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About SPXCO > Privacy Policy

Southern Pacific Exploration Company's Consumer Data Protection and Privacy Practices

Our board of directors and staff believe it is important to inform you of the data protection and privacy practices that we have instituted. This policy does not apply to the practices of companies that we do not own, control or have a contractual relationship with or to people that we do not employ or manage. To ensure that you can rely upon the quality of products and services we make available, our company stands behind the following privacy policy:

1. We will collect only the personal information that is necessary to conduct our business. That means just what is necessary to satisfy our regulatory requirements and provide competitive financial products and services. This information is maintained for indefinite or lengthy time periods.

2. We will protect your personal information. Our company will maintain strong security controls to ensure that investor information in our files and computers is protected. Where appropriate, we will use security-coding techniques to protect against unauthorized access to personal records, ensure accuracy and integrity of communications and transactions, and protect investor confidentiality. We have physical, electronic and procedural safeguards that comply with federal regulations to protect personal information about you.

3. We will only share information when absolutely necessary. We will only share information to administer the products and services we provide, when required to do so by the government, or when we partner with other businesses to offer a broader array of products and services.

4. We will not rent, sell, trade or share personal information about you with other people or nonaffiliated companies except to provide the products and services you requested or when we have your permission.

5. We provide the information to trusted partners who work on behalf of or with our company under strict confidentiality agreements. The businesses we select will offer products designed to enhance our investors' economic well being. These companies may use your personal information to help our company communicate with you about ongoing business between us and about offers from us and our marketing partners. However, these companies do not have any independent right to use or share this information.

6. We limit access to personal information about you to employees who we believe reasonably need to come into contact with that information to provide products or services to you or in order to do their jobs.

7. All employees, agents, brokers and partners who can reasonably be expected to come in contact with any such personal information are obligated to maintain confidentiality under such agreements with the company, and therefore, they have no independent right to use, share, sell, provide, divulge or otherwise dispose of this information.

8. We may use personal information to respond to subpoenas, court orders or legal process, or to establish or exercise our legal rights or defend against legal claims.

9. We believe it is necessary to share information in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of state or federal regulations or as otherwise required by law.

10. We transfer information about you if our company is acquired by or merged with another company. In this event, we will notify you before information about you is transferred and becomes subject to a different privacy policy.

We may update this policy. We will notify you about significant changes in the way we treat personal information by sending a notice to the primary Email address that you have provided, by mail update or by placing a prominent notice on our website and in our Offering Memoranda.

If you have questions or suggestions, please contact us at admin@spxco.com.

Customer Identification Program Notice:
Important Information You Need to Know About Opening an Account

To help the government fight the funding of terrorism and money laundering activities, federal law requires financial institutions to obtain, verify and record information that identifies each person who opens an account. This notice answers some questions about our company's Customer Identification Program.

What types of information will I need to provide?

When you open an account, our company is required to collect information such as the following from you:

•  Your name, Date of birth, Address, Identification number, among other details and; (see below):

•  U.S. Citizen: taxpayer identification number (social security number or employer identification number)

•  Non U.S. Citizen : taxpayer identification number, passport number, and country of issuance, alien identification card number, or government issued identification showing nationality, residence and a photograph of you. You may also need to show your driver's license or other identifying documents.

A corporation, partnership, trust or other legal entity may need to provide other information, such as its principal place of business, local office, employer identification number, certified articles of incorporation, government-issued business license, a partnership agreement or a trust agreement.

U.S. Department of the Treasury, Securities and Exchange Commission, NASD and New York Stock Exchange rules already require you to provide most of this information. These rules also may require you to provide additional information, such as your net worth, annual income, occupation, employment information, investment experience and objectives and risk tolerance.

Your firm may not be able to open an account or carry out transactions for you. If your firm has already opened an account for you, they may have to close it. We thank you for your patience and hope that you will support the financial industry's efforts to deny terrorists and money launderers access to America 's financial system.

How we handle information we gather through initial contact and when you verbally request and accept our company information and/or Confidential Offering Memoranda.

Our employees, agents, affiliates and brokers are required to maintain information about you which supports and exhibits the establishment of a relationship with you regarding our mutual interest in the projects and programs that our company undertakes to fund, develop and complete. This information typically includes:

•  Your name, address, telephone, fax and Email contact information
•  Your age and sex
•  Your profession, business or line of work, and whether you are an owner, principal or employee
•  Your educational background and business experience
•  Your investment experience(s) and the types of investments you have historically made, your investment frequency and what your investment objectives are
•  Your level of interest and the apparent timeliness of investing in our company's projects

This information is maintained within our offices for use in determining, at least initially, your level of interest in our projects and the suitability of such a potential investment for you at the current time. This information is allowed limited access by the employee or agent or trusted partner with whom you discuss this opportunity, and his or her immediate supervisor(s) for oversight purposes. Those employees and trusted partners work on behalf of this company under confidentiality agreements and they have no independent right to use or share this information.

If it is appropriate to proceed from this basic informational stage to responding to your request by providing a Confidential Information Memorandum, this information will be added to a secure computer database, with further access limited to the agent, employee or partner with whom you discuss this business matter and his/her immediate supervisor and office clerical staff, all of whom function under confidentiality agreements. For persons or entities who elect to participate in one of our company's projects or programs, further information is collected as follows.

How we handle information we gather when you participate in our projects or programs through our Confidential Offering Memoranda.

State and Federal regulatory authorities require that you complete a “Purchaser Suitability Questionnaire” along with an Application and Subscription Agreement to participate. Further, when you participate, various other documents are provided requiring your signature and limited personal information. The information collected on these various documents include:

•  Your name, address, telephone, fax and Email contact information
•  Your age and sex
•  Your profession, business or line of work, and whether you are an owner, principal or employee
•  Detailed information regarding your authority to enter into these agreements
•  Detailed information regarding the entity under which you are participating
•  Personal information regarding your recent and current income, tax brackets and source of income
•  Your investment experience(s) and types of investments you have historically made, your investment frequency and what your investment objectives are
•  Your general experience and knowledge in business affairs and willingness to exercise same as a participant

This information is maintained within our offices for use in determining the suitability of such a potential investment for you at the current time. We are required to collect and maintain this information by regulatory authorities under NASD requirements. This information is allowed limited access by the employee or agent or trusted partner with whom you discuss this opportunity, and his or her immediate supervisor(s) for oversight purposes. Those employees and trusted partners work on behalf of this company under confidentiality agreements and they have no independent right to use or share this information.

How we handle the information we gather when you visit our web site -
Web server activity log

Like most web servers on the Internet, our servers collect and store all of the information that your web browser sends when it requests a web page, including:

•  The name, domain and numerical internet address of the "host" computer (typically a computer belonging to your Internet Service Provider and not your personal computer) from which you access the Internet
•  The date and time you accessed our site
•  The Internet address of the web page that you came from
•  The page you requested from our site and the number of characters sent to your computer
•  The information your web browser software sends as its so-called "User Agent," which typically identifies the browser software and may also indicate the operating system and type of CPU used in your personal computer.

It is impossible to determine the actual identity of an individual user from this information.

The logs are periodically summarized and analyzed in order to study site usage over time and to perform other studies to help us improve the site's organization, performance and usefulness.

We limit access to personal information about you to employees whom we believe reasonably need to come into contact with that information to provide products or services to you or in order to do their jobs.

We have physical, electronic and procedural safeguards that comply with federal regulations to protect personal information about you.

Electronic Mail

When you send us personal identifying information via Email (that is, in a message containing a question or comment, or by filling out a form that Emails us this information), we use it to respond to your requests. We may forward your Email to other employees or contract personnel who are better able to answer your questions. We do not retain or distribute lists of Email addresses to any parties outside of the company except as necessary to conduct company business.

File Transfer Protocol (FTP)

Various company sites using the file transfer protocol may also store your Email address if your web browser is configured to provide it. By default most web browser software do not send your Email address; this option is configured through your browser preferences. In Netscape Navigator, for example, this option must be set by you through the Advanced preferences category by the item labeled, "Send Email address as anonymous FTP password."

Online Surveys

When you voluntarily provide us with personal information as part of an online survey, we use it to perform various quantitative and qualitative analyses to improve customer service and satisfaction. We may forward the information collected to other company employees or contract personnel to perform the actual analysis. You are under no obligation to participate in such surveys. Non-participation will not inhibit your use of our web site in any way. If you provided the information to us in error, you may request its removal at any time.

Ordering Products

When you voluntarily provide us with personal information such as your name, shipping and billing address, and credit card number when ordering products online, we use the information to fulfill your order. We may forward the information collected to other company employees or contract personnel or to other computer systems (such as secure electronic commerce servers) to complete the requested transaction.

Marketing Information

We may collect information from you, with your permission, that will allow us to provide various customer services, such as promotional materials and product availability notices. We may forward the information collected to other company employees or contract personnel to provide specific marketing services. We will remove such information at your request.

Collection and Release of Gathered Information

We want to make it clear that we will not obtain personal identifying information about you when you visit our web sites, unless you choose to provide such information to us. Except in the course of officially authorized law enforcement investigations, or in the event of a suspected attempt to deliberately circumvent our system's s'curity with the intent to gain unauthorized access or to do physical damage (for example, an attack by hackers), we do not attempt to identify individual users or share any information we receive with any parties outside of the company.

Retention of Collected Information

Cookies - Some applications may save a "cookie" on your computer's hard disk to provide a temporary history of actions taken. A common example is the tracking of items placed in an online "shopping basket." We do not retain any record of "cookies" beyond what is necessary for running the application.

Web server activity logs - Monthly extracts of the log files are archived and stored off-line at our discretion for an indefinite period of time. Some statistical summaries derived from these data may be retained online or off-line at our discretion for an indefinite period of time.

Email - Information collected via Email will be retained at our discretion in a directly readable form for as long as necessary to complete our response. The Email itself may be retained in an archival form indefinitely, at our discretion.

Online surveys - Information collected via online surveys may be maintained at our discretion for an indefinite period of time.

Marketing information - Such information may be maintained at our discretion for an indefinite period of time.

Liability

Neither the company nor any affiliate thereof, nor any of their employees, contractors or subcontractors, make any warranty, express or implied, nor assume any legal liability or responsibility for the accuracy, completeness or usefulness of any information, apparatus, product or process disclosed, nor represent that its use would not infringe on privately owned rights.

Content Accuracy, Completenes, and Usability of Data and Information

We make every effort to provide and maintain accurate, complete, usable and timely information on our web sites. However, some data and information accessed through these pages may, of necessity, be preliminary in nature and presented prior to final review and approval by the persons in charge of such review. The data and information is provided with the understanding that it is not guaranteed to be correct or complete. Users are cautioned to consider carefully the provisional nature of the data and information before using it for decisions that concern personal or public safety, or to conduct business that involves substantial monetary or operational consequences. Conclusions drawn from, or actions undertaken on the basis of, such data and information are the sole responsibility of the user.


SOUTHERN PACIFIC EXPLORATION COMPANY

Telephone and Fax (toll free): 888-OIL-NATION

Email: admin@spxco.com