Privacy Policy Statement

Last Updated October 29, 2007 This is the web site of Value Averager LLC. Our postal address is 801 N Pitt St. Alexandria, Va 22314

We can be reached via e-mail at jaymuntz@valueaverager.com
or you can reach us by telephone at 703 563 9426

Collection and Use of Personally Identifiable Information
We collect the domain name, name, and e-mail address (where possible) of visitors to our Web page, the name and e-mail addresses of those who post messages to our bulletin board or blog, the name and e-mail addresses of those who communicate with us via e-mail, aggregate information on what pages consumers access or visit on our site, user-specific information on what pages consumers access or visit, information volunteered by the consumer, such as survey information and/or site registrations, payment information (e.g., credit card number and billing address).

We collect financial account holding information from visitors who register to use the site for Value Averaging. This information includes the financial institution, account names, account types, securities held in the accounts and the number of shares of each security. We do not have a relationship with any financial services provider and we do not interact with them in any way. We do not collect account numbers and we do not verify that the financial information that is collected is correct.

The information we collect is used for internal review and is then discarded, used to improve the content of our web page, used to customize the content and/or layout of our page for each individual visitor, used to notify consumers about updates to our Web site, and used by us to contact consumers for marketing purposes.

Financial information that is collected is used to provide analysis of the visitor's holdings and to provide recommendations. It is not used for any other purpose. Upon request we provide site visitors with access to all information [including proprietary information] that we maintain about them, unique identifier information (e.g., customer number or password) that we maintain about them, transaction information (e.g., dates on which customers made purchases, amounts and types of purchases) that we maintain about them, contact information (e.g., name, address, phone number) that we maintain about them and, a description of information that we maintain about them. Consumers can access this information by e-mailing us jaymuntz@valueaverager.com.

Registered users of the site can change their Personally Identifiable Information at any time by clicking on the "My Account" menu item after logging in.

Opting Out of Email Communications
Users wishing to opt out of email communications may take one or more of several actions:

1. Visitors wishing to stop receiving new post alerts from the ValueAverager Forums can visit the forums at http://www.valueaverager.com/forums/ and click the Unsubscribe Icon ( ) next to any portion of the forum where it appears. This will remove the user's email subscription to that portion of the forum.
2. Visitors wishing to stop receiving email alerts about new posts on the ValueAverager blog can click on the unsubscribe link at the bottom of any email they have received from this service.
3. Registered users wishing to stop receiving alerts and reminders from the ValueAverager service may do so by logging into the ValueAverager site and clicking on the "Email Preferences" link in the navigation bar at the top of the page. Users can change the frequency and/or turn off alerts that are provided by the ValueAverager service from this page. These email reminders and alerts are an integral part of the operation of the ValueAverager service, and we do not recommend unsubscribing from them because we believe visitors will suffer from a poorer user experience.
4. Any visitor may contact ValueAverager support at jaymuntz@valueaverager.com for help with opting out of any email service provided by ValueAverager.

Collection and Use of Third Party Personally Identifiable Information
Tell a Friend
If you choose to use our Tell a Friend service to tell a friend about our site, we will ask you for you and your friend's name and email address. We will automatically send your friend a one-time email inviting him or her to visit the site. ValueAverager stores this information for the purpose of sending this one-time email, tracking the success of the program, and to aid in our investigating any misuse of the Tell a Friend feature.

We will not use any personally identifiable information collected from the Tell a Friend feature for any purpose beyond the Tell a Friend functionality described above.

Sharing of Personally Identifiable Information
All personally identifiable information collected is held in the strictest confidence. We do not share personally identifiable information with any agents, vendors, or other entities.

We reserve the right to disclose your personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served on our Web site.

Security
ValueAverager has put in place certain technological and procedural security functions in order to protect the personally identifiable information it collects, uses or transfers from loss, misuse, alteration or destruction. ValueAverager uses firewalls to prevent outside parties from accessing our database server through the Internet, and physical access to our database server is restricted to authorized individuals.

Tracking Technologies
A cookie is a small text file that is stored on a user's computer for record-keeping purposes. We use cookies on this site. We do not link the information we store in cookies to personally identifiable information you submit while on our site. One exception is with the use of the ValueAverager forums. If you check the "Save Password" box when you log in, the forums software will set a cookie that will allow you to be automatically logged into the forums on subsequent visits.

We use Session ID cookies on the site to maintain the state of your session. This is used to make it easier for you to navigate the site and to allow for you to interact with the site over multiple page views. A Session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. The only time a persistent cookie is used is when you choose the "Save Password" option on the ValueAverager forums. You can remove persistent cookies by following the directions provided in your internet browser's "help" file.

ValueAverager web pages may contain a file called a Web Beacon, which allows us to count the number of times a page is accessed. This is used to compile reports on site usage. Email messages sent by ValueAverager may also contain a Web Beacon to determine if the message was opened or not.

ValueAverager's web server maintains a log of all requests. This is done to measure and report on site usage. The web server log records the following information about every request:

• The page requested
• The date and time of the request
• The referring URL
• The ip address that the request came from.

This information may be linked to personally identifiable information for users who have logged in.

Public Display of Personally Identifiable Information
If you use the ValueAverager Forums or the ValueAverager Blog, you should be aware that any personally identifiable information you submit there can be read, collected or used by other users of the website, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit in these forums.

Changes in this Privacy Statement
If we decide to change our privacy policy, we will post those changes to this privacy statement, the home page, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by email, or by means of a notice on our home page.

TRUSTe
ValueAverager is a licensee of the TRUSTe Web Privacy Seal Program. TRUSTe is an independent, non-profit organization whose mission is to build users' trust and confidence in the Internet by promoting the use of fair information practices. This privacy statement covers the web site valueaverager.com. Because this web site wants to demonstrate its commitment to your privacy, it has agreed to disclose its information practices and have its privacy practices reviewed for compliance by TRUSTe.

If you have questions or concerns regarding this statement, you should first contact Jay Muntz at jaymuntz@valueaverager.com. If you do not receive acknowledgement of your inquiry or your inquiry has not been satisfactorily addressed, you should contact TRUSTe at http://www.truste.org/consumers/watchdog_complaint.php. TRUSTe will then serve as a liaison with us to resolve your concerns.