EEPULSE, INC. PRIVACY POLICY

ePulse, Inc. complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. eePulse, Inc. has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

You have a right to access data we hold about you. You can correct factual errors in
your personally identifiable information (name, e-mail address, etc.) by contacting the party who asked you to complete the online survey or by sending an e-mail to: inof@eepulse.com To protect your privacy and security, we will also take reasonable steps to verify your identity before making corrections.

How To Contact Us
Our postal address is: eePulse, Inc.
455 E. Eisenhower Pkwy,
Ann Arbor, MI 48108 USA

Our phone number is: 734-429-4400
Should you have other questions or concerns about this privacy policy, please email us with your contact information at: info@eepulse.com

For more information go to www.eepulse.com

Right to Change Policy

We reserve the right to change this Privacy Statement. If we make any changes to this policy we will change the date at the top of this statement to reflect the effective date of the change. You are encouraged to check the date of this Privacy Statement to insure your awareness of any updates.

eePulse, Inc. commits to resolve complaints about your privacy and our collection or use of your personal information. Individuals with inquiries or complaints regarding this privacy policy should contact eePulse, Inc.at:

eePulse, Inc.
455 E. Eisenhower Pkwy., Ann Arbor, MI 48108 info@eepulse.com
734-429-4400
Note: there is the possibility under certain limited conditions, for the individual to invoke "last resort" binding arbitration.

eePulse, Inc. complies with the Swiss-U.S. Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from Switzerland. EePulse, Inc. has certified that it adheres to the Swiss-U.S. Privacy Shield Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. If there is any conflict between the policies in this privacy policy and the Swiss-U.S. Privacy Shield Principles, the Swiss-U.S. Privacy Shield Principles shall govern. To learn more about the Swiss-U.S. Privacy Shield and to view our certification page, please visit https://www.privacyshield.gov/Individuals-in-Europe In compliance with the Swiss-U.S. Privacy Shield Principles, eePulse, Inc. commits to resolve complaints about your privacy and our collection or use of your personal information. Swiss citizens with inquiries or complaints regarding this privacy policy should first contact eePulse, Inc.at:

eePulse, Inc.
455 E. Eisenhower Pkwy., Ann Arbor, MI 48108 info@eepulse.com | 734-429-4400

Your privacy is important to us. This notice explains our online information practices and it is available on all pages of our marketing web site and on all surveys we conduct. We do not sell, rent or trade data submitted to us.

In compliance with the Privacy Shield Principles eePulse commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Private Shield policy should first contact eePulse at:
Phone: +1 734-429-4400
Email: info@eepulse.com
Mail: 455 E. Eisenhower Pkwy., Ann Arbor, MI 48108 USA

eePulse has further committed to cooperate with EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU in the context of the employment relationship. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs for more information or to file a complaint. The services of EU DPAs are provided at no cost to you. eePulse has further committed to cooperate with the Swiss data protection authority (Swiss Federal Data Protection and Information Commissioner) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from Switzerland in the context of the employment relationship. If you do not receive timely acknowledgement of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the Swiss Federal Data Protection and Information Commissioner for more information or to file a complaint. The services of Swiss Federal Data Protection and Information Commissioner are provided at no cost to you.

eePulse, Inc. collects a wide range of data through our secure site https://secure.eepulse.net about and from respondents (anyone submitting data via a survey conducted by eePulse, Inc.) depending on the information needs of the client. In addition, clients may provide us with demographic information such as respondent name, respondent job title, department, geographic region, etc. This information gives us the flexibility to create group reports of respondent data sorted by department, location etc. Personal information is NEVER connected with any of the data or report seen by any client or third party unless authorized by the individual respondent. However, to make sure you do not inadvertently identify yourself, when submitting your response to comment questions, please refrain from writing comments like, "I just got back from vacation and found..." or anything that might cause you to disclose your
identity or your company's identity directly or indirectly within your comment. Before a user (a survey participant or manager viewing reports) can view secure information (e.g. individual or manager reports), the user must complete a registration process and establish logon credentials including user name and password. Users that only submit data via surveys typically are not required to complete the registration process or to enter logon credentials to complete a survey. Visitors to our marketing web site (www.eepulse.com) may also submit
data on our "Contact Us", "Join Our Team" or other data submission pages.

If you have a user account on one of our Web sites, you may access your information to update your registrant information through the Web site. You may also request that we remove your registration information from our current database by contacting us in the USA at +1 734-429- 4400 or info@eepulse.com.

Protecting the privacy of the very young is especially important. For that reason, no part of our websites are structured to attract anyone under 13 and we do not collect or maintain information at our websites from those we actually know are under 13.

We will only share your personally identifiable information ("Personally identifiable
information" means data that individually identifies you, such as your name, email address, phone number, address, etc.) to any third party if one or more of the following occur:

• we have your consent
• we consider that we are required to do so by law
• we find that you are in breach of our terms and conditions or any of our policies or usage guidelines for specific products or services
• it is necessary in our opinion to do so to prevent, investigate, detect or prosecute criminal offences or attacks on the technical integrity of our site(s) or our network
• it is necessary in our opinion to do so to protect the rights, property, or safety of eePulse and its employees, the users of our site(s), or the public.
• eePulse, Inc. may be required to disclose an individual's personal information in response to a lawful
• request by public authorities, including to meet national security law enforcement requirements.
• you may ask us to provide you access to your personal data and we will provide that upon a request submitted in writing to info@eepulse.com or calling us at +1 734-429-4400. eePulse is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTCo)

In the typical eePulse, Inc. survey process, the data we receive from respondents are confidential to eePulse and anonymous to the client. eePulse knows who submitted data and stores the responses with the respondent's name. This allows us to: 1) provide individual reports to the respondent so the respondent can compare himself or herself to department and company level results; 2) group data into various categories allowing reports to be generated immediately; 3) give managers the ability to respond directly to groups or individuals within an organization while maintaining individual respondent anonymity; 4) give coaches (either eePulse, Client or Third Party) the ability to respond directly to the individual for the purpose of clarifying information provided by the respondent or to provide information to the respondent while maintaining individual respondent anonymity. At all times, the respondent's name and other identifying information previously loaded into our database are kept confidential to eePulse and anonymous to the client and third party.

At times, respondents say things in the open-ended comments that can identify them to anyone reading a report. For example, if you say:
"I was on vacation last week and I can't believe they moved my desk to the third floor in front of the big window. I can't work because the sun is too bright."

Anyone reading this comment would know that the person on the third floor whose desk was just moved wrote the comment.

Under our standard contract terms, comments go directly into reports to managers and the staff at eePulse does not read, edit or make changes to respondent comments. If
respondents do not want it to be known that they participated or made a comment, they must

make sure to write comments so that they do not disclose information that will identify them to the reader of a group report (that puts multiple comments together in one large report).

eePulse, Inc. has implemented internal controls and procedures that are designed to preserve the confidentiality and anonymity of the respondents. These include: 1) Each client must agree that eePulse, Inc. will not reveal information to the client or any third party that identifies the respondent. 2) Data that has been previously loaded into our database that may identify or be identifiable to a respondent, such as name, title, etc., are not included with any reports to the client or in any other data provided to clients. 3) Any information provided by the respondent during the technical support process is used only for the intention of providing technical support. 4) All eePulse employees sign non-disclosure agreements obligating them to maintain the confidentiality of the data. 5) Multi-tier security technology is utilized to prevent and detect unauthorized access to the eePulse Measurecom website, including using a secured (SSL) line for data transmission. Unfortunately, no method of transmission over the Internet, or method of electronic storage, is completely secure. Therefore, while we take safeguards to protect the personal information that you transmit to us, we cannot guarantee its absolute security.

Liability for onward transfer of data to third parties ePulse does not, and will not in the future transfer personal data to third parties.

A cookie is a small piece of data that is sent to your browser from a web server and stored on your computer's hard drive. A cookie can't read data off your hard disk or read cookie files created by other sites. Cookies do not damage your system. We use cookies to store your client id., user name, and if you choose, your password, so that you don't have to re-enter them each time you visit our website. eePulse, Inc. does not store any other personally identifiable information in cookies.

You can choose whether to accept cookies by changing the setting of your browser. You can set your browser to refuse all cookies, or allow your browser to show you when a cookie is being sent. If you choose not to accept these cookies, your experience at our site and other websites may be diminished and some features may not work as intended.

We use log file analysis tools and outside services to collect and analyze our web traffic. None of these tools personally identifies our visitors to the www.eepulse.com web site. They are used to help us understand our marketing effectiveness, enhance our web interface, and improve your overall online experience with eePulse.

Our web sites contain links to other, third party web sites. Please be aware that eePulse is not responsible for the privacy practices of such other sites. We encourage you to read the privacy statements of the destination sites.