Gaine Solutions, Inc. complies with the U.S. EU Safe Harbor Framework as agreed upon by the United States Department of Commerce and the European Commission. Gaine Solutions also complies with the U.S. Swiss Safe Harbor Framework as agreed upon by the United States Department of Commerce and the Federal Data Protection and Information Commissioner of Switzerland. Each of these frameworks includes a set of seven data protection principles and fifteen frequently asked questions. The respective frameworks enable US companies to satisfy the European Union requirement set forth in the European Commission’s Directive on Data Protection and the requirement set forth in the Swiss Federal Act on Data Protection that adequate protection be given to personal information transferred from the EU and Switzerland to the United States. Gaine Solutions adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view the certification, please visit http://www.export.gov/safeharbor/.

Gaine Solutions collects the following types of information: traditional contact information such as mailing addresses, phone and fax numbers and internet contact information such as email addresses. This information is voluntary via our website. It allows us to contact customers with information about our services.

Our website uses cookies and tracking technology called Google Analytics. Cookies and Google Analytics tracking technology are useful for gathering information such as browser type and operating system, tracking the number of visitors to the site, and understanding how visitors use the site. Cookies also help customize the site for visitors. Personal information cannot be collected via cookies; however, if a customer previously provided personally identifiable information, cookies may be tied to such information. Aggregate cookie and tracking information may be shared with Google Analytics to provide us with site management statistics.

Gaine Solutions, Inc. provides its customers with Master Data Management which creates and manages processes for collecting, aggregating, matching, consolidating, quality-assuring, and distributing data to ensure consistency and control in the ongoing maintenance and application of information. In this capacity, Gaine Solutions does not collect or own any personal information or control any of the information processed on behalf of our customers; all such information is owned and controlled by our customers.

The information we manage is not shared with email advertisers or other parties. Only Gaine Solutions contractors or employees who access the information in order to perform their job duties have access to information. These employees are fully committed to our privacy and security policies.

Privacy Principles

The privacy principles in this Policy are based on the seven Safe Harbor Principles.

1. NOTICE: This Safe Harbor Privacy Policy informs individuals about the purposes for which we collect and use data, how to contact us, the parties to which that information may be accessible, and the choices and means, if any, that Gaine Solutions offers individuals for limiting the disclosure of such data to non-agent third parties.

2. CHOICE: Gaine Solutions will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a third party, or (b) to be used for a purpose that is incompatible with the purpose(s) for which it was originally collected or subsequently authorized by the individual. Individuals will be provided with clear and conspicuous, readily available, and affordable mechanisms to exercise choice. We will provide notice in clear and conspicuous language when identifiable persons are first asked to provide their personal information, or as soon as practicable thereafter, but in no event before we use their personal information for a purpose other than which it was originally collected.

3. ONWARD TRANSFER: If and when we transfer personal information to data processors to perform processing tasks on our behalf and under our instructions, we require these data processors either: (i) to subscribe to the EU Safe Harbor Principles, the EU Data Protection Directive, or another adequacy finding; or (ii) to enter into a written agreement with Gaine Solutions requiring them to provide the same level of protection that we provide.

4. SECURITY: Gaine Solutions will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. Our employees are required to take a security training course and sign an agreement in connection with the Gaine Solutions security policy. Our Security Officer is responsible for ensuring that appropriate disciplinary action is taken against those who violate our security policy.

5. DATA INTEGRITY: Gaine Solutions will take reasonable steps to ensure that data is relevant to its intended use, accurate, complete, and current.

6. ACCESS: Upon request, Gaine Solutions will provide individuals reasonable access to personal information that it holds about them. Upon receipt of a written request, we will provide identifiable persons from whom we collect personal information reasonable access to their personal information.

7. ENFORCEMENT: Gaine Solutions has established internal mechanisms to verify its ongoing adherence to this statement. Gaine Solutions also encourages individuals covered by this statement to raise any concerns about our processing of their personal information by contacting the appropriate Gaine Solutions Privacy Office at the address below. Gaine Solutions will seek to resolve any concerns. Any employee that Gaine Solutions determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.

Dispute Resolution

Gaine Solutions encourages individuals to raise any concerns about our processing of their personal information by contacting the appropriate Gaine Solutions Privacy Office at the address below. We will investigate and try to resolve your complaint. However, if we cannot resolve the complaint, we shall participate in the dispute resolution procedures of the panel established by the EU data protection authorities to resolve disputes pursuant to the Safe Harbor Privacy Principles, as well as to cooperate and comply with the Swiss Federal Data Protection and Information Commissioner.

Gaine Solutions, Inc., Privacy Inquiries

1250 Judith Lane

Arroyo Grande, CA 93420 USA

Or email: privacy@gaine.com

All inquiries should include the individual’s name, address, and other relevant contact information (phone number, e-mail address).

We are 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 Privacy Policy

The practices described in this Policy are current Personal data protection policies as of November 30, 2004. Gaine Solutions 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.