Matthew Lee Company

In order to operate the Matthew Lee Company service and to reduce the risk of fraud, Matthew Lee Company Corp. ("Matthew Lee Company" or "we") must ask you to provide us information about yourself and your credit card and/or bank account. This Privacy Policy describes the information we collect and how we use that information.

If you sign up for Matthew Lee Company services, you authorise Matthew Lee Company and the issuer of the Matthew Lee Company services to exchange the information you provide in the application form. If you are approved for Matthew Lee Company services, your account will be governed by the issuing bank’s privacy policy.

Matthew Lee Company takes the privacy of your personal information very seriously and will use your information only in accordance with the terms of this Privacy Policy. We will not sell or rent your personally identifiable information or a list of our customers to third parties. However, as described in more detail in Part C below, there are limited circumstances in which some of your information will be shared with third parties, under strict restrictions, so it is important for you to review this Privacy Policy. This Privacy Policy applies to all services that are hosted on the Matthew Lee Company Web site, whether the services are offered by Matthew Lee Company, or by its subsidiaries.

If you have questions or concerns regarding this Privacy Policy, you should first contact Matthew Lee Company.

By accepting the Privacy Policy and User Agreement in registration, you expressly consent to our use and disclosure of your personal information in the manner described in this Privacy Policy. This Privacy Policy is incorporated into and subject to the terms of the Matthew Lee Company User Agreement.

Please note that your personal information will be stored and processed on our computers in the United States. The laws on holding personal data in the United States may be less stringent than the laws of your country, but Matthew Lee Company will hold and transmit your personal information in a safe, confidential and secure environment. If you object to your personal information being transferred or used as described in this Privacy Policy, please do not register for the Matthew Lee Company service.

Notification of Changes

This policy may be revised over time as new features are added to the Matthew Lee Company service or as we incorporate suggestions from our customers. If we are going to use or disclose your personally identifiable information in a manner materially different from that stated at the time we collected the information, you will have a choice as to whether or not we use or disclose your information in this new manner. Any material changes will be effective only after we provide you by e-mail with at least 30 days' notice of the amended Privacy Policy (if you have closed your Matthew Lee Company account, you will not be contacted to notify you of the amended Policy and your personal information will not be used or disclosed in this new manner).

We will post the amended Privacy Policy prominently on our Web site so that you can always review what information we gather, how we might use that information, and whether we will disclose it to anyone. Please check the Matthew Lee Company Web site at wwww.Matthew Lee Company.ws at any time for the most current version of our Privacy Policy.

Matthew Lee Company Shops and other pages on the Matthew Lee Company Web site include links to third party Web sites. These sites are governed by their own privacy statements, and Matthew Lee Company is not responsible for their operations, including but not limited to their information practices. Users submitting information to or through these third party Web sites should review the privacy statement of these sites before providing them with personally identifiable information.

A Special Note About Children.

Children are not eligible to use our service and we ask that minors (under the age of 18) do not submit any personal information to us or use the service.

B. Information We Collect

Required Information

To open an Matthew Lee Company account, you must provide your name, address, phone number, and e-mail address. In order to make payments through Matthew Lee Company, you must provide credit card, debit card or bank account information.

Pursuant to section 326 of the USA PATRIOT Act, the U.S. Department of the Treasury and the Securities and Exchange Commission require Matthew Lee Company Funds to obtain, verify, and record the following information for each investor in the Matthew Lee Company Money Market Fund.

Information About You From Third Parties

In order to protect all our customers against potential fraud, we verify with third parties the information you provide. In the course of such verification, we receive personally identifiable information about you from such services. In particular, if you register a credit card or debit card with Matthew Lee Company, we will use card authorisation and fraud screening services to verify that your card information and address matches the information that you supplied to Matthew Lee Company, and that the card has not been reported as lost or stolen.

If you register your online business with Matthew Lee Company or if you send or receive high overall payment volumes through Matthew Lee Company, in some circumstances we will conduct a background check on your business by obtaining information about you and your business from a credit bureau or a business information service such as Dun & Bradstreet. If you incur a debt to Matthew Lee Company, we will generally conduct a credit check on you by obtaining additional information about you from a credit bureau, to the extent permitted by law. Matthew Lee Company, at its sole discretion, also reserves the right periodically to retrieve and review a business and / or consumer credit report for any account, and reserves the right to close an account based on information obtained during this credit review process.

Additional Verification

If we cannot verify the information that you provide, or if you request a withdrawal by check to an address other than your verified credit card billing address, we ask you to send us additional information by fax (such as your drivers' license, credit card statement, and/or a recent utility bill or other information linking you to the applicable address), or to answer additional questions online to help verify your information.

Web Site Traffic Information

Because of the way that World Wide Web communication standards work, when you arrive at or leave the Matthew Lee Company Web site, we automatically receive the Web address of the site that you came from or are going to. We also collect information on which pages of our Web site you visit while you are on the Matthew Lee Company site, the type of browser you use and the times you access our Web site. We use this information only to try to understand our customers' preferences better and to manage the load on our servers, so as to improve our service and your experience with Matthew Lee Company. We do not track the Web sites that you visit before or after you leave the Matthew Lee Company site.

Our Use of "Cookies"

"Cookies" are small files of data that reside on your computer and allow us to recognise you as an Matthew Lee Company customer if you return to the Matthew Lee Company site using the same computer and browser. We send a "session cookie" to your computer if and when you log in to your Matthew Lee Company account by entering your e-mail address and password. These cookies allow us to recognise you if you visit multiple pages in our site during the same session, so that you don't need to re-enter your password multiple times. Once you log out or close your browser, these session cookies expire and no longer have any effect.

We also use longer-lasting cookies to display your e-mail address on our sign-in form, so that you don't have to retype the e-mail address each time when you log in to your Matthew Lee Company account. In addition, we use cookies to process our referral program, described in Section C below. Our cookie files are encoded so that Matthew Lee Company can only interpret your e-mail address and other information. We may, however, share cookie information regarding whether or not a certain user is already registered with Matthew Lee Company with certain merchants with whom we have an official co-marketing relationship.

Customer Service Correspondence

If you send us correspondence, including e-mails and faxes, we retain such information in the records of your account. We will also retain customer service correspondence and other correspondence from Matthew Lee Company to you. We retain these records in order to measure and improve our customer service, and to investigate potential fraud and violations of our User Agreement. We may, over time, delete these records if permitted by law.

Questionnaires, Surveys and Profile Data

From time to time, we offer optional questionnaires and surveys to our users for such purposes as collecting demographic information or assessing users' interests and needs. The use of the information collected will be explained in detail in the survey itself. If we collect personally identifiable information from our users in these questionnaires and surveys, the users will be given notice of how the information will be used prior to their participation in the survey or questionnaire.

Non-member Recipients and Requests

When a member either sends a payment to, or requests a payment from, an individual who is not a registered member of Matthew Lee Company, we will retain the information that the member submits to us, including, for example, the other party's email address and/or name, for the benefit of the member who is attempting to contact the non-member, so that the member can see a complete record of his or her transactions, including uncompleted transactions. Although this information is stored indefinitely, we will not market to the non-member in any way at any time. Additionally, these non-members have the same rights to access and correct information about themselves (assuming that their email addresses were correct enough to reach them) as anyone else who uses Matthew Lee Company.

C. Our Use and Disclosure of Information

We collect, store and process your personal information on servers located in the United States. We use the information we collect about you in order 1) to provide our services and process your transactions, 2) to provide customer service, 3) to determine your eligibility to receive offers for special features or products, and 4) to improve our products and services. At your option (as indicated in your Matthew Lee Company Profile settings), we use the information you provide to access specific third party services on your behalf and perform the actions that you request us to perform, such as invoicing winning bidders on behalf of auction sellers.

We give access to individually identifiable information about our users only to those employees who require it to fulfil customer service requests.

Disclosure to Other Matthew Lee Company Customers

If you are a registered Matthew Lee Company user, your name, e-mail address, phone number (if applicable) date of sign-up, and whether you have verified control of a bank account are displayed to other Matthew Lee Company customers whom you have paid or who are attempting to pay you through Matthew Lee Company. If you are a Business account holder, we will also display to other Matthew Lee Company customers the Web site address (URL) and customer service contact information that you provide us. However, your credit card number, bank account and other financial information will NEVER be revealed to anyone who has also paid through Matthew Lee Company, except with your express permission or if we are required to do so pursuant to a subpoena or other legal process.

If you are buying goods or services and paying through Matthew Lee Company, the seller of the goods or services may request that you provide a mailing address that Matthew Lee Company has confirmed as matching the billing address in the credit card system. You do not have to provide this information. If you do not provide the information, however, the seller may choose not to accept your Matthew Lee Company payment and not to complete the transaction.

Disclosure to Third Parties Other Than Matthew Lee Company Customers

Matthew Lee Company will not sell any of your personally identifiable information to third parties. Matthew Lee Company will not share any of your personally identifiable information with third parties except in the limited circumstances described below, or with your express permission (and with other Matthew Lee Company customers as described above). These third parties are limited by law or by contract from using the information for secondary purposes beyond the purposes for which the information is shared.

We share information with companies that help us process the transactions you request and protect our customers' transactions from fraud, such as sharing your credit card number with a service that screens for lost and stolen card numbers. See "Information About You From Third Parties" in Section B above. Additionally, if you go into a negative balance and owe us money, we may share information with processing companies including collection agencies.

We may disclose the information we collect, as described in Section B above, to companies that perform marketing services on our behalf. We may also disclose the information we collect (but not your bank account or credit card information) to other financial institutions with whom we have joint marketing agreements, in order to determine whether you are pre-approved for the products that Matthew Lee Company is jointly marketing with the third party (such as the Matthew Lee Company Visa credit card issued by Providian National Bank). These companies are subject to confidentiality agreements with us and other legal restrictions that prohibit using the information except to market the specified Matthew Lee Company-related products or services, unless you have affirmatively agreed or given your prior permission for other uses.

We disclose information that we in good faith believe is appropriate to cooperate in investigations of fraud or other illegal activity, or to conduct investigations of violations of our User Agreement. For example, this means that if we conduct a fraud investigation and conclude that one side has engaged in deceptive practices, we can give that person or entity's contact information (but not bank account or credit card information) to victims who request it.

We disclose information in response to a subpoena, warrant, court order, levy, attachment, order of a court-appointed receiver or other comparable legal process, including subpoenas from private parties in a civil action.

We share aggregated statistical data with our business partners or for public relations. For example, we may disclose that a specific percentage of our users live in California. However, this aggregated information is not tied to personally identifiable information.

As with any other business, it is possible that Matthew Lee Company in the future could merge with or be acquired by another company. If such an acquisition occurs, the successor company would have access to the information maintained by Matthew Lee Company, including customer account information, but would continue to be bound by this Privacy Policy unless and until it is amended as described in Section A above.

We share your information with our parent, subsidiaries and joint ventures to help coordinate the services we provide to you, enforce our terms and conditions, and promote trust and safety.

Our Contacts with Matthew Lee Company Customers

We communicate with users on a regular basis via e-mail to provide requested services, and we also communicate by phone to resolve customer complaints or investigate suspicious transactions. We use your e-mail address to confirm your opening of an Matthew Lee Company account, to send you notice of payments that you send or receive through Matthew Lee Company (including referral payments described below), to send information about important changes to our products and services, and to send notices and other disclosures required by law. Generally, users cannot opt out of these communications, but they will be primarily informational in nature rather than promotional.

We also use your e-mail address to send you other types of communications that you can control, including the Matthew Lee Company Periodical newsletter, auction tips, customer surveys and notice of special third-party promotions. You can choose whether to receive some, all or none of these communications when you complete the registration process, or at any time thereafter, by logging in to your account on the Matthew Lee Company Web site and changing your preferences in the Profile page of the My Account tab. You can also change your choices at any time through the same procedure.

In connection with independent audits of our financial statements and operations, the auditors may seek to contact a sample of our customers to confirm that our records are accurate. However, these auditors cannot use personally identifiable information for any secondary purposes.

Internet Address Information

We use IP addresses, browser types and access times to analyse trends, administer the site, improve site performance and gather broad demographic information for aggregate use.

Your Use of Information and Our Services

In order to facilitate the transactions between Matthew Lee Company members, our service allows you limited access other users' contact or shipping information. As a seller you may have access to the User ID, email address and other contact or shipping information of the purchaser, and as a purchaser you may have access to the User ID, email address and other contact information of the seller.

By entering into our User Agreement, you agree that, with respect to other users' personally identifiable information that you obtain through the site or through an Matthew Lee Company-related communication or Matthew Lee Company-facilitated transaction, you will only use this information for: (a) Matthew Lee Company-related communications that are not unsolicited commercial messages, (b) using services offered through Matthew Lee Company (e.g. insurance, shipping and fraud complaints), and (c) any other purpose that such user expressly agrees to after adequate disclosure of the purpose(s).

In all cases, you must provide users with the opportunity to remove them from your database and review any information you have collected about them. In addition, under no circumstances, except as defined in this Section, can you disclose personally identifiable information about another Matthew Lee Company user to any third party without our consent and the consent of such other user after adequate disclosure. Note that law enforcement personnel and other rights holders are given different rights with respect to information they access.

Matthew Lee Company does not tolerate spam. Therefore, without limiting the foregoing, you may not add an Matthew Lee Company user to your mail list (email or physical mail) without their express consent after adequate disclosure, even if said user has previously made a purchase from you. We strictly enforce our Anti-Spam Policy! To report Matthew Lee Company-related spam to Matthew Lee Company, please contact us.

Merchant Referral Program

When you sign up for an Matthew Lee Company account, you become eligible to participate in our Merchant Referral Bonus program. We provide you with a link on the Merchant Referral Bonus page, which identifies you as the referrer. If a merchant uses that link to sign up for a Premier or Business Matthew Lee Company account and completes the bonus requirements, you are eligible for a referral bonus. If you use a referral link to sign up, your business name (if you have a Business account) or first and last name (if you have a Premier account) may be listed in the referrer's Matthew Lee Company account, along with the amount of bonus you have generated for the referrer, which is calculated as a percentage of your transaction volume, as described in the Merchant Referral Bonus Policy.

Please use our referral program responsibly. We strictly enforce our Anti-Spam Policy! Read details on the Referral Bonus.

D. Information Security

Information Security

Matthew Lee Company is committed to handling your customer information with high standards of information security. Your credit card and bank account information is stored only in encrypted form on computers that are not connected to the Internet. We restrict access to your personally identifiable information to employees who need to know that information in order to provide products or services to you. We maintain physical, electronic and procedural safeguards that comply with federal regulations to guard your non-public personal information. We test our security systems regularly and also contract with outside companies to audit our security systems and processes. For more information on Matthew Lee Company's security practices, please visit the Matthew Lee Company Security Center.

The security of your Matthew Lee Company account also relies on your protection of your Matthew Lee Company password. You may not share your Matthew Lee Company password with anyone. Matthew Lee Company will never ask you to send your password or other sensitive information to us in an e-mail, though we may ask you to enter this type of information on the Matthew Lee Company website, which will always have a URL beginning with www.mlcompany.net

Any e-mail or other communication requesting your password, asking you to provide sensitive account information via email, or linking to a website with a URL that does not begin with www.mlcompany.net should be treated as unauthorised and suspicious and should be reported to Matthew Lee Company immediately using this form. If you do share your Matthew Lee Company password with a third party for any reason, including because the third party has promised to provide you additional services such as account aggregation, the third party will have access to your account and your personal information, and you may be responsible for actions taken using your password. If you believe someone else has obtained access to your password, please change it immediately by logging in to your account at www.mlcompany.net and changing your Profile settings, and also contact us right away.