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Privacy and Security Policy

The following represents the Privacy and Security policies of TraceLink Inc.

TRACELINK PRIVACY AND SECURITY POLICY

1. GENERAL

TraceLink, Inc. (“TraceLink”) respects your online privacy and security and protects information that you decide to share with us, in an appropriate and reasonable manner. Your privacy and the protection of data is our top concern and we have established and comply with the principles set forth in this TraceLink Privacy and Security Policy in order to protect your privacy and your data. TraceLink does not list all of the details of the TraceLink infrastructure for security reasons, but we believe that TraceLink’s privacy and security policies, practices, procedures and infrastructure are industry standard, proven and reliable.

Your access to, license and use of TraceLink’s web-based Services (the “Services”) is strictly conditioned upon your agreement with and consent to the terms and conditions of the TraceLink Privacy and Security Policy, as it may be amended and/or updated from time to time by TraceLink. In the event of any material change or modification by TraceLink to the TraceLink Privacy and Security Policy, TraceLink will notify you here. You also agree to comply with all of the terms and conditions of the TraceLink Terms of Use Agreement.

2. CONTACT INFORMATION

Please direct all inquiries, questions or comments with respect to this TraceLink Privacy and Security Policy to TraceLink at the email addresses set forth below. TraceLink will use commercially reasonable efforts to respond to your inquiries, questions or comments within three (3) business days of their receipt.

Email Address: notices@tracelink.com

3. REGISTRATION

In order to become a TraceLink designated Subscriber and/or a TraceLink designated Member with respect to the TraceLink Services, you must comply with TraceLink’s then current registration policies and procedures and create an account on our website. To create an account, you are required to provide certain information to TraceLink, which you recognize and expressly acknowledge, is personal information allowing others, including TraceLink, to identify you. TraceLink will not sell or market any personal information that you provide to us.

4. SERVICES

TraceLink may collect information in order to, among other things, accurately categorize and respond to a Subscriber’s and/or Member’s inquiry and deliver appropriate Services levels.

5. CONTENTS OF YOUR ACCOUNT

TraceLink stores and maintains certain forms and contents stored in your account. Use of TraceLink’s Services signifies your consent to any transfer of such contents outside of your country. In order to prevent loss of data due to errors or system failures, we also keep backup copies of data including the contents of your account and such contents may remain on our Services even after deletion or termination of your account.

6. VISITOR DETAILS

We may use the Internet Protocol address, browser type, browser language, referring URL, files accessed, errors generated, time zone, operating system and other visitor details collected in our log files to analyze the trends, administer the website, track visitor's movements and to improve our website.

7. COOKIES

We may use session and/or persistent cookies with respect to the TraceLink Services. We may also, from time to time, retain an independent third party to perform an analysis of the statistical and aggregate data and other information with respect to our Services. Such aggregated information is not personally identifiable and is used to improve the functionality and/or use of our Services and future product offerings. Such third parties may, at their option, employ the use of cookies in the provision of their third party services. TraceLink does not have access to these third party cookies nor are we responsible for them.

8. YOUR OBLIGATIONS

You have certain obligations imposed by applicable law or regulations or by the TraceLink Terms of Use Agreement. You must, at all times, respect the terms and conditions of this TraceLink Privacy and Security Policy, including but not limited to any intellectual property rights, which may belong to third parties. You must not disseminate, distribute and/or download any information which may be deemed to be injurious, offensive, violent or racist. Any violation of these obligations and guidelines in the TraceLink Terms of Use Agreement or in the TraceLink Privacy and Security Policy may lead to the termination or suspension of your access to or license of the Services by TraceLink, at its sole option.

9. CHILDREN'S ONLINE PRIVACY PROTECTION

Children are not eligible to use TraceLink’s Services. Minors should not submit any personal information to TraceLink and/or use the TraceLink Services. TraceLink does not knowingly collect personal information from minors who are under 18 years of age.

10. LEGAL DISCLAIMER

IT IS POSSIBLE THAT WE MAY NEED TO DISCLOSE PERSONAL INFORMATION WHEN REQUIRED BY LAW, SUCH AS RESPONSES TO CIVIL OR CRIMINAL SUBPOENAS, OR OTHER REQUESTS BY LAW ENFORCEMENT PERSONNEL. WE WILL DISCLOSE SUCH INFORMATION IN THE EVENT THAT WE HAVE A GOOD-FAITH AND REASONABLE BELIEF THAT IT IS NECESSARY TO COMPLY WITH A COURT ORDER, JUDICIAL PROCEEDING, SUBPOENA, OR OTHER LEGAL PROCESS OR REQUEST TO TRACELINK BROUGHT IN ANY COUNTRY THROUGHOUT THE WORLD, OR TO EXERCISE OUR LEGAL RIGHTS OR DEFEND AGAINST LEGAL CLAIMS.

11. FORUMS/CHATS/BLOGS/DIRECTORY

If you choose to use a bulletin board or directory, import a blog, or participate in a chat room, you should be aware that any personally identifiable information you choose to provide there can be read, collected and/or used by other parties and that such personally identifiable information could be used to send you unsolicited messages.

TRACELINK IS NOT RESPONSIBLE FOR ANY PERSONALLY IDENTIFIABLE INFORMATION THAT YOU CHOOSE TO SUBMIT WITH RESPECT TO THESE FORUMS.

12. SURVEYS AND POLLS

As a Subscriber or Member with respect to TraceLink Services, you may receive requests from time to time to participate in market research, including but not limited to certain polls and surveys which may be submitted by other TraceLink Subscribers or Members. If you decide to participate in such surveys or polls, you acknowledge that you are responsible for the provision of any and all of your personal and/or other information in response to such poll or survey.

13. ACCESSING AND CHANGING YOUR ACCOUNT INFORMATION

You can review the personal information that you have provided to us and make any desired changes to such information by logging in to your account on the TraceLink website. Please be aware that even after we have processed your request for such a change, TraceLink may retain certain residual information in the backup and/or archival copies of TraceLink’s database.

14. CLOSING YOUR ACCOUNT

In the event you close your TraceLink account, we will remove your name and other personally identifiable information. TraceLink may retain certain data contributed or provided by you if we reasonably believe that it may be necessary to prevent fraud or abuse; it is retained for legitimate business purposes (such as analysis of aggregated, non-personally identifiable data for account recovery purposes); or, if it is required by law.

15. LINKS FROM TRACELINK WEBSITE

Certain pages of our website may, from time to time, contain external links. You should verify and validate any and all privacy practices of other websites. We encourage you not to provide personal information, without first assuring yourself of the privacy policies of such other websites.

TRACELINK IS NOT RESPONSIBLE IN ANY WAY FOR ANY USE AND/OR MISUSE OF ANY PERSONAL INFORMATION OR OTHER INFORMATION PROVIDED BY YOU AT SUCH OTHER WEBSITES.

16. ANONYMOUS DATA

TraceLink may accumulate and aggregate certain anonymous statistical and related data in order to improve the performance and functionality of its Services, to develop new products and/or Services or to analyze the usage of TraceLink’s Services. TraceLink may use aggregated anonymous data for such purposes as TraceLink, in its sole discretion, deems to be appropriate.

17. SECURITY

Access to personal information and/or your data at TraceLink is password-protected and PCI compliant. TraceLink will use a credit card processing company with respect to the billing of Services fees and such third parties may use such personally identifiable information solely to provide such billing services. TraceLink also audits its system, from time to time, for possible vulnerabilities. It is your responsibility to protect the security of any of your login information. Emails, instant messaging and other similar methods of communication may not be encrypted, and we urge you not to use these means or methodologies for the communication of any confidential information.

18. TRACELINK EMPLOYEES

TraceLink's employees have years of experience in managing and assessing security and data protection risk. Only TraceLink employees with the highest level of clearance have access to our datacenter and the data contained therein. TraceLink limits access to customer data to only a designated number of its employees with a legitimate need to access such data in order to provide technical, support and other important services for TraceLink’s customers. TraceLink, on a continuing basis, reviews its then current security policies and develops new policies and/or procedures with respect to management, knowledge sharing, escalation procedures and day-to-day operations. TraceLink routinely and regularly audits its security policies and procedures and those same policies and procedures are regularly reviewed by TraceLink executive management. Any access to customer data is solely on an as needed basis by authorized TraceLink employees or by TraceLink senior management employees in order to provide and perform maintenance and/or support services for our customers, and in order to maintain or improve the quality of our Services.

19. TRACELINK NETWORK SECURITY

TraceLink’s network security system and infrastructure helps to protect our customers’ data against sophisticated attacks. All TraceLink Services are protected and screened by intrusion detection systems. Access to the TraceLink network is tightly and comprehensively controlled and strictly audited by appropriate TraceLink personnel. Communications between a customer’s computer and TraceLink’s servers is encrypted and TraceLink applications operate in a secure operating system that TraceLink believes minimizes vulnerabilities.

20. REDUNDANCY

In a cloud computing environment, certain computer resources may at some point fail to operate – TraceLink has designed its infrastructure in light of that potential failure. The core cloud computing infrastructure provides redundancy and high availability at every level, from multiple Tier-1 ISP connections, redundant networking equipment, and servers. TraceLink's Services are built on this infrastructure with the ability to quickly add or change service capacity in response to customer load or in uncommon situation where a compute infrastructure experiences a failure. TraceLink monitors each of its Services critical performance metrics to track availability and performance. Finally, TraceLink periodically backs up appropriate data across multiple servers so as to protect that same data in the event of a service failure.

21. PHYSICAL SECURITY

TraceLink Services are hosted in secure, SAS70 Type II certified facilities that are protected from physical attacks and from natural disasters. Such datacenters are monitored on a 7x24 basis and entrance to the datacenters is controlled and restricted to a select group of authorized personnel. Multiple forms of authentication must be used in order to enter any such datacenter and the datacenters are guarded and protected 7 days a week, 24 hours a day.

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