STARTRAK WEBSITE PRIVACY POLICY

This Privacy Statement discloses the information gathering and dissemination practices of StarTrak Systems LLC in connection with the World Wide Web site located at www.startrak.com (collectively, the "Site"). The Site is controlled and operated by StarTrak Systems LLC from its offices in the United States. This Privacy Statement addresses only StarTrak Systems' practices regarding information collected directly from the Site – it does not address or govern any information gathering or dissemination practices related to information collected by way of other means or media, whether off-line or otherwise. ORBCOMM Headquarters can be contacted by mail at 395 W Passaic Street, Suite 325, Rochelle Park, NJ 07662 USA, by phone at 1.703.433.6300 (within the United States), or by e-mail at sales@orbcomm.com.

1. Collection of Personal Information from Site Visitors

StarTrak Systems LLC may collect or track (1) the home server domain names, e-mail addresses, type of client computer, files downloaded, search engine used, operating system, and type of Web browser of visitors to the Site, (2) the e-mail addresses of visitors that communicate with StarTrak Systems via e-mail, (3) information knowingly provided by the visitor in online order forms, sign-up forms, contact forms, online resume submissions, registration forms, surveys, e-mail, and other online avenues (including, without limitation, demographic and personal profile data), and (4) aggregate and user-specific information regarding which pages Site visitors access.

StarTrak Systems may place Internet "cookies" and digital "certificates" on visitors' hard drives. Internet cookies save data about individual visitors, such as the visitor's name, password, user-name, screen preferences, and the pages of a site viewed by the visitor. When the visitor revisits the Site, StarTrak Systems may recognize the visitor by the Internet cookie and customize the visitor's experience accordingly. Visitors may decline Internet cookies, if any, by using the appropriate feature of their Web client software, if available. A digital certificate is an attachment to an electronic message used for security purposes. The certificate verifies that the user sending a message is who he or she claims to be, and provides the receiver with the means to encode a reply. A certificate contains the domain name for which the certificate was issued, the owner of the certificate and the domain name, the physical location of the owner and the validity dates of the certificate. When the visitor revisits the Site, the server authenticates itself to the web browser by presenting the digital certificate. The certificate is proof that an independent trusted third party has verified that the website belongs to the visitor it claims to belong to. A valid certificate gives StarTrak Systems' clients confidence that they are sending personal information securely, and to the right place.

StarTrak Systems also may use Web bugs to gather, store, and track certain information related to your visit to and activity on the Site. A Web "bug" is a file object, which can be a graphic image such as a transparent one pixel-by-one pixel graphics file, which is placed on a Web page or in an e-mail message to monitor user activity. A Web bug can gather, for example, the IP address of your computer, the time the Web page was viewed, and the type of browser used.

When a visitor performs a search within the Site, StarTrak Systems may record information identifying the visitor or linking the visitor to the search performed. StarTrak Systems may also record limited information for every search request and use that information to solve technical problems with the services available directly or indirectly in connection with the Site and to calculate overall usage statistics.

2. Use of Personal Data Collected

Personal data collected by StarTrak Systems may be used by StarTrak Systems for many reasons, for example, for editorial and feedback purposes, for marketing and promotional purposes, for a statistical analysis of users' behavior, for product development, for content improvement, for fulfillment of a requested transaction or recordkeeping, or to customize the content and layout of the Site. Aggregate data on visitors' home servers may be used for internal purposes, and individually identifying information, such as names, postal and e-mail addresses, phone numbers, and other personal information which visitors voluntarily provide to StarTrak Systems may be added to StarTrak Systems' databases and used for future calls and mailings regarding Site updates, new products and services, and upcoming events.

StarTrak Systems also may use Site visitor data to contact the Site visitors regarding account status and changes to the subscriber agreement, privacy statement, and any other policies or agreements relevant to Site visitors.

3. Disclosure of Personal Data to Third Parties

Aggregate data on visitors' home servers may be provided to marketing, promotion, and similar firms. Identifiable and non-identifiable visitor information and data which visitors provide to StarTrak Systems may be provided to third parties who provide products, information, or services which StarTrak Systems believes that visitors may be interested in directly or indirectly purchasing or obtaining. Identifiable or non-identifiable data also may be disclosed or distributed to another party with which StarTrak Systems enters or reasonably may enter into a corporate transaction, such as, for example, a merger, consolidation, acquisition, or asset purchase, or to a third party pursuant to a subpoena, other form of legal process, or a request by or on behalf of any local, state, federal, or other government department or agency.

While StarTrak Systems may undertake efforts to see that any third party to which StarTrak Systems shares, rents, sells, or otherwise discloses personal data is under a contractual obligation to use the personal data solely for the purposes for which the data was disclosed, such third parties are independent third parties over which StarTrak Systems exercises no control, and StarTrak Systems is not responsible for their conduct, actions, omissions, or information handling or dissemination practices and StarTrak Systems will not be liable therefore.

This Site may contain links to other World Wide Web sites or advertisements for or placed by third parties. StarTrak Systems is not responsible for the privacy practices of such Web sites, advertisers, or third parties, or for the content of such sites or advertisements. It is possible that these links or advertisements, themselves, may be used by third parties or others to collect personal or other information about Site visitors. It is solely the visitors' obligation to review and understand the privacy practices and policies of these other Web sites and of these advertisers and third parties.

4. Security Measures

StarTrak Systems has implemented numerous security features to prevent the unauthorized release of or access to personal information. For example, employees responsible for operation and maintenance of the Site are asked to sign a non-disclosure agreement. Please be advised, however, that the confidentiality of any communication or material transmitted to or from StarTrak via this Site or e-mail cannot be guaranteed. Accordingly, StarTrak Systems is not responsible for the security of information transmitted via the Internet. Instead of communicating with StarTrak Systems LLC via e-mail or the Internet, visitors can contact ORBCOMM Headquarters by mail at 395 W Passaic Street, Suite 325, Rochelle Park, NJ 07662 USA, by phone at 1.703.433.6300 (within the United States).

5. Opt-Out Right

Except in connection with StarTrak Systems' provision of services, information, and products requested by a visitor, the visitor may opt out of having his or her personally identifiable information, which has been voluntarily provided to StarTrak Systems through an account registration, customer order, or electronic news or information subscription, prospectively retained by StarTrak Systems, used by StarTrak Systems for secondary purposes, or disclosed by StarTrak Systems to third parties by contacting StarTrak Systems via postal mail, e-mail, or telephone at the addresses set out above. (This does not apply to collection of the type of Web browser of the visitor to the Site or to information provided or collected that does not meet the above description.)

6. Access to and Ability to Correct Personal Data

Upon a visitor's request via postal mail, e-mail, or phone, StarTrak Systems will provide to the visitor a summary of any personally identifiable information retained by StarTrak Systems regarding the visitor, which information has been voluntarily provided to StarTrak Systems through the Site through an account registration, customer order, or electronic news or information subscription. A visitor may modify, correct, change or update their personally identifiable information by contacting StarTrak Systems via postal mail, e-mail, or telephone at the address or number above.

7. Right to Change Privacy Statement

StarTrak Systems may change this Privacy Statement at any time. Notice of any new or revised Privacy Statement, as well as the location of the new or revised statement, will be posted on the Site for at least 60 days after the change. It is the obligation of users visiting the Site before the change to learn of changes to the Privacy Statement since their last visit. Any change to this Privacy Statement shall be effective as to any visitor who has visited the Site before the change was made.

8. Date Privacy Statement Effective

This Privacy Statement is effective April 27, 2005.