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MERKLE EU SAFE HARBOR PRIVACY POLICY

Merkle conducts its data transfer from the European Union (EU) to the United States (US) according the EU Safe Harbor Principles and the frequently asked questions (FAQs) issued by the US Department of Commerce on July 21, 2000.

Processor On Behalf

Merkle Inc. acts as a processor on behalf of its clients, providing customized services that enable organizations to manage their customer information efficiently in such ways as reducing data-processing timeframes, increasing marketing efficiency, and applying database marketing strategies. Merkle processes marketing information of its clients and on behalf of its clients. In this capacity as a processor on behalf, Merkle acts on the instructions of its clients and does not control or share such data without direction from the client.

For such data processing, Merkle enters into agreements with its clients in the EU specifying that the EU client recognizes that it is a data controller for the purpose of the EU Data Directive and is in compliance with the corresponding Member State national data protection laws.

Data Security

Merkle will not disclose to third parties personal data processed in this capacity, except as permitted or required by the processing agreement, EU Safe Harbor, applicable Member State data protection law or as otherwise required by law.

Merkle has security measures in place to help protect personal data from loss, misuse, unauthorized access, disclosure, alteration, and destruction.

Inquiries

Merkle has a designated individual who is responsible for the internal supervision of Merkle’s privacy policies. Merkle educates relevant employees about compliance with the Safe Harbor Principles and has self-assessment procedures in place to ensure its compliance. The U.S. Direct Marketing Association (DMA) serves as Merkle's third-party dispute resolution provider, as required under the Safe Harbor principles.

If you believe that Merkle is not complying with the Safe Harbor principles or this policy, contact our company by mail, e-mail, or telephone at:

Merkle Inc. 7001 Columbia Gateway Drive
Columbia, Md. 21046

Telephone: 443-542-4000
Email: eusafeharbor@merkleinc.com

If your inquiry with Merkle has not been satisfactorily addressed, you should contact the DMA Safe Harbor Dispute Resolution Program. The DMA will then work with Merkle to resolve your concerns. You can reach the DMA Safe Harbor Program at:

Safe Harbor
Direct Marketing Association
1615 L St, NW Ste 1100
Washington, DC 20036-5624
http://www.dmaresponsibility.org/SafeHarbor/consumers.shtml