SAFE HARBOR PRIVACY POLICY

Arandell Corporation, acting as a processor on behalf of its customer, agrees to conduct its business according to the European Union (EU) Safe Harbor Principles and the Frequently Asked Questions issued by the United States Department of Commerce on July 21, 2000.

Prior to any processing on behalf of Arandell Corporation’s customer, we 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. The processing contract will also specify that the processing will be carried out with appropriate data security measures. These measures are to protect personal information from loss, misuse, unauthorized access, disclosure, alteration and destruction.

Any data processed by Arandell Corporation will not be 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 identified as sensitive by the data controller will be treated accordingly.

Arandell Corporation provides its employees education on compliance with the Safe Harbor Principles and has self-assessment procedures in place to ensure its compliance. Individuals who wish to file a complaint or who take issue with Arandell Corporation’s Safe Harbor Privacy Policy should contact Mr. James Giencke at the address provided above.

Arandell Corporation has registered under The Direct Marketing Association Dispute Resolution Agreement. Should an individual be unable to resolve a complaint after having contacted Mr. Giencke, they may file their complaint with The Direct Marketing Association at the following address:

The Direct Marketing Association

Attn: Ethics/Consumer Affairs Department

1111 19th Street, Suite 1100

Washington, D.C. 20036

safeharbor@the-dma.org

www.the-dma.org

Arandell Corporation is also subject to the jurisdiction of the United States Federal Trade Commission. Should an individual be unable to resolve a complaint through The Direct Marketing Association’s Safe Harbor Dispute Resolution process, they may contact the Federal Trade Commission at the following address:

Federal Trade Commission

Attn: Consumer Response Center

600 Pennsylvania Avenue NW

Washington, D.C. 20580

consumerline@ftc.gov

www.ftc.gov