PRIVACY POLICY

HRsoft respects individual privacy and values the confidence of its customers, our employees, our customer’s employees, our business partners and others. We collect, use and disclose personal information in a manner consistent with the laws of the countries in which we do business.

Our Safe Harbor Privacy Policy (the “Policy”) sets forth the privacy principles we follow with respect to transfers of personal information from the European Economic Area (EEA) (which includes the twenty-seven member states of the European Union (EU) plus Iceland, Liechtenstein and Norway) and from Switzerland to the United States.

HRsoft complies with the U.S. – European Union Safe Harbor Framework and the U.S. – Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. HRsoft has certified that it adheres to the Safe Harbor Privacy Principals of notice, choice, onward transfer, security, data integrity, access and enforcement. To learn more about the Safe Harbor program, and to view HRsoft’s certification please visit
http://www.export.gov/safeharbor

SAFE HARBOR

The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EEA to the United States (the “U.S.-EU Safe Harbor”). The EEA also has recognized the U.S.-EU Safe Harbor as providing adequate data protection (OJ L 45, 15.2.2001, p.47). The United States Department of Commerce and the Federal Data Protection and Information Commissioner (FDPIC) of Switzerland have agreed on a similar set of principles and frequently asked questions to enable companies to satisfy the requirement under Swiss law that adequate protection be given to personal information transferred from Switzerland to the United States (the “U.S.-Swiss Safe Harbor”). Consistent with our commitment to protect personal privacy, we adhere to the principles set forth in the U.S.-EU Safe Harbor and the U.S.-Swiss Safe Harbor (the “Safe Harbor Principles”).

SCOPE

This Safe Harbor Privacy Policy (the “Policy”) applies to all personal information received by us in the United States from the EEA and from Switzerland, in any format, including electronic, paper or verbal.

PRIVACY PRINCIPLES

The privacy principles in this Policy have been developed based on the Safe Harbor Principles.

NOTICE: Where we collect personal information directly from individuals in the EEA, we will inform them about the purposes for which we collect and use personal information about them, the types of non–agent third parties to which we disclose that information, the choices and meanswe offer individuals for limiting the use and disclosure of personal information about them, and how to contact us. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to us, or as soon as practicable thereafter, and in any event before we use or disclose the information for a purpose other than that for which it was originally collected.

Where we receive personal information from subsidiaries, affiliates or other entities in the EEA, we will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.

CHOICE:Where we collect personal information directly from individuals in the EEA we will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

For sensitive personal information, we will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. We will provide individuals with reasonable mechanisms to exercise their choices.

DATA INTEGRITY:We use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. We will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.

TRANSFERS TO AGENTS: We generally do not transfer personal information to our agents. If we do, we will obtain assurances from our agents that they will safeguard personal information consistent with this Policy. Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is required by the relevant Safe Harbor Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), being subject to Swiss Federal Act on Data Protection, Safe Harbor certification by the agent, or being subject to another European Commission or Swiss FDPIC adequacy finding (e.g., companies located in Canada). Where we have knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, we will take reasonable steps to prevent or stop the use or disclosure.

ACCESS AND CORRECTION: Upon request, we will grant individuals reasonable access to personal information about them. In addition, we will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.

SECURITY: We will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

ENFORCEMENT:From time to time we will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that we determine is in violation of this policy will be subject to disciplinary action up to and including termination of employment.

DISPUTE RESOLUTION: Any questions or concerns regarding the use or disclosure of personal information should be directed to us at the address given below. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information by reference to the principles contained in this Policy. For complaints that cannot be resolved between us and the complainant, weagree to participate in the following dispute resolution procedures in the investigation and resolution of complaints to resolve disputes pursuant to the Safe Harbor Principles:

1. for disputes involving all personal information received by us from Switzerland, we will cooperate with the Swiss FDPIC;

2. for disputes involving employment-related personal information received by us from the EEA, we will cooperate with the data protection authorities in the EEA and will participate in the dispute resolution procedures of the panel established by the European data protection authorities;

3. individuals who submit a question or concern to us and who do not receive acknowledgment of the inquiry, or who think their concern has not been satisfactorily addressed,or who otherwise wish to engage an independent recourse mechanism are encouraged to contact: Council of Better Business Bureaus, Inc., BBB EU Safe Harbor, 3033 Wilson Blvd, Suite 600 Arlington VA 22201

INTERNET PRIVACY

Weuse the Internet, and other technologies, as tools to communicate and interact with consumers, employees, customers, business partners, and others. We recognize the importance of maintaining the privacy of information collected online and have created a specific Internet Privacy Policy governing the treatment of personal information collected through web sites that we operate. With respect to personal information that is transferred from the European Economic Area or Switzerland to the U.S., our Internet Privacy Policy is subordinate to this Policy.

CONTACT INFORMATION

Questions or comments regarding this Policy should be submitted to us by mail to:

HRsoft; 2200 Lucien Way, Suite 201, Maitland, FL 32751 att: Chief Executive Officer

CHANGES TO THIS SAFE HARBOR PRIVACY POLICY

This Policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. A notice will be posted on the HRsoft web page (www.HRsoft.com) for 60 days whenever this Safe Harbor Privacy Policy is changed in a material way.

INTERNET PRIVACY POLICY

  • We understand and respect that your privacy is important to you.
  • We use and share personal information that you provide online only in ways that we tell you about.
  • We use commercially reasonable efforts to secure personal information that you provide online to prevent it from being used and shared for other purposes.
  • For more details, please read our Internet Privacy Policy below or contact us.

We are committed to collecting, maintaining, and securing personal information about you in accordance with this policy, as well as applicable laws, rules and regulations. This policy applies to personal information (as defined below) collected from online resources and communications (such as Web sites, e-mail, and other online and downloadable tools) that display a link to this policy.

This policy is consistent with our Safe Harbor Privacy Policyfor transfers of personal information from the European Economic Area and from Switzerland to the United States.

Should you have any questions about this policy or our data collection, use and disclosure practices, please contact us.

PERSONAL INFORMATION

The term “personal information” as used throughout this policy, applies to any information or set of information that identifies or that is used by us to identify an individual.

We may collect information about your computer or other electronic device when you visit our Web sites and use our online resources. This information may include your Internet Protocol (IP) address, domain name, browser type, date and time of your request and information provided by tracking technologies such as cookies. If you use a mobile device to access our web sites and online resources, we also may collect information about your device, such as your device ID and device type, as well as usage information about your device and your use of our mobile Web sites and other mobile resources.

We may use other companies to deliver e-mail communications on our behalf or to place advertisements on other web sites. We do not control the tracking technologies used by these other companies.

In some cases, we may use tracking technologies in ways that identify you personally, but only after you have entered information such as a name or e mail address into a form or data field on our Web sites, or where we have registered you to use our online resources by providing a user ID and password based on information validated through other offline interactions with you. We may use tracking technologies to remember your personal preferences and selections, such as personal information that you have entered into data fields on our Web sites, answers that you have provided in response to our surveys, sections of our Web sites that you visit frequently, or to confirm whether you have read or clicked on certain e-mail communications we send to you so that we can make our communications more useful and interesting to you.

COOKIES: A cookie is a small data file that is sent by Web servers to your computer’s hard drive, where your Internet browser files are kept. Cookies enable Web sites to store small bits of information on your computer and retrieve that information at a later time.


USE OF PERSONAL INFORMATION:Generally, we collect personal information online as necessary to enable individuals to register for, customize and personalize certain of our online resources and communications. We mayuse personal information collected online to provide products, services and features and other resources that individuals have requested; for example, educational literature and related information about our business, e-mail programs, tools, quizzes, questionnaires, and surveys.

Consistent with the purposes identified and standards set within this policy and other applicable privacy notices that have been provided, in some cases we consolidate and use personal information that individuals share with us through various services and channels, such as the telephone, surveys, Web sites and other online resources and communications, in order to enhance the quality of services that we offer.

CHOICES ABOUT COLLECTION AND USE: You have four categories of choices regarding the collection and use of personal information. These include:

1. No personal information collection: You may choose not to provide any personal information online by electing not to enter any personal information into a form or data field on our Web sites, and by not using any personalized services provided by our online resources. However, some of our online resources are available only to individuals who provide personal information or who use personalized services.

2. Limitations and options regarding uses and disclosures for other purposes: Some of our online resources may request your permission to use and disclose personal information about you in order to add you to our contact lists and to identify and offer additional services and promotions that we believe you might find interesting. You can limit the use of personal information about you by checking or un-checking options provided at the time that you enter that information or that we may offer to you in the future.

3. Limitations on tracking: Our online resources that use tracking technologies, such as cookies, to remember your personal preferences and selections, enable you to choose whether you want us to use such technologies to remember you, or to provide additional services to you, by checking or un-checking options provided during registration, or at the time that you enter personal information into forms or data fields. Our online resources do not limit non-identifiable uses of tracking technologies for individual users. Individual users can control the use of certain tracking technologies, such as cookies, through most Internet browsers. If you limit or disable cookies, certain functions of our Web sites may not work properly, including access to some of our registration-based Web sites.

4. E-mail communications: You may choose to receive optional e-mail and other communications from us by signing up for or subscribing to these communications on our Web sites and other online resources. If you do not wish to receive optional e-mail communications, you may opt-out by visiting the web site or other online resources where you subscribed, where available, and update your e-mail communication selections.

ACCESS: Personal information about you will be accessible to us and our subsidiariesand to individuals and organizations that use personal information solely for and at the direction of us. Uses and disclosures of personal information by external individuals and organizations acting on our behalf are governed by agreements that require personal information to be protected appropriately.

SHARING OF PERSONAL INFORMATION: In general, we do not sell or share personal information about you except as described in this policy and other applicable privacy notices.

SECURITY: We will take reasonable steps to protect personal information as it is transmitted from your computer to our online resources and servers, as well as to protect personal information in its possession from unauthorized access, disclosure, alteration or destruction. It is your personal responsibility to secure your own copies of your passwords and related access codes for our online resources.

THE PRIVACY OF CHILDREN: In general, our Web sites are not directed at children and most of the online services that we offer are designed for individuals who are 18 years of age or older.

CORRECTING INFORMATION: To gain access to personal information about you collected online, and to keep it accurate, complete and current, you may contact us at the address below.

Contact address for privacy questions: HRsoft; 2200 Lucien Way, Suite 201 Maitland FL 32751 Att: Chief Executive Officer