PRIVACY POLICY OF SPEAR HOLDINGS, INC. AND INDEPENDENT INVESTOR, INC.

Summary:

This paragraph does not contain our actual privacy policy and shall have no legal standing. It is intended only to provide a quick overview of the general intent of that policy, which is described below in detail. We carefully protect your privacy. We never release your e-mail address or mailing address to third parties, with the possible exception of matters involving fraud or other legal issues or legal requirements. We may send you announcements and offers regarding our own products and you may opt-out of receiving these announcements at any time. We may send you announcements and offers on behalf of third parties WITHOUT releasing your e-mail address or mailing address to those parties. You may opt-out of receiving any or all of these announcements at any time by following the directions contained in those announcements.

Details:

We respect and are committed to protecting your privacy. That is why we have adopted this Privacy Policy. This Privacy Policy lets you know how your personal information is processed and used. We promise that we will take steps to use your personal information only in ways that are compatible with this Privacy Policy. The following policies are only in effect for the Web pages, newsletters and opt-in announcement lists owned and operated by Independent Investor, Inc. and/or Spear Holdings, Inc. The following discloses our Privacy Policy.

What information are we collecting and how are we collecting it?

Every computer connected to the Internet is given a domain name and a set of numbers that serve as that computer's "Internet Protocol" IP address. When a visitor requests a page from any Web site within the Spear Holdings, Inc. Network, our Web servers automatically recognize that visitor's domain name and IP address. The domain name and IP address reveal nothing personal about you other than the IP address from which you have accessed our site. We use this information to examine our traffic in aggregate, but do not collect and evaluate this information for individuals. Our Web servers do not record e-mail addresses of visitors.

What are cookies?

Spear Holdings, Inc. or its advertisers may send a "cookie" to your computer. A cookie is a small piece of data that is sent to your browser from a web server and stored on your computer's hard drive. A cookie can't read data off your hard disk or read cookie files created by other sites. Cookies do not damage your system. We use cookies to identify which areas of the Spear Holdings Web sites you have visited or customized, so the next time you visit, those pages may be more readily accessible by you. Our advertisers may also use cookies to ascertain how many times you have seen an advertisement. Our advertisers and we may use this information to better personalize the content, banners, and promotions that you see on our Sites. You can choose whether to accept cookies by changing the settings of your browser. You can reset your browser to refuse all cookies, or allow your browser to show you when a cookie is being sent. If you choose not to accept these cookies, your experience at our site and other Web sites may be diminished and some features may not work as intended.

What other information do we request?

We may also request your e-mail address or mailing address for the purposes of conducting a survey or to provide or offer additional services (for example, subscriptions to newsletters or announcement lists). Whenever we request the identity of a visitor, we will clearly indicate the purpose of the inquiry before the information is requested. We maintain a strict "No-Spam" policy which means that we do not intend to sell, rent, or otherwise give your e-mail address to a third-party, without your consent. We may from time to time send e-mail announcing new Spear Holdings, Inc. products and services. If you choose to supply your postal address, you may receive mailings from other reputable, third party companies. When you enter a contest or other promotion, we may ask for your name, address, and e-mail address so we can administer the contest and notify winners. You may opt-out of receiving any and/or all of such notices or offers by procedures described below.

Will you disclose the information you collect to outside third parties?

Spear Holdings, Inc will disclose personal information when required by law or in the good-faith belief that such action is necessary to: 1) Conform to the edicts of the law or comply with a legal process served on Spear Holdings, Inc or Independent Investor, Inc., 2) Protect and defend the rights or property of the Spear Holdings, Inc. network of sites, or visitors to Spear Holdings, Inc. 3) Identify persons who may be violating the law, the legal notice, or the rights of third parties, 4) Cooperate with the investigations of purported unlawful activities. Spear Holdings, Inc. uses reasonable precautions to keep the information disclosed to us secure. Spear Holdings, Inc. reserves the right to transfer information in connection with the sale of all or part of Spear Holdings, Inc. capital stock or assets. Furthermore, we are not responsible for any breach of security or for any actions of any third parties that receive the information. Spear Holdings, Inc. also links to a wide variety of other sites and contains advertisements of third parties. We are not responsible for their privacy policies or how they treat information about their users. See below.

Opt-in announcement List Privacy Policy

When you sign up for a Spear Holdings, Inc. product, you may be given the opportunity to also receive announcements related to certain topics that you select. You will not receive these announcements unless you make such a selection. If you choose to receive announcements, you will receive commercial messages that are related to the topic you have selected on behalf of independent third parties that have contracted with Spear Holdings, Inc. YOUR E-MAIL ADDRESS IS NOT RELEASED TO ANY OF THESE COMPANIES. Personally identifiable information will not be used by Spear Holdings, Inc. for any purpose other than to deliver the information you have requested. You may stop the arrival of these announcements at any time by following the directions indicated on any message that you receive. If you have selected more than one type of information to receive, you will need to stop each type of announcement separately.

What else should I know about my privacy when online?

The Spear Holdings, Inc. Web sites contain many links to other Web sites. Spear Holdings, Inc. is not responsible for the privacy practices or the content of such Web sites. Spear Holdings, Inc. does not share any of the individual personal information you provide Spear Holdings, Inc. with the sites to which Spear Holdings, Inc. links, although Spear Holdings, Inc. may share aggregate data with such Web sites (such as how many people use our Site). Please check with those sites to determine their privacy policy. Please keep in mind that whenever you voluntarily disclose personal information online - for example through e-mail, discussion lists, or elsewhere - that information can be collected and used by others. In short, if you post personal information online that is accessible to the public, you may receive unsolicited messages from other parties in return. Ultimately, you are solely responsible for maintaining the secrecy of your personal information. Please be careful and responsible whenever you're online.

Your Consent To This Agreement

By using our Web site, you consent to the collection and use of information by Spear Holdings, Inc. as specified above. If we decide to change our privacy policy, we will post those changes on this page so that you are always aware of what information we collect, how we use it, and under what circumstances we disclose it