This is the official privacy policy (“Privacy Policy”) of (the “Website”).  This Privacy Policy governs the personally identifiable information collected by us (“Personal Information”) and does not cover any other information, whether collected in any other manner or for any other purpose, nor on any other website or service unless specifically stated.

Our privacy standards are designed to ensure that we will:

§          protect your Personal Information, maintaining strict standards of security and confidentiality;

§          not disclose your Personal Information to any external organization unless we have previously notified you and obtained your consent;

§          require any other organization that we retain or engage to provide support services for us to conform to our privacy standards; and

§          make every effort to keep your Personal Information complete, up to date, and accurate.


We maintain physical, electronic and procedural safeguards to protect your Personal Information and while no data transmission over the Internet is 100% secure from intrusion, we have used and will continue to use commercially reasonable efforts to ensure the protection of your Personal Information.


Your Personal Information and any data, personal or otherwise, that you disclose and which may be saved on the Website is used to administer the Website and make information available to you in a manner consistent with all applicable laws, rules, regulations and other legal obligations.  Sometimes we may use your Personal Information to advise you of services that may be of interest to you.

We will not use any of your Personal Information for any purpose other than to provide the Website and contact you if you submit Personal Information to us because you want to receive correspondence from us, unless we provide advance notice to you of any other use.  We will not share your Personal Information with any non-affiliated parties.  We will only share your Personal Information with our operational service providers that assist in administrating the Website.

You are required to provide true, current, complete and accurate Personal Information and we have the right to refuse or revoke your right to use our Website and/or reject and delete any entry you make if we have reason to believe that the Personal Information you provide to us is or may be false, fraudulent, or inconsistent with this Privacy Policy. 

Although your privacy is very important to us, in this legal and technical environment, we cannot fully ensure that your Personal Information will not be disclosed to third parties. For example, we may be compelled to disclose your Personal Information to a governmental agency or a court or third parties may unlawfully intercept or access transmissions or private communications.  Additionally, we may (and you authorize us to do so) disclose any of your Personal Information to private entities, law enforcement or other government officials as we, in our sole discretion, believe necessary or appropriate to investigate or resolve possible problems or inquiries or to protect our own business and assets. In such circumstances, we will, where possible, require such third parties to maintain the confidentiality of any information so disclosed.

Our Website may contain links to websites and services owned or maintained by third parties. We are not responsible for and have no control over the privacy and data collection policies and practices implemented by such third parties, some of which may be substantially different from our corresponding policies and practices.  We have no obligation and are not liable for the treatment or maintenance of any information, content, data or materials transmitted, distributed or otherwise provided by you via any such third party websites or services.  It is your sole responsibility to review their respective policies and practices and determine whether the same are adequate.

Your Internet browser has a feature called “cookies.”  A cookie is a small piece of information that is stored in your browser by a web server.  Cookies can only be read by the website that placed the cookie on the hard drive of your PC.  However, cookies tell us nothing about who you are unless you specifically give us Personal Information.  You do not need to have cookies turned on to visit our Website.  In addition, you may elect not to allow cookies to be collected by selecting certain options on your browser.  We may also use temporary cookies (a.k.a. “per-session cookies”) to improve the functionality and usability of our Website. These temporary cookies are permanently erased from your computer as soon as you log out of your session on our Website or link to a different website from your parent browser window.

We have the right to revise this Privacy Policy at any time and from time to time by posting an updated version on our Website, without advance notice to you. The revisions shall be effective immediately upon posting. We encourage you to check this Privacy Policy often so that you are aware of the most current terms and conditions that apply to you. We may also, at our discretion, email you about these changes. Your continued use of our Website indicates your acceptance of this Privacy Policy and of the collection, use, disclosure, maintenance, management and storage of your Personal Information, as described.  This Privacy Policy remains applicable to your Personal Information for as long as your Personal Information is in our possession, even if you terminate or discontinue your use of our Website.

If you have any questions concerning our Privacy Policy, what information about you we collect and use, or if you do not understand any of the terms or disclosures noted above, you may contact us at: (212) 837-6000.

The foregoing statements, terms and conditions contained in this Privacy Policy is the sole statement of our privacy policy, and no summary, restatement or other version, or other statement or policy, in any form, including, without limitation, machine-generated, is valid.


This Privacy Policy can be reviewed at any time at

This Privacy Policy was last modified on October 13, 2008 and is effective immediately.

©  Copyright 2008 Hughes Hubbard & Reed LLP.  All Rights Reserved.