Certent (“Certent” or the “Company”) collects and uses personal information you provide to the Company through this website solely to directly contact individuals who express interest in receiving our services. The Company does not sell any personal information to any third parties. By providing the Company your personal information, you agree that the Company may contact you and may use, store, process, and disclose to third parties your personal information solely and exclusively for the purpose for which it was originally collected and may not use, store, process, and/or disclose your personal information for any other purpose. See Certent’s Privacy Policy below for more information about how Certent protects your privacy.

Introduction

Certent (the “Company”) is a leading provider of equity administration solution services. Protecting the privacy of Personal Information (defined below) is important to the Company. The Company adheres to the Safe Harbor Agreement concerning the transfer of personal data from the European Union (“EU”) to the United States of America. Accordingly, we follow the Safe Harbor Principles published by the U.S. Department of Commerce (the “Principles”) with respect to all such data. If there is any conflict between the policies in this Privacy Policy and the Principles, the Principles shall govern. This Privacy Policy outlines our general policy and practices for implementing the Principles, including the types of information we gather, how we use this information, your rights regarding our use of this information and your ability to correct the information. This Privacy Policy applies to all Personal Information received by the Company whether in electronic, paper or verbal format.

Definitions

“Personal Information” or “Information” means information that (1) is recorded in any form; (2) is about, or pertains to a specific individual; and (3) can be linked to that individual.

Principles

Notice

The Personal Information the Company receives comes from use of our web site by individuals and use of our services by employees of a customer company or by administrators on behalf of such employees of a customer company. The Company uses this Personal Information solely to directly contact individuals who express interest in receiving our services or to provide such services. The Company does not sell any Personal Information to any third parties.

Company shall inform an individual providing his or her Personal Information directly of the purpose for which it collects and uses the Personal Information and the types of non-agent third parties to which the Company discloses or may disclose that Information. If the individual is providing his or her Personal Information directly, then Company shall provide the individual with the choice and means 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 the Company, or as soon as practicable thereafter, and in any event before the Company uses or discloses the Information for a purpose other than for which it was originally collected.

If in connection with providing its services, the Company receives Personal Information indirectly through an administrator employee, and not the individual with respect to which the Personal Information is regarding, then the administrator employee has received the express or implied consent of the applicable employee with whose Personal Information is being provided.

Choice

The Company will offer individuals providing their Personal Information directly and administrator employees the opportunity to choose (opt out) whether the Personal Information provided by them is (1) to be disclosed to a third party or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

By using the Company’s services and providing Personal Information to the Company through such use, individuals or administrators on behalf of those individuals have opted to authorize the Company to use the Personal Information for the purpose it was intended but for no other purpose.

Onward Transfers

The Company may provide Personal Information to third parties performing services on the Company’s behalf for the benefit of such individuals whose Personal Information is being disclosed provided that such third parties have agreed in writing with Company that they will provide at least the same level of privacy protection as is required by the Principles. Other than as permitted in the prior sentence, prior to disclosing Personal Information for any other purpose, Company shall notify the individual or company administrator employee of such disclosure and allow the individual the choice (opt out) of such disclosure. Company shall ensure that any third party for which Personal Information may be disclosed subscribes to the Principles or are subject to law providing the same level of privacy protection as is required by the Principles and agree in writing to provide an adequate level of privacy protection.

Data Security

Company shall take reasonable steps to protect the Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. Company has put in place appropriate physical, electronic and managerial procedures to safeguard and secure the Information from loss, misuse, unauthorized access or disclosure, alteration or destruction. Company cannot guarantee the security of Information on or transmitted via the Internet.

Data Integrity

Company shall only process Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual.

Access

Company shall allow an individual access to their Personal Information and allow the individual to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated.

Enforcement

Company uses a self-assessment approach to assure compliance with this Privacy Policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Principles. We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Information in accordance with the Principles. If a complaint or dispute cannot be resolved through our internal process, we agree to dispute resolution using (an independent resource mechanism) as a third party resolution provider.

Amendments

This Privacy Policy may be amended from time to time consistent with the requirements of the Safe Harbor. The Company will post any revised policy on this website.

Information Subject to Other Policies

The Company is committed to following the Principles for all Personal Information within the scope of the Safe Harbor Agreement. However, certain information is subject to policies of the Company that may differ in some respects from the general policies set forth in this Privacy Policy.

Contact Information

Questions, comments or complaints regarding the Company’s Safe Harbor Policy or data collection and processing practices can be mailed or emailed to:

Certent, Inc.
Attn: Legal Department
4683 Chabot Drive, Suite 260
Pleasanton, CA 94588

Effective date: March 20, 2011