eTrigue Corporation Safe Harbor Privacy Policy

eTrigue Corp. respects individual privacy and values the confidence of its customers, employees, consumers, business partners and others. Not only does eTrigue strive to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business, it also has a tradition of upholding the highest ethical standards in its business practices. This Safe Harbor Privacy Policy (the “Policy”) sets forth the privacy principles that eTrigue Corp. follows with respect to transfers of personal information from the European Economic Area (EEA) (which includes the twenty-seven member states of the European Union (EU) plus Iceland, Liechtenstein and Norway) and from Switzerland to the United States.

Compliance with both U.S. - EU Safe Harbor Framework & U.S. - Swiss Safe Harbor Framework

The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions (the "Safe Harbor Principles") to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EU to the United States. The EEA also has recognized the U.S. Safe Harbor as providing adequate data protection (OJ L 45, 15.2.2001, p. 47). Consistent with its commitment to protect personal privacy eTrigue Corporation adheres to the Safe Harbor Principles.

Certified Compliance with EU Safe Harbor Principles & Scope of Safe Harbor Certification

eTrigue Corp. ("eTrigue" or "we") recognizes that the European Community has established a data protection regime pursuant to Directive 95/46/EC, which applies to the European Economic Area ("EEA") and restricts companies in the EEA in transferring personal data about individuals in the EEA 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," eTrigue Corp adheres 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 that we receive from our customers and other business partners. eTrigue’s Safe Harbor Certification also extends to data that we receive directly through eTrigue's publicly accessible websites via secure form submission (any of our websites such as www.eTrigue.com). More information on the Safe Harbor Principles and eTrigue's scope of participation in both the U.S. – EU Safe Harbor Framework and the U.S. – Swiss Safe Harbor Framework is available at http://export.gov/safeharbor/eg_main_018236.asp.

Adherence to Seven Safe Harbor Principles

Client Personal Data processed or stored by eTrigue Corp. may be subject to contractual agreements with our clients that require more stringent privacy and security safeguards than the requirements in the Safe Harbor Agreement. At a minimum, however, eTrigue Corp. handles Client Personal Data in accordance with our Safe Harbor Privacy Policy, which is based upon the seven principles identified in the Safe Harbor Privacy Framework.

This Notice addresses data subjects residing in the EEA ("EEA Persons") whose data we may receive from one of our customers, suppliers or other business partners in the EEA e.g., referral partners, integration partners, etc. When eTrigue Corp. receives Client Personal Data for processing pursuant to instructions of clients or their partners, we are acting as an agent for our client and do not provide notice to individuals regarding the collection and use of their personal data. Our clients remain responsible for providing notice, if and to the extent they believe such notice is necessary under applicable EU law.

Business Purposes for the Collection and Use of Personal Data

eTrigue Corp. sells and maintains integrated web-based business application software largely to small, midsize and enterprise businesses. We receive mostly business-related information from the EEA, including contact information of individual representatives of the businesses with whom we or our customers are dealing, including, without limitation, names, addresses, work phone numbers, work email addresses, etc. of EEA Persons ("EEA Data"). In connection with some services, e.g., eTrigue's Lead Management services, our customers use our hosted technology platform to store and process EEA Data at their own discretion. As EEA Data covered by this Notice is by definition sent to us by another company in the EEA (e.g., a customer of eTrigue), the categories of data sent and the purposes of processing often depend on such other company, with whom the EEA Person typically has a closer employment or business relationship (and which, therefore, can provide additional information on categories of data shared with us). eTrigue Corp. will not use Client Personal Data for any other purposes than for the purposes that eTrigue Corp. clients provide such information.

eTrigue Corp. collects and uses EEA Data for purposes of providing products and services to our customers, communicating with corporate business partners about business matters, processing EEA Data on behalf of corporate customers, providing information on our/their services, and conducting related tasks for legitimate business purposes.

eTrigue Corp. does not transfer Client Personal Data to unrelated third parties, unless lawfully directed by a client, or in certain limited or exceptional circumstances in accordance with the Safe Harbor Privacy Framework. For example, such circumstances would include disclosures of Client Personal Data required by law or legal process, or disclosures made in the vital interest of an identifiable person such as those involving life, health or safety.

In the event that eTrigue Corp. is requested to transfer Client Personal Data to an unrelated third party, eTrigue Corp. will ensure that such party is either subject to the Safe Harbor Agreement, subject to similar laws providing an adequate and equivalent level of privacy protection, or will enter into a written agreement with the third party requiring them to provide protections consistent with the Safe Harbor Privacy Framework and eTrigue Corp.’s Safe Harbor Privacy Policy. Should eTrigue Corp. learn that an unrelated third party to which Personal Data has been transferred by eTrigue Corp. is using or disclosing Personal Data in a manner contrary to this Policy, eTrigue Corp. will take reasonable steps to prevent or stop the use or disclosure.

In the event that eTrigue is requested to transfer data to a client’s vendor(s) for additional processing, it will be at the direction of our client, making the vendor an agent of the client, and not an agent of eTrigue Corp. Accordingly, each time we send data in complying with such requests, we ensure a transmittal letter accompanies the data that reflects that the data is being provided “at the direction of [client name].”

Contact information and Client Personal Data is accessible only by those eTrigue Corp. employees and consultants who have a reasonable need to access such information in order for us to fulfill contractual, legal and professional obligations. All of our employees and consultants have entered into strict confidentiality agreements, and/or have been subjected to thorough criminal background checks requiring that they maintain the confidentiality of Client Personal Data.

Annual Assessment

eTrigue Corp. assures compliance with this Safe Harbor Privacy Policy and the Safe Harbor Privacy Framework by utilizing the self-assessment approach as specified by the U.S. Department of Commerce. The assessment is conducted on an annual basis to ensure that all of eTrigue Corp.’s relevant privacy practices are being followed in conformance with this Safe Harbor Privacy Policy and the Safe Harbor Privacy Framework. Any employee that eTrigue Corp. determines is in violation of these policies will be subject to discipline, up to and including termination of employment and/or criminal prosecution.

eTrigue Corp. also assures compliance with this Safe Harbor Privacy Policy and the Safe Harbor Privacy Framework by fully investigating and attempting to resolve any complaint or dispute regarding the use and disclosure of personal data in violation of this Privacy Policy.

For complaints that cannot be resolved by eTrigue Corp. and the complainant, eTrigue Corp. agrees to cooperate with data protection authorities located in the European Union (or their authorized representative) and participate in dispute resolution procedures of those authorities, pursuant to the Safe Harbor Privacy Framework.

With respect to emails, EEA Persons may opt-out of receiving further email communications from eTrigue or eTrigue clients by following opt-out instructions that are contained in the bottom of the email communication you received.

Safe Harbor Privacy Policy Updates

This Safe Harbor Privacy Policy may occasionally be updated. When material updates are made, the date of the last revision will be reflected at the end of the page. This page may be bookmarked to facilitate periodic review of this Safe Harbor Privacy Policy and to note recent updates. Neither this Safe Harbor Privacy Policy nor updates to it will affect or modify any contracts we have with our clients.

Access, Review & Update

If you are an EEA Person about whom we hold EEA Data on a clients behalf, you may request access to, and the opportunity to update, correct or delete, such EEA Data. To submit such requests or raise any other questions, please contact the business that provided your EEA Data. 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

If you have questions, please contact eTrigue's Security Officer, e-mail: . If you have a comment or concern that cannot be resolved with us directly, you may contact the competent local data protection authority.



Safe Harbor Statement Effective Date: 12/30/2009