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CONFLUO SAFE HARBOR PRIVACY POLICY
Confluo is committed to uploading the highest ethical standards in its business practices and strives to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business. Confluo 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. Confluo 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 Confluo’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 (the “U.S.-EU Safe Harbor Principles”) and frequently asked questions (collectively the “U.S.-EU Safe Harbor Framework”) to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EU to the United States. The EEA also has recognized the U.S. Safe Harbor as providing adequate data protection. The United States Department of Commerce and the Federal Data Protection and Information Commissioner of Switzerland have agreed on a similar set of data protection principles (the “U.S.-Swiss Safe Harbor Principles”) and frequently asked questions (collectively the “U.S.-Swiss Safe Harbor Framework) 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. Consistent with its commitment to protect personal privacy, Confluo adheres to the U.S.-EU and U.S.-Swiss Safe Harbor Principles (hereinafter “Safe Harbor Principles”).

DEFINITIONS:
“Personal information” means any information or set of information that identifies or is used by or on behalf of Confluo 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, or trade union membership, or that concerns health or sex life. In addition, Confluo 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 are based on the Safe Harbor Principles. NOTICE: Where Confluo 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 and the choices and means, if any, Confluo offers individuals for limiting the use and disclosure of their personal information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to Confluo, or as soon as practicable thereafter, and in any event before Confluo uses or discloses the information for a purpose other than that for which it was originally collected or disclosed information to a non-agent third party.

CHOICE: For personal information, Confluo will offer individuals the opportunity to choose (opt-in) 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, Confluo 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 authorised by the individual. Confluo will provide individuals with reasonable mechanisms to exercise their choices.

DATA INTEGRITY: Confluo will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Confluo will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current. We will only collect and store personal information that is relevant to fulfill the purpose of the request and will retain such information no longer than appropriate to fulfill the purpose of the request. TRANSFERS TO AGENTS: Confluo will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent 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), Safe Harbor certification by the agent, or being subject to another European Commission adequacy finding (e.g., companies located in Canada). Where Confluo has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, Confluo will take reasonable steps to prevent or stop the use or disclosure.

ACCESS AND CORRECTION: Upon request, Confluo will grant individuals reasonable access to personal information that it holds about them. In addition, Confluo will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. SECURITY: Confluo will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. ENFORCEMENT: Confluo uses a self-assessment approach to maintain compliance with this privacy policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with these Principles. We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Information in accordance with the Principles.

DISPUTE RESOLUTION
Any questions or concerns regarding the use or disclosure of personal information should be directed to the Confluo Department of Ethics and Business Conduct at the address given below. Confluo 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. For complaints that cannot be resolved between Confluo and the complainant, Confluo has agreed to cooperate and comply with the EU Data Protection Authorities (DPAs) to investigate and resolve unresolved complaints pursuant to the safe harbor principles.

LIMITATIONS ON APPLICATIONS OF PRINCIPLES:
Adherence by Confluo to these Safe Harbor Principles may be limited (a) to the extent required or permitted by law or legal process, such as to respond to or investigate a legal or ethical obligation or request or pursuant to court orders, subpoenas, interrogatories or similar directive carrying the force of law; and (b) to the extent expressly permitted by an applicable law, rule or regulation. INTERNET PRIVACY:
Confluo sees the Internet and the use of other technologies as valuable tools for communicating and interacting with consumers. Confluo 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.

CONTACT INFORMATION:
Questions or comments regarding this Policy should be submitted to the Confluo Department of Ethics and Business Conduct by mail as follows:

Confluo Inc.
Department of Ethics and Business Conduct
115 Broadway, 12th Floor,
New York, NY 10006

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 Confluo web page (www.confluo.com) for 60 days whenever this Safe Harbor Privacy Policy is changed in a material way.