GraciasVRS Communications, Inc. Privacy Policy

GraciasVRS, Inc. ("GraciasVRS," "we" or "us") is committed to protecting your privacy. This Privacy Policy ("Privacy Policy" or "Policy") explains how we collect and use information about you and your use of our Web site, products and services, including but not limited to GraciasVRS telecommunications relay services, such as GraciasVRS's Video Relay Service ("VRS"), Internet Protocol Relay ("IP Relay"), or other IP-based relay services (collectively, "IP-based Relay Services"), and Videophones. We urge you to read this Privacy Policy carefully so that you will understand clearly how GraciasVRS may collect and use information provided by you because, by using GraciasVRS's Web site or using or registering for our products or services, you agree to the terms of this Privacy Policy and authorize GraciasVRS to disclose that information, as described more fully below.

GraciasVRS will inform you of the following in this Privacy Policy:

• What personally identifiable information of yours is collected;
• Who is collecting the information;
• How the information is used;
• With whom the information may be shared;
• What choices are available regarding collection, use and distribution of the information;
• What kind of security procedures are in place to protect the loss, misuse or alteration of information under our control; and,
• How you can delete or correct any inaccuracies in the information.

I. Collection of Information

A. Personally Identifiable Information

Personally identifiable information ("PII" or "Personal Information") is information that can be used to identify or contact you. GraciasVRS generally collects Personal Information in two ways: (1) when you choose to use, apply for, register for, or purchase a service or product offered by GraciasVRS, or (2) when you choose to send an e-mail, participate in surveys, or engage in other transactions or interactions with GraciasVRS. We also may collect non-personally identifiable information ("non-PII" or "Non-Personal Information") when you interact with or respond to e-mails, newsletters or promotional or other informational communications, or register for or use the Web site, products or services of GraciasVRS.

In order to have access to certain GraciasVRS products and services, you are required to complete an application or other registration form(s) and provide other information reasonably necessary for us to provide the products and/or services to you. Some examples of the type of information we collect in the registration form(s) are:

• Your Name
• Your Address(es) (including the physical location from which you will access GraciasVRS VRS or IP Relay services)
• Your Phone Number(s)
• Your E-mail Address(es)
• Your IP Address(es)
• Your Operating System/Machine Type

In addition, Personal Information and Non-Personal Information collected, maintained, or generated by your use of GraciasVRS's service or products may be transmitted periodically to GraciasVRS as part of software or other updates to equipment and/or services provided to or used by you.

B. Non-Personally Identifiable Information

You may view or use our Web site without registering or submitting any Personal Information. In that case, the only information we collect will be Non-Personal Information collected through the use of cookies or other Web devices. Non-PII may include Web site pages viewed, time spent using certain services, demographic data, user preferences or other information that does not specifically identify any one individual. We also may collect non-PII when you send us e-mails or respond to special promotions or newsletters. For example, GraciasVRS, or an authorized third party acting on our behalf, may use cookies to collect information that allows us, or such authorized third party, to dynamically generate advertising, Web pages, e-mail or other content or to statistically monitor whether people are opening e-mails or using the Web site, products or services of GraciasVRS. It may be possible to stop or restrict the placement of these devices on your computer by adjusting your Web browser preferences, in which case you may still use our Web site, but it may interfere with some of its functionality.

C. Links to Other Web Sites

GraciasVRS may provide links to, or automatically produce search results for, third-party Web sites or resources or third-party information referencing or linking to third-party Web sites or resources. GraciasVRS has no control over such third-party Web sites and resources, and you acknowledge and agree that GraciasVRS is not responsible for the content or information contained therein. When you follow such a link, you are no longer protected by our Privacy Policy, and we encourage you to read the privacy statements or other disclaimers of such other parties. GraciasVRS is not responsible for the privacy or security practices or the content of non-GraciasVRS Web sites, services or products. GraciasVRS cannot and does not guarantee, represent or warrant that the content or information contained in such third-party Web sites and resources is accurate, legal, non-infringing or inoffensive. GraciasVRS does not endorse the content or information of any third-party Web site or resource and, further, GraciasVRS does not warrant that such Web sites or resources will not contain viruses or other malicious code or will not otherwise affect your computer. By using any of GraciasVRS's systems or Web sites to search for or link to a third-party Web site, you agree and understand that GraciasVRS shall not be responsible or liable, directly or indirectly, for any damages or losses caused or alleged to be caused by or in connection with your use of, or reliance on, GraciasVRS to obtain search results or to link to a third-party Web site.

D. E-mails or Other Communications

This Privacy Policy does not protect you when you send business information, ideas, concepts or inventions by e-mail or other means to GraciasVRS. If you want to keep confidential any business information, ideas, concepts or inventions, do not send them in an e-mail or by other means to GraciasVRS.

II. Use of Your Personal Information

As noted, Personal Information is information that can be used to identify or contact you. In the course of providing services to you, we collect and maintain certain Personal Information about you. In addition, we may collect and maintain other Non-Personal Information generated by or related to the provision or use of our products or services, including the type of equipment you use, your operating system, and data regarding your usage of our services (including minutes of use, telephone numbers or IP addresses called, date and time of call, etc.).

GraciasVRS will access, use, share or disclose your Personal Information only under the following limited circumstances.

First, we may access, use, share or disclose your Personal Information if reasonably necessary to:

• Initiate, render, bill and collect for the provision of GraciasVRS products or services;
• Comply with valid legal requirements such as a law, regulation, search warrant, subpoena or court order;
• Enforce applicable provisions of GraciasVRS's "VP-100 Premium GraciasVRS VRS® Service & Products Agreement / VP-200 Premium GraciasVRS VRS® Service & Products Agreement," including investigation of potential violations;
• Detect, prevent, or otherwise address fraud, security or other technical issues; or
• Protect the rights, property or safety of GraciasVRS, our employees or users, or the public as required or permitted by law.

Second, GraciasVRS may use your Personal Information to improve our products or services or the content of our Web site or in connection with promotional or other informational communications.

Third, GraciasVRS may provide Personal Information to its corporate subsidiaries and affiliates. Any Personal Information provided to GraciasVRS's subsidiaries or affiliates will be treated in accordance with the terms of this Privacy Policy. In addition, GraciasVRS may provide Personal Information to certain authorized third parties acting on our behalf ("Authorized Entities") to provide or market GraciasVRS products or services, or to perform other functions on our behalf. Such sharing shall occur only after such Authorized Entities have entered into a confidentiality agreement that (1) prohibits them from using, allowing access to, or disclosing your Personal Information to any other party (unless required to do so under force of law) and (2) requires them to have appropriate protections in place to ensure the ongoing confidentiality of your Personal Information.

Fourth, in the event that GraciasVRS undergoes a business transition or change in corporate structure, such as a merger, acquisition, or sale of a portion of its assets, users' Personal Information may become part of the assets transferred. We may choose in such instances to disclose Personal Information and Non-Personal Information about you, the consumer, to a third party for compensation.

Fifth, in order to provide our services, we may occasionally provide information to other companies or independent contractors that work on our behalf.

Finally, information that does not reveal how to identify or contact a user is not Personally Identifiable Information. For example, "aggregated data," such as the number of visitors who access GraciasVRS's Web site on a particular day or the percentage of users who download services from GraciasVRS, does not constitute Personal Information under this Policy.

Notwithstanding any other provision of this Agreement, to the extent you use the GraciasVRS Web site to place a telecommunications relay service call, your privacy rights and GraciasVRS's obligations with regard to any information generated by that call shall be governed by applicable law, including relevant sections of the Communications Act of 1934, as amended, and any applicable implementation rules and orders.

III. Security

GraciasVRS wants your Personal Information to remain as secure as possible. That is why we have a two-tier security system that combines leading technical safeguards and a code of conduct for those personnel who are permitted to access your Personal Information. On the technical side, GraciasVRS uses Secure Socket Layer (SSL) encryption technology in transmitting your Personal Information to our servers to help ensure the integrity and privacy of the Personal Information you provide to us via the Internet. Encryption involves systematically scrambling numbers and letters, so that even if someone managed to intercept the information, they would not be able to make sense of it. In order to take advantage of this encryption technology, you need to have an Internet browser that will support 128-bit encryption, such as Netscape or Microsoft Explorer. As an additional security measure, your Personal Information is also physically maintained on a separate server where your password is encrypted and stored in a database. On the personnel side, only certain GraciasVRS personnel are authorized to access your Personal Information. All GraciasVRS personnel must abide by our Privacy Policy and those who violate our Privacy Policy are subject to disciplinary action, up to and including termination.

GraciasVRS will continue to revise its policies and implement additional security features as new technologies becomes available. Although we will make every reasonable effort to protect your Personal Information from loss, misuse, or alteration by third parties, no system or service can give a 100% guaranty of security, especially a product or service that relies upon the public Internet. Therefore, you acknowledge the risk that third parties may gain unauthorized access to your information when using our products or services.

IV. Updating or Deleting Your Personal Information

You can always contact us in order to (1) delete your Personal Information from our systems, (2) update the Personal Information that you have provided to us, or (3) change your preferences with respect to marketing contacts or other activities, by calling us at (877) 326-3877. We will endeavor to accommodate such requests, unless such information is needed to comply with valid legal requirements or to protect the rights, property or safety of GraciasVRS, our employees or users, or the public. Any requested changes will not have any effect on other information that GraciasVRS maintains. If you have a complaint or problem you may contact us by calling at (877) 326-3877 and the customer service department will forward your complaint to the appropriate GraciasVRS department for a response or resolution. We try to answer every e-mail in a timely manner but please be aware that some requests may take longer than others.

You should be aware that it may not be technologically possible to remove from our servers each and every record of the information you have provided to GraciasVRS. The need to back-up our systems to protect information from inadvertent loss means that a copy of your Personal Information may exist in a non-erasable form that may be difficult or impossible for us to locate. Nevertheless, upon receiving your request, we will endeavor to delete all Personal Information stored in the databases we actively use for research and daily business activities, as well as other readily searchable communications.

V. Changes to this Privacy Policy

GraciasVRS will update this policy if our practices change or if the law requires changes to it. You should review this policy regularly for changes, and can easily see if changes have been made by checking the Effective Date below. If you do not agree to the terms of this Privacy Policy or any revised policy, you should exit the site and cease use of all GraciasVRS services and products immediately. Your continued use following the posting of any changes to this Policy means you agree to be bound by the terms of this Privacy Policy.