Effective Date February 1^st 2008

Cogent Online Pty Ltd
ACN: 123 947 571 ABN: 81 123 947 571

Cogent Online respects the privacy of it′s members.

Cogent Online manages your data for the purpose of marketing third party products and services to subscribers.

Cogent Online sends information to subscribers that have consented to receiving material from Cogent Online.

Cogent Online intends to only send relevant targeted messages to subscribers that wish to receive them.

If you have been subscribed in error, have been subscribed by other individual/s without your consent or wish to have mailings to your address stopped for any reason Cogent Online will unsubscribe you within the shortest possible time from notification.

How do I unsubscribe or change my information?

You can unsubscribe from our mailing lists by the following methods:

1. Clicking the hyperlink located at the bottom of all Cogent Online branded mailings.
2. Replying to any Cogent Online mailing with a written request to unsubscribe. N.B this process is manual and it may take several days for updates to occur.
3. Using the Contact Us form on this site
4. Sending written notification to:
   Customer Information and Privacy Officer
   Cogent Online Pty Ltd,
   GPO Box 4515
   Sydney NSW 2001
   Australia

How is my confidential information protected?

We employ 256-Bit SSL encrypted secure transmission channels when you send us the following types of personal data during the order / payment process:

• Primary personal data (such as name and contact details)
• Other personal data (such as location, telephone and demographic data)
• Identifiers (such as credit card details, web site passwords)

We have implemented security policies, rules and technical measures to protect the personal data that we have under our control from:

• Unauthorised access
• Improper use or disclosure
• Unauthorised modification
• Unlawful destruction or accidental loss

Where we store your credit card details for recurring billing, these are maintained in an encrypted manner in isolated systems. Any time your credit card details are displayed to you on screen for confirmation, they will be partially obscured to protect your privacy.

All our employees, contractors and data processors, who have access to, and are associated with the processing of personal data, are obliged to respect the confidentiality of our visitors' personal data.

How is personal information collected?

Cogent Online collects personal information as provided by participating subscribers directly to Cogent Online or to participating website/companies that may include email address, name, telephone numbers, date of birth, occupations and areas of interest. Data is collected at the time of opt–in by active participation of the end user.

Interests are added in some cases where they can be reasonably assumed from the style of content of the participating website at which the user has subscribed.

What personal information is collected?

Cogent Online collects name, physical address, email address, phone numbers, job and industry function information and interest categories as provided by the end user.

Cogent Online collects IP address for validation and diagnostic purposes. We may also use cookies to personalize or simplify your user experience. Responses to Cogent Online campaigns such as positive opens and click throughs may also be collected in order to better target future mailings.

Will Cogent Online release my personal information to third parties?

Data is used only for the purpose of providing relevant marketing material to subscribers and will only be disclosed to Cogent Online staff and agents for that purpose.

Information is aggregated and provided as group statistics for advertisers to make purchasing decisions and analyze results from campaigns. Advertisers do not have access to any individual′s personal records.

Third parties will not be given access to an individual′s personal subscriber data unless ordered by order of Australian Federal or State authorities.

Personal information may on occasion be transferred to relevant agents for the purposes of de–duplication, correction or suppression.

Who owns Cogent Online data?

Data collected from Cogent Online websites remain the property of Cogent Online Pty Ltd.

How to contact Cogent Online

Under the Privacy Act you have the right to view or change any personal information that Cogent Online holds about you. If you wish to contact Cogent Online in relation to any privacy issues please feel free to using the following contact details.

Customer Information and Privacy Officer
Cogent Online Pty Ltd,
GPO Box 4515
Sydney  NSW 2001
Australia

Alternatively you can use the Contact Us form on this site

Cogent Online Pty Ltd
ACN: 123 947 571 ABN: 81 947 571

Please be advised that the absence of email addresses and phone numbers on this site is a deliberate anti–spam and privacy precaution.

Disclaimer

Cogent makes no warranty, express or implied as to the fitness for a particular purpose, or assumes any legal liability for the accuracy or usefulness of any information carried under Cogent′s website. Any consequential loss or damage suffered as a result of reliance on this information is the sole responsibility of the user.

Any reference to any specific product, process or service by provider manufacturer or distributor does not constitute or imply its endorsement or recommendation by Cogent.

Cogent makes no representation or warranty as the financial status or accuracy of any information concerning any organisation listed under Cogent′s website.

The use of any information on this service creates no legal obligation, affiliation or association with Cogent or with third parties arising as a consequence of using information provided by this service.

The property and copyright in all material contained in Cogent′s website vests in Cogent.

The unauthorised reproduction of any part of Cogents′s website is an infringement of copyright.

Damian Saunders 
Director, Cogent Pty Ltd

Cogent Anti–Spam Policy

Updated 01 February, 2008

At Cogent, we are aware of our responsibilities as a good Internet citizen and are dedicated to protecting the privacy rights of other Internet citizens. We vigorously oppose the sending of unsolicited email (spam).

Cogent does not allow anyone to use our services for the purpose of sending spam. We refuse business from known spammers. If a current Cogent customer uses our services to spam anyone, that customer′s service will be voided without refund.

It is a requirement that each email message sent out from Cogent includes an easy way for subscribers to remove themselves via an unsubscribe link. If a recipient calls our offices and requests to be manually removed from a customer′s list, we will manually unsubscribe the recipient from the customer′s account.

There are three ways by which a customer may violate this Anti–Spam policy:

1. By sending spam.
2. By not responding properly to an inquiry from a Cogent staff member about the source of a particular email list or email address.
3. By not including the required elements on every mass email sent through the service.

Cogent may determine at its sole discretion whether a customer is spamming. There are a number of factors Cogent uses to determine whether a customer is spamming, including, but not limited to: complaints sent to abuse report addresses, SpamCop reports, complaints sent to any of Cogent′s upstream providers, and evaluating a customer′s mass email statistics and recipient addresses. Decisions made by Cogent personnel regarding a customer′s use of Cogent are final.

More about Spam

Definition of Spam

Spam is unsolicited email sent in bulk. Any promotion, information or solicitation that is sent to a person via email without their prior consent, where there is no pre′existing relationship between the sender and the recipient, is spam.

Examples of Spam

Any email message that is sent to a recipient who had previously signed up to receive newsletters, product information or any other type of bulk email but later opted-out by indicating to the sender that they did not want to receive additional email, then that email is spam.

Any email message that is sent to recipients that have had no prior association with the organization or did not agree to be emailed by the organization is spam.

Any email message that is sent to a recipient without a way for a person to opt′out or request that future mailings not be sent to them, is spam.

Any email message that does not have a valid email address in the From Line is spam.

Any email message that contains any false or misleading information in the header, subject line or message itself is spam.

Any email that says you can earn $1000s each week from home is spam.

Any email message that promotes an adult web site is spam, unless the recipient has specifically requested information from that web site.

Any message that contains "ADV:", "ADV ADLT:", or "ADV ADULT" in the subject is spam.

Any message that is sent to email addresses that have been harvested off of web sites, newsgroups, or other areas of the Internet is spam.

Any message that is sent to email addresses that have been gathered via "email appending", also known as, e–pending, is spam. E–pending is the practice of merging a database of customer information that lacks email addresses for the customers with a third party′s database of email addresses in an attempt to match the email addresses with the information in the initial database.

What is not Spam

An email message is NOT spam if the recipient in anyway requested email be sent to them from the sender or the sender′s organization.

Anytime an organization sends a mass email message to one of its customers, it is NOT spam provided that the organization offers a way for the customer to opt–out of future mailings and that the customer did not previously opt–out.

An email message is NOT spam when sent to recipients who agreed to receive information or promotions from a partner organization (as long as there is a clear opt–out option).

Any customer that sends spam is in violation of this Anti–Spam policy.

The Complaint Response Process

Even though a customer may not be sending spam, complaints may still be received by Cogent from a customer′s recipients. It is Cogent′s policy to respond individually to every complaint, so that the complainant knows his/her address was not harvested, sold, rented, or otherwise improperly added to a customer's lists. The Cogent Abuse staff takes the following steps anytime a complaint is received:

• Contact the email Manager for the customer's account with a Cogent Abuse Inquiry. This inquiry will ask the customer to confirm the list source, in general, and also to provide all specific information available regarding the particular email address in question.
• Customers should respond within two business days of receiving an Abuse Inquiry from Cogent. Failure to respond to the Abuse Inquiry is in itself a violation of this policy. Failure to provide all requested information about the email address in question is a violation of this policy. The customer may not respond directly to the complainant without prior approval from the Cogent Abuse staff.
• The Cogent Abuse team reviews the customer‾s response and the entire complaint and determines whether or not the customer is in compliance with this policy.
• Cogent will respond to the complainant. As long as the customer has been adhering to this policy, Cogent will simply respond to the complainant letting him know how he opted in to receive emailings and reassure him that his email address has been unsubscribed from future mailings. We carbon copy the customer on our response to the complainant. Should the customer be found to be in violation of this policy, the customer will receive a spam determination response from our Abuse team with specific information related to the violation.

Why do we respond individually to every complaint?

We need to make sure that we serve our customers in the best way possible. Proper response to spam complaints is essential to ensure our reputation with email providers all over the world. If Cogent is used to send out spam or if we do not respond to spam complaints to inform the complainants that they did indeed sign up for our customer′s emailings, then we risk tainting our relationship with ISPs around the world and having our servers blocked by them.

We are here to help our customers maximize the effectiveness of their emailings, educate them as to the best email practices, and help them to avoid spam complaints.

Required Elements on Every Mass email

Every mass email sent through Cogent must contain:

1. Information on how the recipient joined the list
2. An unsubscribe mechanism, such as an unsubscribe link (for HTML messages) or instructions to reply back with "unsubscribe" in the Subject line (for plain text messages)
3. The sender′s postal address

To ask questions about this Anti–Spam Policy, or to report spamming activity by one of our customers, please contact our privacy department at:

Cogent On Line Pty Ltd.,
ACN 123 947 571
GPO Box 4515
Sydney NSW 2001
Australia

Alternatively you can use the Contact Us form on this site.

Please be advised that the absence of email addresses and phone numbers on this site is a deliberate anti–spam and privacy precaution.