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Safe Harbor Notice

Zift Solutions Safe Harbor Notice

Scope of Safe Harbor Certification

Zift Solutions Incorporated and all its wholly-owned U.S. subsidiaries (“Zift,” “Zift Solutions” orĀ “we”) recognizes that the European Community and Switzerland have established a data protection regime pursuant to Directive 95/46/EC, which applies to the European Economic Area (“EEA”) and Switzerland and restricts companies in the EEA or Switzerland in transferring personal data about individuals in the EEA or Switzerland to the United States, unless there is “adequate protection” for such personal data when it is received in the United States. To create such “adequate protection,” we adhere to the Safe Harbor Privacy Principles published by US Department of Commerce (“Safe Harbor Principles”) with respect to personal data about individuals in the EEA or Switzerland that we receive from our customers and other business partners. Zift Solutions adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. Our Safe Harbor Certification does not extend to data that we receive directly through Zift’s publicly accessible websites (any of our websites such as www.ziftsolutions.com that can be accessed without a password). More information on the Safe Harbor Principles and Zift’s scope of participation is available at http://export.gov/safeharbor.

Scope of this Notice

This Notice addresses data subjects residing in the EEA (“EEA Persons”) or Switzerland whose data we may receive from one of our customers, suppliers or other business partners in the EEA or Switzerland e.g., referral partners, integration partners, etc.

Categories of EEA Data

We sell integrated web-based business application software largely to small and midsize businesses. We receive mostly business-related information from the EEA and Switzerland, including contact information of individual representatives of the businesses with whom we are dealing, including, without limitation, names, addresses, work phone numbers, work email addresses, etc. of EEA or Swiss Persons (“EEA Data”). In connection with some services, e.g., Zift’s Content Syndication services, our customers use our hosted technology platform to store and process EEA or Swiss Data at their own discretion. Since EEA and Swiss Data covered by this Notice is by definition sent to us by another company in the EEA or Switzerland (e.g., a customer of Zift), the categories of data sent and the purposes of processing often depend on such other company, with whom the EEA or Swiss Persons typically have a closer employment or business relationship (and which, therefore, can provide additional information on categories of data shared with us).

Purposes

We collect and use EEA and Swiss Data for purposes of providing products and services to our customers, communicating with corporate business partners about business matters, processing EEA and Swiss Data on behalf of corporate customers, providing information on our services, and conducting related tasks for legitimate business purposes.

Disclosure

We share EEA and Swiss Data with our affiliates and contractors, who process EEA and Swiss Data on behalf of Zift. We also share EEA and Swiss Data with other third parties for the purposes for which we receive the EEA and Swiss Data (e.g., performance of contractual obligations and rights), and we may also disclose EEA and Swiss Data where we are legally required to disclose (e.g., under statutes, contracts or otherwise) or the disclosure is permitted by law or the Safe Harbor Principles and we have a legitimate business interest in such disclosure.

With respect to marketing emails, EEA and Swiss Persons may opt-out of receiving further email marketing communications from Zift by sending an email to info (at) ziftsolutions.com, or by following opt-out instructions that are contained in each marketing email. EEA and Swiss Persons may also send an email to this address to ask to opt-out of disclosures to third parties, but such a limitation on data sharing may make it difficult or impossible for us to provide the requested services.

Access and Review

If you are an EEA or Swiss Person about whom we hold EEA or Swiss Data, you may request access to, and the opportunity to update, correct or delete, such EEA or Swiss Data. To submit such requests or raise any other questions, please contact the business that provided your EEA or Swiss Data to us. You can also contact our Safe Harbor Contact. We reserve the right to take appropriate steps to authenticate an applicant’s identity, to charge an adequate fee before providing access and to deny requests, except as required by the Safe Harbor Principles.

Safe Harbor Contact

In compliance with the US-EU and US-Swiss Safe Harbor Principles, Zift Solutions commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss citizens with inquiries or complaints regarding this privacy policy should first contact the Zift Solutions team at legal (at) ziftsolutions.com

Zift Solutions has further committed to refer unresolved privacy complaints under the US-EU and US-Swiss Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Zift Solutions, please visit the BBB EU SAFE HARBOR web site at www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.

Safe Harbor Statement Effective Date: 9/1/2013