Safe Harbor Privacy Policy

Assessments 24X7, LLC. (A24X7) complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. A24X7 has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view A24X7's certification, please visit http://www.export.gov/safeharbor/

SAFE HARBOR

The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EEA to the United States (the "U.S.-EU Safe Harbor"). The EEA also has recognized the U.S.-EU Safe Harbor as providing adequate data protection (OJ L 45, 15.2.2001, p.47). The United States Department of Commerce and the Federal Data Protection and Information Commissioner (FDPIC) of Switzerland have agreed on a similar set of principles and frequently asked questions to enable U.S. companies to satisfy the requirement under Swiss law that adequate protection be given to personal information transferred from Switzerland to the United States (the "U.S.-Swiss Safe Harbor"). Consistent with its commitment to protect personal privacy, A24X7 adheres to the principles set forth in the U.S.-EU Safe Harbor and the U.S.-Swiss Safe Harbor (the "Safe Harbor Principles")

SCOPE

This Safe Harbor Privacy Policy (the "Policy") applies to all personal information received by c in the United States from the EEA and from Switzerland, in any format, including electronic, paper or verbal.

DEFINITIONS

For purposes of this Policy, the following definitions shall apply:

"Client" means any third party that collects or uses personal information under the instructions of, and solely for, A24X7 or to which A24X7 discloses personal information for use on A24X7 's behalf.

"A24X7" means Assessments 24X7, LLC., its predecessors, successors, subsidiaries, divisions and groups in the United States.

"Personal information" means any information or set of information that identifies or could be used by or on behalf of A24X7 to identify an individual. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.

"Sensitive personal information" means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, views or activities, that concerns health or sex life, information about social security benefits, or information on criminal or administrative proceedings and sanctions other than in the context of pending proceedings. In addition, A24X7 will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.

PRIVACY PRINCIPLES

The privacy principles in this Policy have been developed based on the Safe Harbor Principles.

NOTICE

Where A24X7 collects personal information directly from individuals in the EEA, it will inform them about the purposes for which it collects and uses personal information about them, the types of non-agent third parties to which A24X7 discloses that information, the choices and means, if any, A24X7 offers individuals for limiting the use and disclosure of personal information about them, and how to contact A24X7. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to A24X7, or as soon as practicable thereafter, and in any event before A24X7 uses or discloses the information for a purpose other than that for which it was originally collected.

Where A24X7 receives personal information from its subsidiaries, affiliates or other entities in the EEA, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.

CHOICE

A24X7 will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

For sensitive personal information, A24X7 will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

A24X7 will provide individuals with reasonable mechanisms to exercise their choices.

DATA INTEGRITY

A24X7 will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. A24X7 will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current

TRANSFERS TO CLIENTS

A24X7 will obtain assurances from its clients that they will safeguard personal information consistently with this Policy. Examples of appropriate assurances that may be provided by clients include: a contract obligating the client to provide at least the same level of protection as is required by the relevant Safe Harbor Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), being subject to Swiss Federal Act on Data Protection, Safe Harbor certification by the client, or being subject to another European Commission or Swiss FDPIC adequacy finding (e.g., companies located in Canada). Where A24X7 has knowledge that a client is using or disclosing personal information in a manner contrary to this Policy, A24X7 will take reasonable steps to prevent or stop the use or disclosure.

ACCESS AND CORRECTION

A24X7 grants individuals access to personal information that it holds about them. This is provided via admin account access for all levels of participants. In addition, A24X7 takes steps to permit these participants to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.

SECURITY

A24X7 will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

ENFORCEMENT

A24X7 will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee or client that A24X7 determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment or contractual agreement.

DISPUTE RESOLUTION

BBB EU SAFE HARBOR is our independent recourse mechanism for Safe Harbor privacy complaints.

Privacy Complaints by European Union Citizens:

In compliance with the Safe Harbor Principles, A24X7 commits to resolve complaints about your privacy and our collection or use of your personal information. European Union citizens with inquiries or complaints regarding this privacy policy should first contact A24X7.

Brandon Parker
11415 Via Promesa, San Diego, CA 92124
[email protected]
206-400-6647

A24X7 has further committed to refer unresolved privacy complaints under the US-EU [and EU-Swiss] Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by A24x7, please visit the BBB EU SAFE HARBOR web site at https://www.auto.bbb.org/EU-Safe-Harbor-Complaint-Form/ for more information and to file a complaint.

Any questions or concerns regarding the use or disclosure of personal information can also be directed to the A24X7 Privacy Office at the address given above. A24X7 will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Policy.

LIMITATION ON APPLICATION OF PRINCIPLES

Adherence by A24X7 to these Safe Harbor Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations; and (c) to the extent expressly permitted by an applicable law, rule or regulation.

INTERNET PRIVACY

A24X7 sees the Internet and the use of other technology as valuable tools to communicate and interact with consumers, employees, clients, assessment participants, business partners, and others. A24X7 recognizes the importance of maintaining the privacy of information collected online and has created a specific Internet Privacy Policy (the "IPP") governing the treatment of personal information collected through web sites that it operates. With respect to personal information that is transferred from the European Economic Area or Switzerland to the U.S., the IPP is subordinate to this Policy. However, the IPP also reflects additional legal requirements and evolving standards with respect to Internet privacy. A24X7 's Internet Privacy Policy can be found at https://www.assessments24x7.com/legal/privacy

CONTACT INFORMATION

Questions or comments regarding this Policy should be submitted to the A24X7 Privacy Office by mail to:
Assessments 24X7, LLC Privacy Office
Attn: Brandon Parker, Managing Partner
11415 Via Promesa, San Diego, CA 92124
Or by e-mail to the Assessments 24X7 LLC Privacy Office
[email protected]

CHANGES TO THIS SAFE HARBOR PRIVACY POLICY

This Policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. A notice will be posted on the A24X7 web page (www.assessments24x7.com) for 60 days whenever this Safe Harbor Privacy Policy is changed in a material way.