Safe Harbor Privacy Statement

This Safe Harbor Privacy Statement (“Safe Harbor Privacy Statement“) covers personally identifiable data that is subject to the European Union Data Protection Directive (“Personal Data“). This Safe Harbor Privacy Statement applies to PlumChoice, Inc. (referred to hereafter as the “Company,” “we,” “us,” “our“) and covers our web site located at www.plumchoice.com (the “Site“). The Company has developed this Safe Harbor Privacy Statement to explain how the Company complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework (such frameworks are collectively referred to as the “Safe Harbor Frameworks“).

Background

The Safe Harbor Frameworks were established in 2000 by the United States Department of Commerce, the European Commission and Switzerland, as a method for transferring personal information from the European Union and Switzerland (the “Covered Countries“), to companies in the United States. The program is a voluntary self-certification process for companies operating in the United States. Companies that certify represent that they are upholding privacy standards for personal information received from the Covered Countries that have been jointly accepted by the EU Commission and the US Department of Commerce and Switzerland and the US Department of Commerce. The Company has certified to the applicable safe harbor programs and has developed this Safe Harbor Privacy Statement to describe its commitment to the Safe Harbor Framework.

Scope

This Safe Harbor Privacy Statement applies to all Personal Data received by the Company in the United States from the Covered Countries in any format including electronic or paper-based Personal Data.

Notice

When the Company collects Personal Data directly from individuals in the Covered Countries, the Company informs them about the purposes for which it collects and uses their Personal Data. The Company informs such users about the purposes for which it collects and uses their Personal Data, the types of non-agent third parties, if any, to which the Company discloses the Personal Data, and the choices and means, if any, that the Company offers individuals for limiting the use and disclosure of their Personal Data. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Data to the Company, or as soon as practicable thereafter, and in any event before the Company uses the Personal Data for a purpose other than that for which it was originally collected. With respect to Personal Data that is collected through this Site, the Company provides notice through this Safe Harbor Privacy Statement and the Company’s Privacy Policy.

If the Company receives Personal Data from its subsidiaries, affiliates or other entities in the Covered Countries, the Company will use such Personal Data in accordance with the notices such entities provided and the choices made by the individuals to whom such Personal Data relates.

Choice

We respect your right to privacy and do not want to send marketing materials to you if you choose not to receive them. Please let us know if you do not wish to receive future mailings from the Company by contacting us as indicated below.

Onward Transfer

The Company may disclose Personal Data to business partners and subcontractors as necessary in connection with the performance of requested services or solutions, or as otherwise appropriate in connection with a legitimate business need. The Company may also disclose Personal Data as necessary in connection with the sale or transfer of all or part of its business. In these situations, the Company will require the recipient of the data to protect the data in accordance with the relevant principles in the Safe Harbor or otherwise take steps to ensure that the Personal Data is appropriately protected. The Company may also disclose Personal Data as required or permitted by law, or when the Company believes that disclosure is necessary to protect its rights and/or to comply with a judicial proceeding, a court order, a law enforcement request, or other legal process

Security

We are committed to securing all Personal Data provided to us. We have deployed process and technology measures to provide reasonable assurance that your Personal Data is secured against unauthorized use, loss or disclosure.

Data Integrity

The Company will take reasonable steps to ensure that Personal Data is accurate and we will employ controls to meet this requirement. If you become aware that Personal Data that we maintain about you is inaccurate or if you would like to update any of your Personal Data please let us know by contacting us as indicated below.

Access

You may contact us to inquire about your personal information maintained by the Company by sending us e-mail at help@plumchoice.com.

Enforcement

We have deployed internal processes to monitor our compliance with the Safe Harbor Frameworks and to address all questions or complaints. We encourage you to raise any concerns or complaints directly with us by contacting us at help@plumchoice.com.

Dispute Resolution

If you have questions or concerns regarding this Safe Harbor Privacy Statement, you should first contact the Company, as indicted below under “Contacting Us.” If you do not receive acknowledgement of your inquiry or your inquiry has not been satisfactorily addressed, you should contact the International Centre for Dispute Resolution, a Division of the American Arbitration Association, Case Filing Services, 1101 Laurel Oak Road, Suite 100, Voorhees, NJ 08043 Phone: 856-435-6401; Email box: casefiling@adr.org. All disputes will be conducted in the English language.

Changes

This version of this Safe Harbor Privacy Statement was last updated in November 2011. This Safe Harbor Privacy Statement may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. The Company will provide appropriate public notice about such modifications.

Contacting Us

If you have any questions about this Safe Harbor Privacy Statement, please email us at help@plumchoice.com. Please include your name, address and email address in all communications and state clearly the nature of your request.

In addition, for further information about the U.S.-E.U. Safe Harbor Framework, consult the Department of Commerce’s web site at: http://www.export.gov/safeharbor.