Safe Harbor Privacy Policy

ExogenyNetwork.com("ExogenyNetwork.com") respects individual privacy and values the confidence of its customers, vendors, business partners and others. ExogenyNetwork.com strives to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business and has a tradition of upholding the highest ethical standards in its business practices. ExogenyNetwork.com abides by the Safe Harbor Principles developed by the U.S. Department of Commerce and the European Commission and the Frequently Asked Questions (FAQs) issued by the Department of Commerce on July 21, 2000.

This Safe Harbor Privacy Policy (the "Policy") sets forth the privacy principles that ExogenyNetwork.com follows with respect to transfers of personal information anywhere in the world, including transfers from the European Economic Area (EEA) (which includes the 15 member states of the European Union (EU) as well as Iceland, Liechtenstein and Norway) to the United States.
Personal information that is transferred to ExogenyNetwork.com in the United States from the EU falls under one of the following three situations:

·         Processor on Behalf - ExogenyNetwork.com provides corporate communications software designed to help companies automate workflow and manage media information more effectively. ExogenyNetwork.com does not own or control any of the information it processes on behalf of ExogenyNetwork.com’s customer. All such information is owned and controlled by ExogenyNetwork.com’s customer. In this capacity, ExogenyNetwork.com receives information transferred from the EU to the United States merely as a processor on behalf.

·         Data Controller - ExogenyNetwork.com also provides business information products designed to help companies market themselves more successfully. In this function, ExogenyNetwork.com acts as a data controller of the personal information contained in these information products.

·         Personal Data Collection - ExogenyNetwork.com may, in certain instances, itself collect data to improve its processes and products. This data collection is designed primarily to update ExogenyNetwork.com database of media contacts and to monitor the efficacy of various types of information distributed using ExogenyNetwork.com software or other products.

·         ExogenyNetwork.com has appointed a privacy officer who is responsible for the internal supervision of ExogenyNetwork.com’s privacy policies and data security. ExogenyNetwork.com is committed to educating its customers and associates (employees) in the United States and in the EU about the issues, guidelines and laws surrounding compliance with EU Safe Harbor.

·         ExogenyNetwork.com’s privacy officer and its legal team are available to any associate (employee) who may have questions concerning ExogenyNetwork.com’s EU Safe Harbor privacy policies or data security practices.

Since the requirements for compliance with EU Safe Harbor vary depending on whether ExogenyNetwork.com is acting as a processor on behalf of ExogenyNetwork.com’s customer or a data controller, ExogenyNetwork.com’s policies and manner of compliance are described separately below.

·         ExogenyNetwork.com as a Processor on Behalf - When ExogenyNetwork.com acts as a processor on behalf of its customer, the policies outlined below apply to all data processing operations concerning personal information that has been transferred from the EU to the United States.

·         Processing Contracts - Before starting any processing on behalf of ExogenyNetwork.com’s customer, ExogenyNetwork.com will enter into a processing contract with the EU data controller responsible for the personal information pursuant to the applicable EU Member State Data Protection law.

·         The processing contract ensures that the EU data controller will be in compliance with the Member State Data Protection law. Any data processed by ExogenyNetwork.com will not be further disclosed to third parties except where permitted or required by the processing contract, EU Safe Harbor or the applicable Member State Data Protection law. Any information which ExogenyNetwork.com’s customer (acting as the EU controller) identifies as sensitive will be treated accordingly.
The processing contract will also specify that the processing will be carried out with appropriate data security measures. ExogenyNetwork.com has in place measures to protect personal information from loss, misuse, unauthorized access, disclosure, alteration and destruction.

·         As a processor on behalf of ExogenyNetwork.com’s customer (who is the EU controller), ExogenyNetwork.com is not required to apply other EU Safe Harbor Principles to the personal information received for processing from a customer.

·         ExogenyNetwork.com as a Data Controller or Data Collector - When ExogenyNetwork.com acts as a data controller or data collector of personal information, the policies outlined below apply to all personal information that has been transferred from the EU to the United States.

·         ExogenyNetwork.com develops and maintains databases containing personal information on European media contacts from a number of EU Member States. In instances where ExogenyNetwork.com is a data controller, the information for these databases is developed from public records and from information acquired through information providers. In instances where ExogenyNetwork.com is a data collector, the information for these databases is developed from email, telephone, or other responses by media contacts. None of these databases contain any information defined as sensitive by any national law of an EU Member State (e.g., the databases do not include information about race, religion, sexual orientation, and so forth).
ExogenyNetwork.com’s databases contain information which is provided to qualified businesses for marketing and media relations purposes.

·         ExogenyNetwork.com may also use Web beacons or other unique identifiers to allow it to determine which messages or elements of a media campaign generate responses. This allows ExogenyNetwork.com software to gauge the effectiveness of certain communications. ExogenyNetwork.com will, as a service to its clients, provide data regarding the campaign effectiveness; such information is designed to make more efficient the process of transmitting and receiving media campaign information.

As either a data controller or data collector, ExogenyNetwork.com is required to comply with all principles of the EU Safe Harbor.

Notice - Prior to the transfer of any non-public personal information from the EU to the United States, ExogenyNetwork.com requires contractual confirmation from the EU controller from whom ExogenyNetwork.com acquired the information that the data subjects from whom the information was derived have been provided with proper notice pursuant to the applicable EU member state data protection law.

As indicated above, ExogenyNetwork.com may collect information to maintain and update its database, improve its products, and provide information to its clients.

·         Choice - Prior to the transfer of any non-public personal information from the EU to the United States, ExogenyNetwork.com requires contractual confirmation from the EU controller from whom ExogenyNetwork.com acquired the information that the data subjects from whom the information was derived have been provided with the choice to determine how their information may be used pursuant to the applicable EU member state data protection law.

·         In addition, ExogenyNetwork.com will, upon request, remove an individual’s name and related information from its information products.

·         In order to request that ExogenyNetwork.com not use an individual’s non-public personal information, such individual should contact ExogenyNetwork.com’s consumer advocate at the address provided below or by sending an email to us at safeharbor@ExogenyNetwork.com

·         Written communication should be addressed as follows:

Consumer Advocate

EU Safe Harbor Opt-Out

MetairieHumane.Giving.OfficeLive.com

ExogenyNetwork.com

c/o

Exogeny Network Media Partners

6211 Airline Drive

Metairie, LA 70003-4332 USA

Prior to making any alterations in its information, ExogenyNetwork.com will require that individuals confirm their identity.

Data Integrity - ExogenyNetwork.com takes reasonable steps to assure the information which is transferred from the EU to the United States is reliable, accurate and complete. The steps ExogenyNetwork.com takes to assure data integrity are made in light of the purposes for which the personal information is used.

Onward Transfer - ExogenyNetwork.com complies with the notice and choice principles as described above for all data which is disclosed or transferred to a third party.

ExogenyNetwork.com may from time to time use agents to perform processing tasks on behalf and under the instruction of ExogenyNetwork.com. ExogenyNetwork.com requires that its agents either:
Subscribe to the EU Safe Harbor Principles, the EU Data Protection Directive or another adequacy finding; or
Enter into a written agreement with ExogenyNetwork.com requiring them to provide the same level of protection as ExogenyNetwork.com.

Security - ExogenyNetwork.com will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. ExogenyNetwork.com limits access to personal information and data to those persons in ExogenyNetwork.com’s organization, or agents of ExogenyNetwork.com, that have a specific business purpose for maintaining and processing such information and data. Individuals who have been granted access to personal information are aware of their responsibilities to protect the security, confidentiality and integrity of that information.

Any security compromises or potential security compromises and any inquiries concerning security should be reported to the ExogenyNetwork.com consumer advocate. Contact information is provided below.

Access - An individual may make a request to ExogenyNetwork.com for access to the information ExogenyNetwork.com maintains in its information products. The individual has the right to receive confirmation from ExogenyNetwork.com as to whether or not data relating to him/her is found in ExogenyNetwork.com’s information products and to correct, amend, or delete that information when it is inaccurate. This right only applies to personal information relating to the individual making the request and is subject to other limitations as defined by law.
Individuals who wish to make an access request should direct such a request to ExogenyNetwork.com’s Consumer Advocate in ExogenyNetwork.com’s consumer affairs department at the address provided below or by sending an email to us at safeharbor@ExogenyNetwork.com.

Written communication should be addressed as follows:
Consumer Advocate

MetairieHumane.Giving.OfficeLive.com

ExogenyNetwork.com

c/o

Exogeny Network Media Partners

6211 Airline Drive

Metairie, LA 70003-4332 USA

ExogenyNetwork.com’s consumer advocate will explain the process to be followed by any individual making an access request. In order to confirm the identity of the individuals requesting access, ExogenyNetwork.com will require that individuals provide sufficient information to confirm their identity.

ExogenyNetwork.com agrees to process all reasonable requests for access within a reasonable time period, but reserves the right to deny access or limit access in cases where the burden or cost of providing access would be disproportionate to the risks to the individual’s privacy or in the case of a vexatious or fraudulent request.

Enforcement - Individuals who wish to file a complaint or who take issue with ExogenyNetwork.com's EU Safe Harbor policies should direct such communication to ExogenyNetwork.com’s consumer advocate via email or written communication as described above. ExogenyNetwork.com’s consumer advocate will explain the process to be followed when filing a complaint. Filing a complaint in English will expedite the process.

ExogenyNetwork.com will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Policy. For complaints that cannot be resolved between ExogenyNetwork.com and the complainant, ExogenyNetwork.com has agreed to participate in the dispute resolution procedures of the panel established by the European data protection authorities to resolve disputes pursuant to the Safe Harbor Principles.

ExogenyNetwork.com is also subject to the jurisdiction of the U.S. Federal Trade Commission. The Federal Trade Commission may be contacted at the following address:
Federal Trade Commission
Attn: Consumer Response Center
600 Pennsylvania Avenue NW
Washington, DC 20580
consumerline@ftc.gov
www.ftc.gov

Changes to this Safe Harbor Policy
The practices described in this policy are current personal data protection policies as of March 1, 2003. ExogenyNetwork.com reserves the right to modify or amend this policy at any time consistent with the requirements of the Safe Harbor Principles. Appropriate public notice will be given concerning such amendments.