Safe Harbor Privacy Policy

Internet Privacy Policy

Globecon respects individual privacy and values the confidence of its customers, employees, clinical trial participants, consumers, business partners and others. Not only does Globecon strive to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business, but 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 Globecon 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.

SAFE HARBOR

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

SCOPE

This Safe Harbor Privacy Policy (the "Policy") applies to all personal information received by Globecon in the United States from the EEA and from Switzerland, in any format, including electronic, paper or verbal.

DEFINITIONS

For purposes of this Policy, the following definitions shall apply:

"Agent" means any third party that collects or uses personal information under the instructions of, and solely for, Globecon or to which Globecon discloses personal information for use on Globecon's behalf.

"Globecon" means Globecon Group Holdings, LLC, its predecessors, successors, subsidiaries, divisions and groups in the United States.

"Personal information" means any information or set of information that identifies or could be used by or on behalf of Globecon to identify an individual. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.

"Sensitive personal information" means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, views or activities, that concerns health or sex life, information about social security benefits, or information on criminal or administrative proceedings and sanctions other than in the context of pending proceedings. In addition, Globecon will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.

PRIVACY PRINCIPLES

The privacy principles in this Policy have been developed based on the Safe Harbor Principles.

NOTICE: Where Globecon collects personal information directly from individuals in the EEA, it will inform them about the purposes for which it collects and uses personal information about them, the types of non-agent third parties to which Globecon discloses that information, the choices and means, if any, Globecon offers individuals for limiting the use and disclosure of personal information about them, and how to contact Globecon. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to Globecon, or as soon as practicable thereafter, and in any event before Globecon uses or discloses the information for a purpose other than that for which it was originally collected.

Where Globecon receives personal information from its subsidiaries, affiliates or other entities in the EEA, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.

CHOICE: Globecon will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

For sensitive personal information, Globecon will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

Globecon will provide individuals with reasonable mechanisms to exercise their choices.

DATA INTEGRITY: Globecon will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Globecon will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.

TRANSFERS TO AGENTS: Globecon will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is required by the relevant Safe Harbor Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), being subject to Swiss Federal Act on Data Protection, Safe Harbor certification by the agent, or being subject to another European Commission or Swiss FDPIC adequacy finding (e.g., companies located in Canada). Where Globecon has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, Globecon will take reasonable steps to prevent or stop the use or disclosure.

ACCESS AND CORRECTION: Upon request, Globecon will grant individuals reasonable access to personal information that it holds about them. In addition, Globecon will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.

SECURITY: Globecon will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

ENFORCEMENT: Globecon will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that Globecon determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.

DISPUTE RESOLUTION: Any questions or concerns regarding the use or disclosure of personal information should be directed to the Globecon Privacy Office at the address given below. Globecon will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information by reference to the principles contained in this Policy. For complaints that cannot be resolved between Globecon and the complainant, Globecon has agreed to participate in the following dispute resolution procedures in the investigation and resolution of complaints to resolve disputes pursuant to the Safe Harbor Principles:

  1. for disputes involving all personal information received by Globecon from Switzerland, Globecon has agreed and to cooperate with the Swiss FDPIC;

  2. for disputes involving employment-related personal information received by Globecon from the EEA, Globecon has agreed to cooperate with the data protection authorities in the EEA and to participate in the dispute resolution procedures of the panel established by the European data protection authorities;

  3. for disputes involving all other personal information received by Globecon from the EEA, Globecon has agreed to TRUSTe dispute resolution. Individuals who submit a question or concern to Globecon and who do not receive acknowledgment from Globecon of the inquiry or who think their question or concern has not been satisfactorily addressed should then contact the TRUSTe Safe Harbor Dispute Resolution Program on the Internet, by mail or by fax. Inquiries by mail or fax should identify Globecon as the company to which a concern or question has been submitted, and include a description of the privacy concern, the name of the individual submitting the inquiry, and whether TRUSTe may share the details of the inquiry with Globecon. TRUSTe will act as a liaison to Globecon to resolve these disputes.

LIMITATION ON APPLICATION OF PRINCIPLES

Adherence by Globecon to these Safe Harbor Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations; and (c) to the extent expressly permitted by an applicable law, rule or regulation.

INTERNET PRIVACY

Globecon sees the Internet and the use of other technology as valuable tools to communicate and interact with consumers, employees, business professionals, business partners, and others. Globecon recognizes the importance of maintaining the privacy of information collected online and has created a specific Internet Privacy Policy (the "IPP") governing the treatment of personal information collected through web sites that it operates. With respect to personal information that is transferred from the European Economic Area or Switzerland to the U.S., the IPP is subordinate to this Policy. However, the IPP also reflects additional legal requirements and evolving standards with respect to Internet privacy. Globecon's Internet Privacy Policy can be obtained by contacting the company at info@globecon.com.

CONTACT INFORMATION

Questions or comments regarding this Policy should be submitted to the Globecon Privacy Office by mail to:

Globecon Privacy Office
Globecon Group Holdings, LLC
285 West Side Avenue
Jersey City, New Jersey 07305
United States of America

Or by e-mail info@globecon.com

CHANGES TO THIS SAFE HARBOR PRIVACY POLICY

This Policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. A notice will be posted on the Globecon web page (www.globecon.com) for 60 days whenever this Safe Harbor Privacy Policy is changed in a material way.

EFFECTIVE DATE: 1 JUNE 2011

Internet Privacy Policy

Safe Harbor Privacy Policy

SUMMARY OF OUR ONLINE PRIVACY COMMITMENT TO YOU

  1. We understand and respect that your privacy is important to you.
  2. We use and share personal information that you provide online only in ways that we tell you about.
  3. We use commercially reasonable efforts to secure personal information that you provide online to prevent it from being used and shared for other purposes.
  4. For more details, please read our Internet Privacy Policy below or contact us.

Globecon offers online resources designed to provide professional development and performance management for individuals and companies.

Respect for the privacy of personal information about you is very important to us. Globecon Web sites that display this privacy policy ("policy") are committed to collecting, maintaining, and securing personal information about you in accordance with this policy, as well as applicable laws, rules and regulations. This policy applies to personal information (as defined below) collected from Globecon online resources and communications (such as Web sites, e-mail, and other online and downloadable tools) that display a link to this policy. This policy does not apply to personal information collected from offline resources and communications, except in cases where such personal information is consolidated with personal information collected by Globecon online. This policy also does not apply to third-party online resources to which Globecon's Web sites may link, where Globecon does not control the content or the privacy practices of such resources.

This policy is consistent with Globecon's Safe Harbor Privacy Policy for transfers of personal information from the European Economic Area and from Switzerland to the United States. It is supported by Globecon's machine-readable Platform for Privacy Preferences (P3P) Policy.

Please read this policy carefully. Should you have any questions about this policy or our data collection, use and disclosure practices, please contact us as hereinafter described.

*As referred to in this Privacy Policy, "Globecon" means Globecon Group Holdings, llc, its successors, subsidiaries, divisions and groups worldwide, excluding joint ventures to which Globecon is a party.

How does this Privacy Policy define "personal information"?

The term "personal information" as used throughout this policy, applies to any information or set of information that identifies or that is used by or on behalf of Globecon to identify an individual.

How does Globecon collect personal information online?

Globecon collects personal information online through Web sites and other online resources. Globecon also offers online resources in collaboration with other online service providers, from which Globecon may receive personal information about users of such resources. These online collaborations are governed by agreements that require personal information to be protected appropriately. Individuals may access many parts of our Web sites and online resources without disclosing any personal information. There are three methods that Globecon uses to collect personal information online:

1. Information that you provide: Globecon collects personal information and other data that you may enter into forms or data fields on our Web sites or online resources. Such information may include, but not be limited to, contact information (such as your name, postal address, e-mail address, telephone number, user ID and password), date of birth, professional credentials, experiences, activities, skills, preferences, hobbies and interests. Globecon may also collect compensation and competency information about you that you provide by responding to our questions and surveys or through your use of online and downloadable tools we provide. Our Web sites do not collect credit card information, other than credit card confirmation data through third-party vendors, such as PayPal.

2. Information from public or third party information sources: Globecon may collect personal information about business professionals who register on our Web sites from public or third party information sources to verify their professional credentials and identity. In some cases, we may augment our existing user databases with information from third parties. Some of this information may be personal information, such as change of postal address information.

3. Information collected from your computer or other electronic device: We collect information about your computer or other electronic device when you visit our Web sites and use our online resources. This information may include your Internet Protocol (IP) address, domain name, browser type, date and time of your request and information provided by tracking technologies, such as cookies and single-pixel tags. If you use a mobile device to access our web sites and online resources, we also may collect information about your device, such as your device ID and device type, as well as usage information about your device and your use of our mobile Web sites and other mobile resources.

Some of our Web sites and other online resources use tracking technologies to provide additional functionality that enables you to use these resources more effectively. Globecon uses tracking technologies in ways that do not identify you personally, such as to track accurately numbers of users or referring sites or advertisements to our online resources, or to remember whether you have identified yourself as a business professional or a resident of a particular country. Globecon may use other companies to deliver e-mail communications on our behalf or to place Globecon advertisements on other web sites. Globecon does not control the tracking technologies used by these other companies. If you want to limit anonymous data collection through tracking technologies, please refer to your choices as described below.

In some cases, Globecon may use tracking technologies in ways that identify you personally, but only after you have entered personal information into a form or data field on our Web sites, or where we have registered you to use our online resources by providing a user ID and password based on information validated through other offline interactions with you. We may use tracking technologies to remember your personal preferences and selections, such as personal information that you have entered into data fields on our Web sites, answers that you have provided in response to our surveys, sections of our Web sites that you visit frequently, or to confirm whether you have read or clicked on certain e-mail communications we send to you so that we can make our communications more useful and interesting to you.

You may choose whether or not you want Globecon to use tracking technologies to remember you when you visit our web sites, and/or to provide additional personalized services to you. If you want to limit data collection through tracking technologies, please refer to your choices as described below.

What are cookies?

A cookie is a small data file that is sent by Web servers to your computer's hard drive, where your Internet browser files are kept. Cookies enable Web sites to store small bits of information on your computer and retrieve that information at a later time. Globecon uses two types of cookies: session cookies, which are temporary cookies that are erased from your computer's memory when you close your Internet browser or turn your computer off, and persistent cookies, which exist on your computer's hard drive until they expire, unless you delete them at an earlier time.

What are single-pixel tags?

Single-pixel tags, also known as web beacons or web tags, are graphics that function similar to cookies. Single-pixel tags are not visible because of their small size. They are used to collect information in web logs that does not identify you personally such as web pages viewed, the web site you came from and the advertisement you clicked on to visit our web sites. They also are used to determine whether certain promotional or other commercial e-mail messages we send are opened.

Why does Globecon collect, use and disclose personal information?

1. Generally: Globecon collects personal information online as necessary to enable individuals to register for, customize and personalize certain of Globecon's online resources and communications. Globecon uses personal information collected online to provide products, services and features and other resources that individuals have requested; for example, educational literature and related information about Globecon's business, e-mail programs, tools, quizzes, questionnaires, and surveys. Globecon analyzes personal information collected online to identify and offer additional services that we believe you might find interesting. Globecon evaluates use of some online resources and communications with non-identifiable or aggregate information only. Globecon also may use personal information to audit its online resources for authorized access and security.

2. Social Media: Online social media resources are interactive tools that typically enable you to collaborate and share information with others. Some examples of social media resources include social networks, discussion boards, bulletin boards, blogs, wikis, and referral functions to share web site content and tools with a friend or colleague. Globecon may collect personal information from you to enable you to use online social media resources we may offer from time to time. Globecon may also enable you to use these social media resources to post or share personal information with others. You should consider carefully what information about yourself you choose to share with others when you use social media resources. Globecon provides additional notice and choices about how personal information is collected, used and disclosed on our Web sites and other online resources that offer social media.

3. Mobile Computing: Some Globecon Web sites and online resources are designed specifically for use on mobile computing devices. Some mobile versions of Globecon Web sites may require that you log in with your user account for that Web site. Information about your use of the mobile version of the Web site will be associated with your user account. Some of our Web sites and online resources enable you to download an application, widget or other tool that you can use on your mobile or other computing device. Some of these tools may store information on your mobile or other device. These tools may transmit personal information to Globecon to enable you to access your user account and to enable Globecon to track use of these tools. Some of these tools may enable you to e-mail reports and other information from the tool. Globecon may use personal or non-identifiable information transmitted to Globecon to enhance these tools, to develop new tools, for quality improvement and as otherwise described in this Policy or in other notices Globecon provides.

Does Globecon consolidate personal information?

Consistent with the purposes identified and standards set within this policy and other applicable privacy notices that have been provided, in some cases Globecon consolidates and uses personal information that individuals share with Globecon through various services and channels, such as the telephone, surveys, Web sites and other online resources and communications, in order to enhance the quality of services that we offer.

What choices do I have about how Globecon collects, uses and discloses personal information about me?

You have four categories of choices. These include:

1. No personal information collection: You may choose not to provide any personal information to Globecon online by electing not to enter any personal information into a form or data field on our Web sites, and by not using any personalized services provided by our online resources. However, some of our online resources are available only to individuals who provide personal information or who use personalized services.

2. Limitations and options regarding uses and disclosures for other purposes: Some Globecon online resources may request your permission to use and disclose personal information about you in order to add you to our contact lists, to enable you to list yourself in a directory or a social media resource, and to identify and offer additional services and promotions that we believe you might find interesting. You can limit the use of personal information about you by checking or un-checking options provided at the time that you enter that information or that we may offer to you in the future. Additionally, you may change your communications preferences (such as to opt-out of communications you requested previously) by contacting us as hereinafter described.

3. Limitations and options on tracking: Globecon online resources that use tracking technologies, such as cookies, to remember your personal preferences and selections, enable you to choose whether you want Globecon to use such technologies to remember you, or to provide additional services to you, by checking or un-checking options provided during registration, or at the time that you enter personal information into forms or data fields. Our online resources do not limit non-identifiable uses of tracking technologies for individual users. Individual users can control the use of certain tracking technologies, such as cookies, through most Internet browsers. Some Internet browsers enable you to limit or disable the use of cookies for individual Web sites. Other browsers allow you to select cookie settings for all Web sites that you visit. If you are concerned about the use of cookie technology, please read our section above on "Information collected from your computer or other electronic device" to understand the ways that Globecon uses tracking technologies. If you limit or disable cookies, certain functions of our Web sites may not work properly, including access to some of our registration-based Web sites.

If you would like to opt-out of the cookies set by other companies who deliver e-mail communications on our behalf or place Globecon advertisements on other Web sites, you may do so by following the options provided by the Network Advertising Initiative at: http://www.networkadvertising.org/optout_nonppii.asp.

4. E-mail communications: You may choose to receive optional e-mail and other communications from Globecon by signing up for or subscribing to these communications on our Web sites and other online resources. If you do not wish to receive optional e-mail communications, you may opt-out by visiting the web site or other online resources where you subscribed, where available, and update your e-mail communication selections, or you may follow the unsubscribe or opt-out instructions in the e-mail communications you receive from us. You also may opt-out by contacting us as hereinafter described. If you do not wish for Globecon to confirm whether you have read or clicked on certain e-mail communications we have sent to you, you may opt out of e-mail communications tracking by opting out of receiving those e-mail communications altogether using one of the approaches described above. In some cases we will not be able to turn off e-mail tracking and still send the communication to you.

Who will have access to personal information about me?

Personal information about you will be accessible to Globecon, including its subsidiaries, divisions and groups worldwide, and to individuals and organizations that use personal information solely for and at the direction of Globecon. Uses and disclosures of personal information by external individuals and organizations acting on Globecon's behalf are governed by agreements that require personal information to be protected appropriately. Personal information about you only will be used and disclosed by Globecon and individuals and organizations working on its behalf, in a manner consistent with this policy, other applicable privacy notices, and as explicitly permitted or required by applicable laws, rules and regulations.

Does Globecon share personal information with third parties?

In general, Globecon does not sell or share personal information about you except as described in this policy and other applicable privacy notices, however, circumstances may arise where Globecon may, for business reasons, decide to reorganize or divest its business through sale, merger or acquisition. In these circumstances, personal information may be shared with actual or prospective purchasers. Globecon will obtain written assurances that personal information will be protected appropriately in these circumstances. Globecon reserves the right to disclose personal information about you, including your e-mail address, for reporting to government authorities, to parties in relevant legal proceedings as authorized by the presiding court or tribunal and otherwise to the extent required or explicitly authorized by applicable law. Except as provided in this policy, personal information about you will not otherwise be shared without your permission.

How does Globecon secure personal information?

Globecon will take reasonable steps to protect personal information as it is transmitted from your computer to our online resources and servers, as well as to protect personal information in its possession from unauthorized access, disclosure, alteration or destruction. It is your personal responsibility to secure your own copies of your passwords and related access codes for our online resources.

How does Globecon protect the privacy of children? Globecon Web sites are not directed at children and most of the online services that we offer are designed for individuals who are 18 years of age or older.

How may I access and correct personal information about me?

To gain access to personal information about you collected online, and to keep it accurate, complete and current, you may contact us as hereinafter described. Where offered, you also may update personal information about you online by modifying information that you previously have entered into forms or data fields on our Web sites. Where permitted by law, your ability to access and correct personal information will be limited where access and correction would: inhibit Globecon's ability to comply with a legal or ethical obligation, inhibit Globecon's ability to investigate, make or defend legal claims, result in disclosure of personal information about a third party, result in breach of a contract or disclosure of trade secrets or other proprietary business information belonging to Globecon or a third party.

What is Globecon's contact address for privacy questions?

Should you have questions about this policy or Globecon's information collection, use and disclosure practices, you may contact us at the address most relevant to you. You may access this list of addresses online at https://www.globecon.com/contact_us/contact_us.html. When you contact us, please note the name of the Web site or other online resource you used or to which you provided personal information, as well as the nature of any information that you provided. We will use reasonable efforts to respond promptly within 10-20 business days to requests, questions or concerns you may have regarding access to personal information about you collected online or our use of personal information about you. We may contact you for follow up information and may share your inquiry with other individuals within Globecon or working for Globecon that are responsible for functions related to the subject of your inquiry. Except where required by law, Globecon cannot ensure a response to questions or comments regarding topics unrelated to this policy or Globecon's privacy practices.

How will I know whether Globecon has updated this policy?

Globecon may update this policy periodically. Globecon reserves the right to modify, add or remove portions of this privacy statement at its discretion. If we decide to change this policy, we will post those changes at this site so you always will know what information we gather, how we might use that information, and whether we will disclose it to anyone. If the changes we make to the policy are material, we also may post a notice on the Globecon web page (www.globecon.com) or, in some cases, may provide notice of the changes by e-mail. This policy was last updated on January 15, 2011.