WorkforceLogic, LLC
Safe Harbor Privacy Policy

POLICY STATEMENT

To provide an adequate level of protection for personal data received from the European Union, WorkforceLogic, LLC (“WFL” or “the Company”) adheres to the seven Safe Harbor Principles developed by the United States Department of Commerce and the European Commission. This Safe Harbor Privacy Policy (the “Policy”) sets forth the privacy principles that WFL follows when processing personal data received from the E.U. The privacy principles in this Policy are based on the seven Safe Harbor Principles referenced below.

POLICY GUIDELINES

1. Notice: The Personal Data We Collect;
   How And Why We Collect It
   WFL receives personal data from the E.U. to facilitate the recruitment and hiring of job applicants by staffing suppliers, and if an applicant is hired, to assist in the administration of certain aspects of the employment relationship between the staffing supplier and the employee, such as compensation and leave. The personal data that WFL receives from the staffing supplier consists principally of information provided by the job applicant, and if hired, by the employee. This information includes contact information, resume or job history, days and hours worked, leave time, and, when permitted by applicable law, government-issued identification number. The staffing supplier may provide WFL with additional personal data, such as whether the job applicant did or did not successfully complete a background check (if permitted by applicable law) or a reference check, information concerning the job applicant’s interview and negotiations over pay rate, and, if hired, the employee’s pay rate, if hired. WFL does not currently collect “sensitive personal data,” e.g., data concerning nationality or ethnic origin, health, trade union membership, religious or political belief, or sex life.
   
   The staffing supplier generally will provide the job applicant with a notice concerning the processing of personal data. WFL will not use or disclose personal data transferred from an E.U. Member State to the United States for any purpose which has not been previously disclosed to the data subject unless: (a) the data subject has received notice and an opportunity to exercise choice, as described below, with respect to such use or disclosure; or (b) applicable law permits the use or disclosure without requiring that WFL first comply with the Notice and Choice Principles.
2. Choice: How To Opt Out Of Collection Of Your Personal Data And Transfer To Third Parties
   The staffing supplier who transfers personal data to WFL typically is recruiting and hiring personnel on behalf of a third party who is a WFL customer. This WFL customer will access and use the personal data received by WFL from the staffing supplier to participate in the recruiting and hiring process. The WFL customer also may use the information to manage headcount. WFL will permit its customer to access and use personal data only after the data subject has received notice of the customer’s involvement in the recruiting and hiring process. Data subjects may choose not to have their personal data disclosed to WFL and to WFL’s customer by declining to participate in the recruitment and hiring process.
   
   WFL also will, either directly or through the staffing supplier, offer data subjects in the E.U. whose personal data has been transferred to the United States the opportunity to opt out from: (a) the disclosure of personal information to a non-agent third party (in addition to WFL’s customers); and (b) the use or disclosure of their personal data for a purpose other than the purpose for which the information originally was collected or subsequently authorized by the data subject. If WFL does collect “sensitive personal data,” WFL will, directly or through the staffing supplier, provide notice and will request the data subject’s affirmative consent before disclosing such information to a non-agent third party and before using such information for a purpose other than the purpose originally disclosed.
   
   WFL, either directly or though the staffing supplier, will provide readily available, and affordable mechanisms to data subjects to exercise these choices.
3. Onward Transfer: Third Parties To Whom We May Disclose Your Personal Data
   WFL may forward, or permit access to, the personal data that it receives from a staffing supplier to a third party who is a WFL customer and for whose benefit the staffing supplier collected the information. WFL will comply with the Notice and Choice Principles before transferring personal data to its customers. WFL will take reasonable steps to ensure that any such party that receives personal data will maintain its privacy and confidentiality.
   
   WFL may forward, or permit access to, the personal data that it receives from a staffing supplier to an authorized third-party representative or subcontractor of WFL (e.g., service providers that help host or support WFL’s web site, or that otherwise provide technical assistance, or other professional services). Such third parties will receive only the personal information they need to deliver to WFL (for the benefit of WFL’s customer) the requested product or service, they will be prohibited from using the personal data for any other purpose; and they will be required to maintain commercially reasonable security measures to protect the confidentiality and security of that personal information. If WFL learns that an agent is using or disclosing personal information in a manner contrary to this Policy, WFL will take reasonable steps to prevent such use or disclosure.
   
   Disclosures to third parties, whether an agent of WFL or not, will be only for the purposes described in the section under “Notice” or for a compatible purpose.
4. Security For Your Personal Data
   WFL is committed to safeguarding the personal data that it receives from staffing suppliers. WFL takes reasonable precautions to protect the personal data in the Company’s possession from loss, misappropriation, and unauthorized access, disclosure and destruction.
   
   WFL utilizes a combination of online security technologies and organizational measures to help safeguard personal information. WFL employs Secure Socket Layer (SSL) data encryption when data is transmitted over the Internet to WFL. WFL has installed layered firewalls and other security technologies to help prevent unauthorized access to our systems. Strong password protection protocols are used on computers, and employees are kept up-to-date on our security and privacy policies. Electronic security measures continuously monitor access to our servers and provide protection from hacking or other unauthorized access. WFL limits access to personal data to those who have a specific business reason for accessing such personal information. Individuals who have been granted access to personal information will be made aware of their responsibilities to protect such information and will be provided training and instruction on how to do so.
5. Data Integrity: How We Limit The Collection And Retention Of Your Personal Data
   WFL collects only personal data that is necessary for the purposes listed under the section on “Notice.” WFL will use the personal data only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the data subject. WFL takes reasonable steps to ensure that the information it collects is accurate, complete, current, and reliable for its intended use. WFL will retain personal data only for as long as is necessary to accomplish its legitimate business purposes or for as long as may be required by applicable law.
6. Access And Correction: How You Can Exercise
   Your Rights
   Upon reasonable request and in accordance with applicable local law, WFL will grant data subjects reasonable access to their personal data and will permit them to correct, amend or delete personal data that is inaccurate or incomplete. Data subjects who wish to review or update their personal data can do so by contacting WFL’s Chief Financial Officer at 19080 Lomita Ave, Sonoma, California 95476 or by calling (707) 935-6113. WFL may, in its discretion, charge a reasonable, cost-based fee for access or photocopying. For security purposes, WFL may require verification of identity before providing access to personal information.
7. Enforcement: What To Do If You Have a Complaint
   WFL will conduct periodic self-assessments of its relevant practices to verify adherence to this Policy and the Safe Harbor Principles. Any employee who intentionally violates this Policy will be subject to disciplinary action. Any data subject who has a complaint concerning WFL’s processing of his or her personal data should contact WFL’s Chief Financial Officer at 19080 Lomita Ave, Sonoma, California 95476 or call (707) 935-6113. WFL will investigate and attempt to resolve such complaints in accordance with the principles contained in this Policy. Any data subject who is not satisfied with the internal resolution of the complaint may seek redress with the national data protection or labor authority where the data subject resides. In the event the employee chooses to file a complaint with a national data protection authority, WFL will cooperate in investigations by, and comply with the advice of, competent E.U. authorities.

CHANGES TO THIS PRIVACY POLICY

WFL may revise this policy from time to time as we add new products and services. If we decide to materially change this Policy, we will post the revised policy at this location. If at any point we decide to make any material changes in the way we use your personal data, we will make that information available by posting a notice on this site and we will provide data subjects with choice as to whether or not we use their information in this different manner.

CONTACT INFORMATION

For more information about this Policy, please contact: WFL’s Chief Financial Officer at 19080 Lomita Ave, Sonoma, California 95476 or call (707) 935-6113.

EFFECTIVE DATE: February 2009