Last Updated: January 30, 2008

Welcome to RINXCHANGE, an electronic, web-enabled exchange platform for trading RIN credits in the United States located at www.rinxchange.com (the “Site”), operated by Renewable Trading Services LLC (hereinafter, "RTS", "us", “our” or "we"). The Site offers visitors (“you” or “your”) access to various information about us. This privacy policy (the “Privacy Policy”) is intended to inform you about how RTS collects and uses your personally identifiable information (“Personal Information”) and other information in operating the Site.

Please read the Privacy Policy carefully. By accessing the Site, you acknowledge that you have read, understood and agreed to be bound by the terms and conditions set forth in the Privacy Policy. If you do not wish to be bound by this Privacy Policy, you are not authorized to use the Site.

We reserve the right to modify this Privacy Policy at any time, and you agree that all such changes shall be effective and binding upon you upon being posted to the Site. You agree to review the Agreement periodically to be aware of any such modifications. For your convenience, we will indicate for you the date of any prior modifications to the Agreement after “Last Updated” above.

Scope

By accepting the Privacy Policy and the User Agreement in registration, you expressly consent to our collection, storage, use and disclosure of your Personal Information as described in this Privacy Policy.

Collection

You can browse the Site without telling us who you are or revealing any Personal Information about yourself. However, you will need to voluntarily provide us with your Personal Information in order to trade RINs and use other functionality of the Site. If you choose to provide us with Personal Information, you consent to use of such information as set forth herein and the transfer and storage of such information on our servers located in the United States and Canada.

We may collect and store Personal Information, including without limitation:
• email address, physical contact information, and financial information, such as credit card or bank account numbers;
• billing and other information you provide to buy or sell RINs;
• any Personal Information you include in our registration form that you mail to us, and any supplementary information provided by you.

We also may collect non-Personal Information, including without limitation:
• transactional information based on your activities on the Site (such as bidding, buying, selling);
• other information from your interaction with the Site or any services, content and advertising contained on the Site, including computer and connection information, statistics on page views, traffic to and from the Site, ad data, IP address and standard web log information;
• information from other companies with whom we collaborate, such as demographic and traffic data; and
• other supplemental information from third parties (for example, if you incur a debt to RTS, we will generally conduct a credit check by obtaining additional information about you from a credit bureau, as permitted by law; or if the information you provide cannot be verified, we may ask you to send us additional information, such as your driver license, credit card statement, or a recent utility bill or other information confirming your address, or to answer additional questions online to help verify your information).

Marketing

We don't sell or rent your Personal Information to third parties for marketing purposes without your explicit consent. We may combine your information with information we collect from other companies and use it to improve and personalize our services, content and advertising. If you don't wish to receive marketing communications from us or participate in our ad-customization programs, simply indicate your preference at registration or by following the directions provided in an email or from a link on the advertisement.

Use

Our primary purpose in collecting Personal Information is to provide you with the services available on the Site. You agree that we may use your Personal Information to:
• provide the services and customer support you request;
• resolve disputes, collect fees, and troubleshoot problems;
• prevent potentially prohibited or illegal activities, and enforce our User Agreement;
• customize, measure and improve our services, content and advertising;
• tell you about targeted marketing, service updates, and promotional offers based on your communication preferences; and
• compare information for accuracy, and verify it with third parties.

Our Disclosure of Your Information

We may disclose Personal Information to respond to legal requirements, enforce our policies, respond to claims that a listing or other content violates the rights of others, or protect anyone's rights, property, or safety.

We may also share your Personal Information with:
• Our affiliates and subsidiaries to facilitate the provision of our services
• Service providers under contract who help with our business operations (such as fraud investigations, bill collection, affiliate and rewards programs and co-branded credit cards).
• Other third parties to whom you explicitly ask us to send your information (or about whom you are otherwise explicitly notified and consent to when using a specific service).
• Law enforcement or other governmental officials, in response to a verified request relating to a criminal investigation or alleged illegal activity or if we are concerned that a violation of law or third party rights may occur or may have occurred. In such events, we will disclose information relevant to the investigation, such as name, city, state, zip code, telephone number, email address, User ID history, IP address, fraud complaints, and bidding and listing history.
• Third party service providers who help us verify the viability of RINs posted on the Site, to segregate RINs for purposes of exchanging them through the Site, and who otherwise facilitate our provision of services to you through the Site;
• As we in our sole discretion believe necessary or appropriate in connection with an investigation of fraud, intellectual property infringement, piracy, or other unlawful activity. In such events, we will disclose name, street address, city, state, zip code, country, phone number, email address and company name.
• Other business entities, should we plan to merge with or be acquired by that business entity.

Activity Associated with User IDs

Your User ID is displayed throughout RINXCHANGE and is therefore available to the public. All of your activity on our Site is traceable to your User ID. Other people can see your bids, RINs that you have purchased in the past, RINs for sale, and so on. Notices are sent to other members regarding suspicious activity and policy violations on our Site and refer to User IDs and specific RINs. Therefore, if you associate your name with your User ID, the people to whom you have revealed your name will be able to personally identify your activities on the Site.

Cookies

We use "cookies" (small files placed on your hard drive) on certain of our pages to help analyze our web page flow; customize our services, content and advertising; measure promotional effectiveness, and promote trust and safety
A few important things you should know about cookies are that:
• We offer certain features that are available only through the use of cookies.
• We use cookies to help identify you and maintain your signed-in status.
• Most cookies are "session cookies," meaning that they are automatically deleted from your hard drive at the end of a session.
• You are always free to decline our cookies if your browser permits, although doing so may interfere with your use of some of our services.

Accessing, Reviewing and Changing Your Personal Information

You can see, review and change most of your Personal Information by logging on to your account. Generally, we will not manually modify your Personal Information because it is very difficult to verify your identity remotely. You must promptly update your Personal Information if it changes or is inaccurate.

User Agreement

You agree that you have read and agree with the terms of our User Agreement http://www.rinxchange.com/downloads/RINXCHANGE%20User%20Agreement.pdf

Security

Your information is stored on our servers located in the United States and Canada. We employ commercially reasonable methods standard in our industry to protect your Personal Information against unauthorized access and disclosure. However, as you probably know, third parties may unlawfully intercept or access transmissions or private communications, and other users may abuse or misuse your Personal Information that they collect from the Site. Therefore, although we work very hard to protect your privacy, we do not promise, and you should not expect, that your Personal Information or private communications will always remain private.

Third Parties

Except as otherwise expressly included in this Privacy Policy, this document addresses only the use and disclosure of information we collect from you. If you disclose your information to others, whether they are bidders, buyers or sellers on our Site or other sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. RTS does not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable. We encourage you to ask questions before you disclose your Personal Information to others.

General

If your questions are not answered online, you may write to us at: Renewable Trading Services LLC,. Attn: Privacy Practices, 55 Broad Street, 28th Floor, New York, NY 10004, or you may visit our Contact Us page.