SAFE HARBOR POLICY

Safe Harbor Policy

Mitratech Holdings, Inc. provides market-leading Collaborative Accountability Applications for businesses and their trusted partners. With team-oriented domain applications in legal process automation, governance, risk, compliance and security, Mitratech’s TeamConnect Collaborative Accountability Suite improves transparency of financial reporting, reduces exposure to risk, and boosts operating discipline, information security and the efficiency of enterprise processes. Our Collaborati browser application also meets the accountability and collaboration needs of proliferating extraprise teams, wherein vendors, partners and service providers often have to be included in sensitive teamwork projects such as electronic billing, legal hold and collaborative budgeting, or those which expose your business to liability.

Using Mitratech’s Collaborative Accountability Applications, information can be processed on an organization’s own computers or on computers hosted by Mitratech Holdings, Inc. In the latter case, Mitratech Holdings, Inc. is an Application Service Provider (ASP). Mitratech Holdings, Inc. respects individual privacy and values the confidence of their customers, employees, business partners and others. Mitratech Holdings, Inc. prides itself on upholding the highest ethical standards in its business practices. Mitratech Holdings, Inc. shall not knowingly allow the property of a Customer to be used for any purpose other than the Customer’s processing, shall keep such Customer Proprietary Information confidential, and shall not disclose any such Customer Proprietary Information for any other purpose unless instructions are received, in writing from an officer of the Customer. To help ensure and protect the confidentiality of a Customer’s business and to prevent unauthorized persons from gaining access to a Customer’s records, Mitratech Holdings, Inc. shall adhere to best practice security procedures.

As an ASP, Mitratech Holdings, Inc. has certain responsibilities for protecting the privacy of a Customer’s information including any personal information being maintained in a Customer’s files. Each Customer, as the collector and user of that information, has primary responsibility for the privacy of that information. The Safe Harbor Privacy Policy (the “Policy”) sets forth the privacy principles that Mitratech Holdings, Inc. follows with respect to personal information transferred from the European Union (EU) and/or Switzerland to the United States.

SAFE HARBOR

Consistent with its commitment to protect personal privacy, Mitratech Holdings, Inc. adheres to the Safe Harbor Principles as set forth by the U.S. Department of Commerce in the U.S. – EU Safe Harbor Framework and the U.S. Swiss Safe Harbor Framework.

To learn more about the Safe Harbor program, and to view the certification for Mitratech Holdings, Inc., visit http://www.export.gov/safeharbor.

DEFINITIONS

For purposes of this Policy, the following definitions shall apply:
“Personal information” means any information or set of information that identifies or is used by or on behalf of a Company 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, sexual orientation, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns an individual’s health. In addition, Mitratech Holdings, Inc. 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 are based on the Safe Harbor Principles.
NOTICE: Where Mitratech Holdings, Inc. collects personal information directly from individuals in the EU and/or Switzerland, it will inform them about the type of personal information collected, the purposes for which it collects and uses the personal information, and the types of non-agent third parties to which Mitratech Holdings, Inc. discloses or may disclose that information, and the choices and means, if any, Mitratech Holdings, Inc. offers individuals for limiting the use and disclosure of their personal information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to Mitratech Holdings, Inc., or as soon as practicable thereafter, and in any event before Mitratech Holdings, Inc. uses or discloses the information for a purpose other than that for which it was originally collected.

Where Mitratech Holdings, Inc. receives personal information from their subsidiaries, affiliates or other entities in the EU and/or Switzerland, they 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

Mitratech Holdings, Inc. 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, Mitratech Holdings, Inc. 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. Mitratech Holdings, Inc. will provide individuals with reasonable mechanisms to exercise their choices.

DATA INTEGRITY

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

TRANSFERS TO AGENTS

Mitratech Holdings, Inc. will obtain assurances from their agents that they will safeguard personal information consistently with this Policy. Examples of appropriate assurances that may be provided by agents include, but are not limited to: 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), Safe Harbor certification by the agent, or being subject to another European Commission adequacy finding. Where Mitratech Holdings, Inc. becomes aware that an agent is using or disclosing personal information in a manner contrary to this Policy, Mitratech Holdings, Inc. will take reasonable steps to prevent or stop the use or disclosure.

ACCESS AND CORRECTION

Upon request, Mitratech Holdings, Inc. will grant individuals reasonable access to personal information that it holds about them. In addition, Mitratech Holdings, Inc. will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.

SECURITY

Mitratech Holdings, Inc. will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

ENFORCEMENT

Mitratech Holdings, Inc. will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Employees will be properly trained to adhere to these principles. Any employee that Mitratech Holdings, Inc. determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment. Mitratech Holdings, Inc. is subject to the laws and regulations of the Federal Trade Commission.

DISPUTE RESOLUTION

Any questions or concerns regarding the use or disclosure of personal information should be directed to the Mitratech Holdings, Inc. Privacy Office at the address given below. Mitratech Holdings, Inc. 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.

LIMITATION ON APPLICATION OF PRINCIPLES

Adherence by Mitratech Holdings, Inc. to these Safe Harbor Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; and (b) to the extent expressly permitted by an applicable law, rule or regulation.

CONTACT INFORMATION

Questions or comments regarding this Policy should be submitted by mail as follows:

Mitratech Holdings, Inc.
Attention: Human Resources
5001 Plaza on the Lake, Suite 111
Austin, TX 78746
P: 512-382-7322
F: 512-382-7529

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 Mitratech Holdings, Inc. Web page, www.mitratech.com when there is a material change in the policy. This policy can be viewed on the Mitratech Holdings, Inc. Web page. Effective Data: June 26, 2012.