Employee Insights Safe Harbor Privacy Statement

Introduction

Employee Insights and its affiliates are engaged in the development and administration of organizational surveys. These surveys may entail the collection and analysis of personal data provided by users of the system (e.g., email address, first and last name, address, country, other contact information, and answers to various questions). These data are available to Employee Insights, its affiliates, and its clients in that they can support workforce decisions and understanding (e.g., to understand employee attitudes in different parts of the organization, why people are leaving the organization, what people value about working at a particular organization), or when applicable, relay the information to their clients. Employee Insights and its affiliates may also transmit such personal data across international boundaries when it becomes necessary.

Employee Insights and its affiliates respect individual privacy and value the confidence of clients, employees, vendors, business partners and others. Employee Insights and its affiliates strive to collect, use and disclose personal data (as outlined above) in a manner consistent with the laws of the countries in which it does business and has a tradition of upholding the highest ethical standards in its business practices. Employee Insights and its affiliates adhere to the Safe Harbor Principles developed by the U.S. Department of Commerce and the European Commission on July 21, 2000. This Safe Harbor Policy (the "Policy") sets forth the privacy principles that Employee Insights and its affiliates follow with respect to transfers of personal information anywhere in the world, including transfers from the European Economic Area (EEA) to the United States.

I. Notice

Employee Insights and its affiliates may collect personal data. The personal data that we collect or receive regarding survey participants may include: first and last name, age, gender, ethnicity, and email address. For candidate verification and identification purposes, we may collect all or part of a government-issued or employee identification number. Employee Insights and its affiliates do not require participants to provide sensitive information, as defined by Safe Harbor, in connection with processing participant data and delivering its customer services.

II. Choice

Employee Insights and its affiliates will offer individuals the opportunity to choose (opt out) whether their personal information is (1) to be disclosed to a third party or (2) 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, Employee Insights and its affiliates will give individuals the opportunity to affirmatively or explicitly (opt out) consent to the disclosure of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

III. Onward Transfer (Transfers to Third Parties)

Employee Insights and its affiliates may transfer personal information to our clients. By completing the survey process, you give your consent for your personal information to be transmitted to our clients. Our clients require this personal data so that (a) surveys can be correctly administered; and (b) surveys can be processed and administered; and (c) our clients receive accurate transmission of your survey records. Employee Insights and its affiliates shall ensure that any third party for which personal information may be disclosed subscribes to the principles of Safe Harbor or are subject to law providing the same level of privacy protection as is required by the principles of Safe Harbor and agree in writing to provide an adequate level of privacy protection.

IV. Access to Data

Employee Insights and its affiliates will not provide results to individuals taking the surveys. The dissemination of results is the sole responsibility of the requesting organization. Individuals taking the surveys are not guaranteed access to their individual results.

Employee Insights and its affiliates shall allow an individual access to their personal information and allow the individual to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated. To protect your privacy and security, we will take reasonable steps to verify your identity before amending any of your personal information in our databases.

V. Security

Employee Insights and its affiliates have taken reasonable precautions to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction. While we have implemented security precautions (e.g., password protected databases, encryption of all data transmitted over the internet, secure internet connections) to protect the privacy of client, applicant, and employee data, Employee Insights and its affiliates make no representations or warranties that these precautions will prevent any and all security or confidentiality breaches.

VI. Data Integrity

Employee Insights and its affiliates shall only process personal information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, Employee Insights and its affiliates shall take reasonable steps to ensure that personal information is accurate, complete, current and reliable for its intended use.

VII. Enforcement

Should you have any questions or concerns about this privacy policy or how we have handled personal information, please contact us at privacy@eeinsights.com. If we are unable to satisfactorily address your concerns or if a dispute arises, Employee Insights and its affiliates will cooperate with the EU Data Protection Authorities and the Department of Commerce to resolve any complaints and disputes arising in connection with its privacy policy. The EU Data Protection Authorities may be reached through the United States Council of International Business at 212-354-4480.

Changes to the Privacy Policy

Employee Insights and its affiliates reserve the right to amend the terms of this privacy policy from time to time consistent with the requirements of the Safe Harbor. We encourage you to review this privacy policy periodically for any changes for updates.