PRIVACY POLICY
This document describes Igenti, Inc.'s policy regarding information received with regard to visitors to our Web site, or the web site of applications that we manage, or the email address and other information provided to us either directly or through one of our clients, and other client data managed by Igenti.

IGENTI’S BUSINESS:
Igenti is a software developer and application service provider in the business of managing databases of contacts for clients and sending information to those contacts as requested by the client. The contact information typically includes name, address, email address, and information submitted on application forms for job opportunities and related data. The contact information we gather is typically provided by clients or visitors to the web applications that we manage. Accordingly, we only maintain the contact and other information for individuals that have requested to be included in the databases we manage.

SAFE HARBOR:
The United States Department of Commerce and the European Commission (“EC”) have agreed on a set of data protection principles (the "Safe Harbor Principles") to enable US companies to satisfy the requirement under European Union (“EU”) law that adequate protection be given to Personal Information transferred from the EU to the United States. The EC also has recognized the Safe Harbor Principles as providing adequate data protection. This Safe Harbor Privacy Policy (the "Policy") sets forth the privacy principles that Igenti follows with respect to transfers of Personal Information anywhere in the world, including transfers from the European Economic Area (EEA) (which includes the twenty-five member states of the European Union (EU) plus Iceland, Liechtenstein and Norway) to the United States. Information regarding the Safe Harbor Program can be found at the program’s website: http://export.gov/safeharbor.

Consistent with its commitment to protect personal privacy, Igenti abides by and adheres to the Safe Harbor Principles and educates its employees concerning compliance with this Policy and has self-assessment procedures in place to assure compliance.

NORMAL WEB SITE USAGE:
You can visit Igenti's Web site to read product information or use our online tools without telling us who you are and without revealing any personal information. The only information we collect and store during normal Web site usage is the name of the Web site that referred you to us, the pages you request, and the date and time of those requests. We use this information to generate statistics and measure site activity to improve the usefulness of customer visits. During normal Web site usage, we do not collect or store personally identifiable information such as name, mailing address, e-mail address, phone number or Social Security Number.

COLLECTION OF PERSONALLY IDENTIFIABLE INFORMATION:
There are instances where Igenti requests personally identifiable information from a Web site visitor or a visitor to the place of business or website of one of our clients. The requested information (i.e. name, mailing address, e-mail address, etc.) is collected for the purpose of providing you with correspondence such as newsletters, special offers, etc. and is stored in a manner appropriate to the nature of the data. It is used to fulfill your request to receive correspondence. We also collect information on application forms in systems that we manage for clients. The information you provide is never sold, leased, rented, or otherwise provided to any other company.

ELECTRONIC MAIL SENT TO US THAT CONTAINS PERSONAL INFORMATION:
Internet users may decide to send Igenti personally identifying information, for example, in a message containing comments about the Igenti Web site. Igenti will only use this information to identify the user. We will not use this information other than to resolve the matter identified in the e-mail.

By using this site, you are agreeing to the terms of our Privacy Policy. We reserve the right to change our Privacy Policy. A revised Privacy Policy will only apply to data collected subsequent to its effective date. Any revisions will be posted at least 10 days prior to its effective date. Your continued use of this site following the posting of changes to these terms will mean that you accept these changes.

If you are under the age of 16, please do not submit or post any personal information.

Initial Effective date: July 1, 2007
Last Amended: July 20, 2011