SAMPLE PRIVACY POLICY 1. Purpose. Your privacy is important to us and we have prepared this Privacy Policy to explain how HOST NAME, Inc. (â??HOST NAMEâ??, â??weâ?? or â??usâ??) collects, uses and shares information we obtain from you when you participate in an online Community that HOST NAME conducts on behalf of its corporate clients (each a â??HOST NAME Clientâ??) through a HOST NAME-hosted web site (the â??Siteâ??). Your use of the Site may be subject to the HOST NAME Clientâ??s Terms and Conditions of Use. Because the Internet is global, information about you that we collect or that you submit may be transferred to, processed in, and held in countries (including the United States of America) other than the one in which you reside. By using the Site, you explicitly consent to such use of your information and agree to the terms of this Privacy Policy. This Privacy Policy is effective as of April 1, 2008. This Privacy Policy was last updated on April 1, 2008. 2. HOST NAME Client Privacy Policy. Please note that this Privacy Policy only governs HOST NAMEâ??s use of your User Information (as defined below). The HOST NAME Clientâ??s use of your User Information is governed by the HOST NAME Clientâ??s own privacy practices and you should review the HOST NAME Clientâ??s Privacy Policy to understand its privacy practices. We are not responsible for the HOST NAME Clientâ??s privacy practices, or for any information contained on any web site (including the HOST NAME Clientâ??s web site) that may be accessed from the Site. 3. Information We Automatically Collect. We automatically collect certain information from you when you visit the Site to help us understand how you use the Site (which we will refer to in this Privacy Policy collectively as â??Usage Dataâ??). For example, each time you visit the Site we may automatically collect your IP address, browser and computer type, access time, the web page from which you came, and the web page(s) that you access during your visit. We also use cookies (which are small amounts of data sent from a web server to your browser that are stored on your computerâ??s hard drive) to keep track of your use of the Site, to validate your identity, to remember your password and preferences, to tailor the Site to meet your personal interests, and to improve the quality of the Site. We do not link the information we store in cookies to any Personal Information (as defined below) that you provide to us through the Site. Generally, you can set your browser not to accept cookies or to notify you if you are sent a cookie, giving you the opportunity to choose whether or not to accept the cookie. Please note that if you do set your browser not to accept cookies, certain areas of the Site may not function properly. 4. Personal Information. You must register with HOST NAME to use the Site. As part of the registration process, you will be asked to provide certain information by which (either alone or in combination with other information provided by you) someone could personally identify you (which we will refer to in this Privacy Policy collectively as â??Personal Informationâ??), including for example, your first and last names, your home address, your email address, your date of birth, etc. Each HOST NAME Client identifies the Personal Information that it wishes HOST NAME to obtain from you on its behalf. We only collect your Personal Information for the purposes of managing and monitoring your account and passing such Personal Information to the relevant HOST NAME Client on whose behalf we have collected it. Each HOST NAME Clientâ??s use of your Personal Information will be governed their Privacy Policy as set forth above. 5. Sensitive Personal Information. If we ask you to provide sensitive Personal Information (i.e. information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information regarding your sex life), we will require that you affirmatively agree (opt-in) to provide such information, before we collect it from you. You are not required to provide such sensitive Personal Information if you do not wish to do so. 6. Our Information Sharing Practices. (a) Generally. Except as otherwise described in this section of our Privacy Policy, we will never share your Usage Data or Personal Information (which we will refer to in this Privacy Policy collectively as â??User Informationâ??) with any third party without your permission. (b) HOST NAME Client. We provide some or all of your User Information to the particular HOST NAME Client on whose behalf we have collected your User Information through the Site, and such HOST NAME Client may contact you regarding goods or services in which you may be interested. We will not share your User Information with any other HOST NAME Client. (c) Aggregated Data. We collect and use aggregated User Information in respect of users who use the Site for the purpose of enhancing usersâ?? experiences using HOST NAMEâ??s service, and providing feedback to HOST NAME Clients. From time to time, we may share aggregated User Information with third parties. However, we will not share any aggregated User Information in any manner that would enable the recipient to personally identify you. (d) Service Providers. From time to time, we may enter into relationships with third parties who provide services to us (e.g., we outsource a portion of our electronic mailing to a third party). In those circumstances, we only disclose User Information that is necessary for such service providers to perform those services on our behalf, and we require that they maintain the confidentiality of such User Information. (e) Other Disclosure Scenarios. Notwithstanding anything in this Privacy Policy to the contrary, we reserve the right, and you hereby expressly authorize us, to share any User Information: (1) in response to subpoenas, court orders, or legal process, or to establish, protect, or exercise our legal rights or defend against legal claims; (2) if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the safety of any person or property; (3) if we believe it is necessary to investigate, prevent, or take action regarding significant abuse of the Siteâ??s infrastructure or the Internet in general (such as voluminous spamming, denial of service attacks, or attempts to compromise the security of information); (4) to our parent company, subsidiaries, joint ventures, or other companies under common control with us (in which case we will require such entities to honor this Privacy Policy); and (5) if we are acquired by or merge with another entity. 7. Public Information. If you identify any User Information as public, you are authorizing us to share such information publicly. Also, there may be areas of the Site (e.g., message boards, discussion rooms, and other online forums) in which you are able to post information that will be available to all other users of the Site. By choosing to use these areas, you understand and agree that anyone may access, use, and disclose any information that you post to those areas. 8. Modifying and Deleting Your Personal Information. If you would like to modify or delete from our database, any Personal Information stored in your profile, or if you would like to delete your profile completely, you can do so as follows: log into the HOST NAME Client online Community and proceed to the â??My Accountâ?? section where you have the ability to edit your information or close your account. We will implement these changes within ten (10) calendar days. Please note that any Personal Information that we have copied may remain in back-up storage for some period of time after your request. We will also be unable to recover any Personal Information from any HOST NAME Client once it has been transferred to such client. Also, please note that we will maintain all User Information in our database whenever we are required to do so by law. We only retain your User Information during the term of the particular project that we are conducting on behalf of the relevant HOST NAME Client, and for a period of sixty (60) calendar days after the termination of such project. 9. Security. We have implemented reasonable measures to help protect your User Information from loss, misuse, or unauthorized access or disclosure. Unfortunately, however, no data transmission over the Internet can be guaranteed to be one hundred percent secure. As a result, while we strive to protect your User Information, we cannot guarantee its security. 10. Childrenâ??s Privacy. We are committed to protecting the privacy needs of children and we encourage parents and guardians to take an active role in their childrenâ??s online activities and interests. The Site is not intended for and may not be used by children under the age of 13. We do not knowingly collect information from children under the age of 13 and we do not target the Site to children under the age of 13. 11. Changes. We may update this Privacy Policy from time to time. If under any such update we make any material change to the way in which we treat your User Information, we will inform you by posting a notice on relevant areas of the Site. Any updated version of this Privacy Policy will be effective as of the date set forth therein. 12. Safe Harbor Program. HOST NAME participates in the Safe Harbor Program developed by the European Union Commission and the United States Department of Commerce regarding the collection, use, and retention of data from the European Union. Accordingly, we have certified that we adhere to the Safe Harbor Privacy Principles. If you have any questions or concerns regarding our compliance with the Safe Harbor Program, please contact us as indicated below. For more information about the Safe Harbor Program and to view our Safe Harbor Program compliance certification, please visit the U.S. Department of Commerce's Safe Harbor Program web site. As part of our participation in the Safe Harbor Program, we have agreed to use the Direct Marketing Association (DMA) dispute resolution for disputes relating to our compliance with the Safe Harbor Program. If you have any complaints regarding our compliance with the Safe Harbor Program you should first contact us as set forth below. If contacting us does not resolve your complaint, you may raise your complaint with DMA through email at safeharbor@the-dma.org, by phone at (202)861-2410, by fax at (202)955-0085, or by mail at Safe Harbor Line, Direct Marketing Association, 1615 L Street, NW - Suite 1100, Washington, DC 20036, USA. DMA will then serve as a liaison with us to resolve your concerns. 14. Non-Solicited Communications. Except to the extent otherwise required to comply with the Safe Harbor Program, this Privacy Policy does not govern our use of any information you provide to us when you call us, write to us, or communicate with us in any manner other than through the Site. 15. Questions. If you have any questions about this Privacy Policy, please feel free to contact us as follows: HOST NAME, Inc. Address Tel: