirachem reports payment history and performance on Mirachem credit accounts to one or more credit reporting agencies. Mirachem may also use FI as permitted by law in its efforts to collect on balances owed to it, or in pursuit of any legal and/or collections efforts as permitted by law.

We may also share FI under other circumstances with the prior consent of the applicable business contact.        

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7.     How Contacts Can Control the Information that We Collect
Users have control over the information that we collect as follows.

              i.        Automatically Gathered Background Data (“AGBD”)
Some of this information is collected as soon as a visit is made to one of Mirachem’s Online Properties. The only way to avoid this collection is to not visit one of our Online Properties.

We also utilize cookie and tracking technology in some areas, depending on the features offered and/or selected by the User. If personally identifiable information is provided, such as when using our E-commerce or user community functions, this information may be associated with a cookie. We use these cookies for security and/or user-customization purposes. Users can control our Online Properties’ ability to use these technologies based on the privacy and/or security settings in their software. Some of our Online Properties may be unavailable and/or inoperative if the User restricts the ability to use these technologies.

Once we have collected this AGBD, it becomes the property of The Mirachem Corporation and will remain accessible to us, and be used by us, as we deem appropriate without further input from the User.

             ii.        User-Submitted Information (“USI”)
User-Submitted Information can only be collected when Users provide it to us. If the User does not wish us to have access to this information, it should not be provided.

Once we have collected this USI, it becomes the property of The Mirachem Corporation and will remain accessible to us, and be used by us, as we deem appropriate without further input from the User.

            iii.        Personal and/or Organizational Information (“POI”)
Mirachem’s access to POI is possible only when it is provided by a User in some fashion. If Users do not wish us to have this data, it should not be submitted.

Once we have collected POI, Users can exercise a certain degree of control over Mirachem’s use of this data.

At any time, Users may request in writing that we purge their POI from our records. We must retain POI that relates to actual transactions, or in other circumstances that may require us to keep legal or bookkeeping records.

Users may also provide us with instructions on how we and may not communicate with them using POI. This is done by indicating Communications Preferences. This can be done via our online tool, in writing via a fax transmission or postal mail, or by contacting our Customer Service Department as indicated in this Policy. We cannot be restricted from reasonably contacting a User regarding a transaction between us. We must also maintain a valid mailing address and at least one of either a valid telephone number or email address in our records.

            iv.        Transaction Data (“TD”)
Access to TD by Mirachem employees is restricted to those with a need to know.

We provide TD to our third party contractors, agents or partners who work on our behalf to provide certain products or services. These third parties do not have the right to use TD beyond what is necessary to fulfill their obligations to Mirachem, and are contractually obligated to maintain the confidentiality and security of this information

Mirachem may use TD, and share it with applicable contractors, when trying to protect against or prevent actual or potential fraud or unauthorized transactions, or when investigating fraud or unauthorized access which has taken place.

We may release TD when we believe, in our good judgment, that such release is reasonably necessary to comply with applicable law, enforce or apply the terms of any of our policies or agreements, or to protect the rights, property or safety of The Mirachem Corporation, our Users, or others relevant parties.

We use TD, without the inclusion of Personal and/or Organizational Information, for developing customer and technical support, as well as for our sales and marketing programs. 

We may also share TD under other circumstances with the prior consent of the applicable business contact.

Transaction Data is the property of The Mirachem Corporation.

             v.        Financial Information (“FI”)
Access to FI by Mirachem employees is restricted to those with a need to know.

We must share certain pieces FI with third party service providers such as credit card processors and merchant banks to process applicable financial transactions. 

Mirachem may use FI, and share it with applicable contractors, when trying to protect against or prevent actual or potential fraud or unauthorized transactions, or when investigating fraud or unauthorized access which has taken place.

We may release FI when we believe, in our good judgment, that such release is reasonably necessary to comply with applicable law or to enforce or apply the terms of any of our policies or agreements.

Mirachem reports payment history and performance on Mirachem credit accounts to one or more credit reporting agencies. Mirachem may also use FI as permitted by law in its efforts to collect on balances owed to it or in pursuit of any legal and/or collections efforts as permitted by law.

We may also share FI under other circumstances with the prior consent of the applicable business contact.

Once we have collected FI, Users can exercise a certain degree of control over Mirachem’s use of this data.

At any time, Users may request in writing that we purge their FI from our records. We must retain FI that relates to actual transactions, or in other circumstances that may require us to keep legal or bookkeeping records. Mirachem also reserves the right to retain and use any FI necessary to enforce or apply any policy or agreement, or to facilitate the collection of any open account.      

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 8.     How to Contact Us About this Policy or to Exercise Your Rights
       Written questions or concerns about this Policy can be directed to Mirachem as follows:

        Via Postal Mail:
        The Mirachem Corporation
        Attention: Security Administrator
        PO Box 14059
        Phoenix, AZ 85063

        Via Email:
        The Mirachem Corporation
        Attention: Security Administrator
        security@mirachem.com

        Via Fax:
        The Mirachem Corporation
        Attention: Security Administrator
        602-353-1161

       You may also contact us by phone on our toll-free Customer Service number at 800-847-3527 or at our administrative
       offices, 602-272-6066.

      To establish or change your Communication Preferences with us, you can use the online tool found here, complete our designated form, found here, and return it to us by mail or fax, or contact our Customer Service Department at 800-847-3527.

      All requests for removal of information from our records must be made in writing and must include the following:

      -   The full name, title (if applicable) and contact telephone number of the individual making the request.
      -   The contact name, organization name (if applicable), and complete address associated with the records to be deleted.
      -   A description of the information to be removed from our records.
      -   The original signature of the requestor.

     Requests for removal should be directed to:

     Via Postal Mail:
     The Mirachem Corporation
     Attention: Security Administrator
     PO Box 14059
     Phoenix, AZ 85063

     Via Courier:
     The Mirachem Corporation
     Attention: Security Administrator
     4645 W. McDowell Road, Unit 103
     Phoenix, AZ 85035
     
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