Scope of Safe Harbor Certification and this Notice.

ProfitLine, Inc. (hereinafter "ProfitLine" or "we") recognizes that the European Community has established a data protection regime pursuant to Directive 95/46/EC (the "Directive"), which applies to the European Economic Area ("EEA"), and that Switzerland has established a data protection regime pursuant to the Federal Act on Data Protection ("FADP"), which regimes restrict companies in the EEA and Switzerland (collectively, "EEA/CH") in transferring personal data about individuals in the EEA/CH to the United States, unless there is "adequate protection" for such personal data when it is received in the United States. To create such "adequate protection" and to overcome the restriction on international data transfers established by the Directive and the FADP, ProfitLine adheres to the Safe Harbor Privacy Principles published by US Department of Commerce ("Safe Harbor Principles") with respect to personal data about individuals in the EEA/CH ("EEA/CH Persons") that customers and other businesses, e.g., customers' procurement managers, customers' employees, etc., in the EEA/CH send to ProfitLine. This Notice does not apply to employees of ProfitLine, as ProfitLine has issued a separate Safe Harbor Notice for European Employees. Information on ProfitLine's practices regarding data received through websites is contained in the applicable website privacy statements, if any. More information on the Safe Harbor Principles and ProfitLine's scope of participation is available at www.export.gov/safeharbor.

Categories of EEA/CH Data.

ProfitLine provides outsourced telecom expense management solutions to mostly large enterprises and government agencies, but rarely to individual consumers. Thus, ProfitLine receives mostly business-related information from the EEA/CH. ProfitLine also receives and processes, in connection with our services, data that may relate to EEA/CH residents on behalf of, and in accordance with instructions from, customers (collectively "EEA/CH Data"). Since EEA/CH Data covered by this Notice is by definition sent to ProfitLine by another company in the EEA/CH (e.g., a customer of ProfitLine's), the categories of data sent and the purposes of processing often depend on such other company, with whom the EEA/CH Persons typically have a closer employment, business or other relationship (and which therefore, can provide additional information on categories of data shared with us).

Purposes.

ProfitLine collects and uses EEA/CH Data for purposes of providing telecom expense management solutions to its customers, processing EEA/CH Data on behalf of corporate customers, communicating with corporate business partners about business matters, transmitting marketing emails and performing other marketing activities, and conducting related tasks for legitimate business purposes.

Disclosure.

ProfitLine shares EEA/CH Data with affiliates and contractors, which process EEA/CH Data on behalf of ProfitLine. ProfitLine also shares EEA/CH Data with other third parties for the purposes for which ProfitLine receives the EEA/CH Data (e.g., performance of contractual obligations) and as required or permitted by law.

With respect to marketing emails, EEA/CH Persons may opt-out of receiving further email marketing communications from ProfitLine by sending an email to optout@profitline.com or by following opt-out instructions that are contained in each marketing email. EEA/CH Persons may also send an email to this address to ask to opt-out of disclosures to third parties, but such a limitation on data sharing may make it difficult or impossible for ProfitLine to provide the requested services. Notwithstanding other statements in this General Safe Harbor Notice, ProfitLine may disclose EEA/CH Data where it is legally required to disclose (e.g., under statutes, contracts or otherwise) or the disclosure is permitted by law and ProfitLine has a legitimate business interest in such disclosure.

Access and Review.

EEA/CH Persons whose EEA/CH Data ProfitLine holds may request access to, and the opportunity to update, correct or delete some or all of the EEA/CH Data that ProfitLine holds about them. To submit such requests or raise any other questions, please contact the ProfitLine Safe Harbor Contact as described below. ProfitLine reserves the right to take appropriate steps to authenticate an applicant's identity, charge an adequate fee before providing access and deny requests, except as required by the Safe Harbor Principles.

Safe Harbor Contact.

If you have questions, please contact our ProfitLine Safe Harbor Privacy Contact:

ProfitLine, Inc.
9920 Pacific Heights Blvd
Suite 200
San Diego, CA 92121
Attn: IT Security Office

Voice: +1.858.452.6800
Fax: +1.858.452.6998
Email: itsecurity@profitline.com

If you have a comment or concern that cannot be resolved with ProfitLine directly, you may contact the competent local data protection authority in your EEA/CH Member State.
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