Valid from 01-01-2010

• A. Introduction
• B. Personal Information
• C. Notification of Changes
• D. Collection of Information
• E. How We Use Collected Information
• F. How We Store Collected Information
• G. Updating Your Information
• H. Contacting Us

This policy is available in a number of different European languages; all versions are legally binding but in the event of any inconsistency between the English Language version and a translated version, the English Language version will prevail.

CIG takes the privacy of your personal information very seriously. All data is collected, transferred, processed and maintained in accordance with the principles contained within the Privacy and Electronic Communications (EC Directive) Regulations 2003. At the same time, we need to collect, use and disclose personal information to enable us to operate our business in support of the services we offer. This Privacy Policy describes the information we collect and how we use that information. We encourage you to review this Privacy Policy.

By providing personal information to us and by dealing with us in the knowledge of this Privacy Policy, we will assume that you have consented to the collection, use and disclosure of your personal information in accordance with the terms set out in this Privacy Policy unless you advise us otherwise. If you object to your personal information being collected, used or disclosed as described in this Privacy Policy, you should not register with us as a customer.

In this Privacy Policy ”personal information” or “personally identifiable information” means information about you that can be attributed to you. CIG will collect, use and disclose your personal information only in accordance with the terms of this Privacy Policy.

We may collect, use and disclose personal information as authorised by law or with your consent. Depending on the circumstances, your consent to the collection, use and disclosure of personal information may be expressed or implied. Expres consent would arise if you specifically consented to a particular dealing in your personal information. Expres consent can be given orally, electronically (by clicking a button) or in writing. Implied consent can be inferred from the circumstances, taking into account the reasonable expectations of customers and the sensitivity of the information. If CIG needs to collect, use or disclose any information for any purpose not set out in this Privacy Policy, CIG will give you appropriate notification and give you the opportunity to object or decline to the collection, use, or disclosure of this information.

If you have questions or concerns regarding this Privacy Policy, you should contact the CIG Customer Service at commodityinvestmentgroupinc(at)verizon.net.

While FIB will hold and transmit your personal information in a safe, confidential, and secure environment, FIB is not responsible for the privacy practices or the content of third party referrals or web site links.

We reserve the right to modify or amend this Privacy Policy at any time and for any reason. When changed, we will provide notice to you on our website that it has been changed. Please check the CIG website at www.cominvestmentgroup.com at any time for the most current version of our Privacy Policy.

Customers submitting information to or through these third-party websites should review the privacy statement of these sites before providing them with personally identifiable information.

Required Information
To use the CIG Service or one of the offered products, you must provide your name, address, phone number, birth date, e-mail address, government issued identification and bank account information. We also ask you to choose a security question to answer (such as your city of birth or your pet's name) This required information is necessary for us to process transactions, issue a new password if you forget or lose your password, and to protect you, CIG and our other Customers against identity theft and bank account fraud, and to contact you should the need arise in administering your Account.

Transaction Information
We retain your personal information, including transaction information for all of your transactions through CIG, for fraud and security purposes, even after your Account is closed. We also collect the IP address of the computer or device you use to access your CIG Account, in order to help detect possible instances of unauthorized transactions.

Information About You From Third Parties
In order to protect all our Members against potential fraud, we verify with third party verification service providers the personal information you provide. In the course of such verification, we may also receive personal information about you from such service providers.

Web Site Traffic Information
Because of the way that World Wide Web communication standards work,  we automatically receive the Web address of the site that you came from or are going to, when you arrive at or leave the CIG website. We also collect information on which pages of our Web site you visit while you are on the CIG 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 behaviour and preferences, to develop and improve our services to you, and to manage the load on our servers. We do not track the Web sites that you visit before or after you leave the CIG site.

Our Use of "Cookies"
"Cookies" are small files of data that reside on your computer and allow us to recognize you as a CIG customer if you return to the CIG site using the same computer and browser. We send a "session cookie" to your computer if and when you log in to your Account by entering your e-mail address and password. These cookies allow us to recognize 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.

Most browsers allow you to turn off cookies. If you want to know how to do this, please look at the help menu on your browser. However, switching off cookies will severely restrict your use of the CIG site.

Internal Uses
Except as otherwise provided in this Privacy Policy, we will obtain your explicit or implied consent to use your personal information in a particular manner. Set out below are certain circumstances where we may use your personal information without obtaining your further consent. These are:

1. To verify your identity and financial information;
2. To process your transactions, including using your bank account information to obtain payments owing to us;
3. To analyse your personal information and transaction history to assist us in developing and enhancing our services and our website, to conduct market analysis and strategic planning and to determine your eligibility to receive offers for special features, promotions, and products;
4. To use your personal information for the purpose for which it was provided and certain other activities that are reasonably ancillary to that purpose. For example, if you send us an e-mail with a question or comment, we will use your e-mail address to respond to you. Further, we may store your e-mail and e-mail address and a copy of our response for future reference;
5. To provide you with information about our services.

We give access to your personal information only to those employees who require it to provide our services.

Disclosure to Third Parties Other Than CIG Employees
CIG will not sell or rent any of your personal information to third parties.

CIG will not share any of your personal information with third parties except in the limited circumstances described below, as permitted by applicable law, or with your express permission. 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.

1. We share information with companies that help us to process the transactions you request and protect our customers transactions from fraud. In order to assist us in conducting or co-operating in investigations of fraud or other illegal activity, or in order to assist us in investigating suspected violations of our Terms of Use, we may disclose personal information to third parties where we believe it is reasonable and appropriate to do so.
2. 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.
3. We disclose information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you).
4. We share your information with our parent company, subsidiaries and joint ventures to help coordinate the services we provide to you and to enforce our Terms of Use.

Our Contacts with CIG Customers
We communicate with users on a regular basis via e-mail and live chat 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 a CIG Account, to send you notice of payments that you send or receive through CIG, to send information about important changes to our products and services, and to send notices and other disclosures required by law. Generally, customers cannot opt out-of these communications, but they will be primarily informational in nature rather than promotional.

Upon opening a CIG account, every user will receive an email confirming his successful registration.

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

Information Security and Protection
CIG is committed to handle your personal information with high standards of information security. 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 applicable regulations to guard your nonpublic personal information. We test our security systems regularly and also contract with outside companies to audit our security systems and processes.

We protect your information from error, loss, and unauthorised access. Our employees who have access to your information are made aware of how to keep it confidential. Each employee must sign an agreement stating that maintaining confidentiality is a condition of employment with CIG. All of your personal information is collected, used, and disclosed for business purposes only.

The security of your CIG account also relys on your protection of your CIG security identification. You must not share your password with anyone. CIG will never ask you to send your password to us in an e-mail, although we may ask you to enter this and other personal information on the CIG website, which will always have a URL beginning with https://www.cominvestmentgroup.com/.

Any e-mail or other communication asking you to provide personal information via e-mail, or linking to a website with an URL that does not begin with https://www.cominvestmentgroup.com/ should be treated as unauthorised and suspicious and should be reported to CIG immediately. If you do share your 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 security identification or password, please change it immediately and also contact us right away as described in Section H below.

You can review the personal information you provided us and make any desired changes to such information, or to the settings for your CIG account, at any time by logging in to your account on the CIG Web site and changing your preferences in the Options page of your account. If you close your CIG Account, we will mark your Account in our database as "closed," but will keep your account information in our database. This is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. However, if you close your account, your personally identifiable information will not be used by us for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement, or as required by law.

At your request, CIG will also share with you where your personal information has been stored, what personal information CIG has about you and for what purposes CIG uses it for.

If you have any questions about this privacy statement, CIG´s information practices, or your dealings with CIG, you can contact us via e-mail at commodityinvestmentgroupinc(at)verizon.net.

© Commodity Investment Group, Inc. 2010. All rights reserved.