Brintnall & Nicolini, Inc. (“Brintnall & Nicolini”) has certified to the Safe Harbor Agreement between the United States and the European Union, with respect to personal data processed as part of our market research activities.  Accordingly, Brintnall & Nicolini adheres to the Safe Harbor privacy principles and frequently asked questions, as agreed to by the U.S. Department of Commerce and the European Commission.

Scope

This Safe Harbor Privacy Policy sets forth how Brintnall & Nicolini handles personal data transferred from countries in the European Economic Area (EEA) to the United States that are collected or received in conducting our market research activities.

Definitions

The following terms are used throughout this document and are defined here for clarification.

Agent  

“Agent” means a third party that processes personal data solely on behalf of and under the instructions of Brintnall & Nicolini.

Personal data

“Personal data” means any information or set of information that identifies or can reasonably be used to identify an individual.  Personal data do not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.

Sensitive personal data

"Sensitive personal data" means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns health or sex life.  Information will be treated as sensitive personal data where it is received from a third party that treats and identifies it as sensitive.

Privacy Principles

The following privacy principles apply to the collection, use and disclosure of personal data by Brintnall & Nicolini in conducting market research activities.

Notice

Brintnall & Nicolini will inform individuals about the purposes for which we collect and use personal data about them, how to contact us, the types of non-agent third parties with whom we may share personal data, and any ways that individuals may limit the use and sharing of such data.  This notice will be provided when individuals are first asked to provide personal data or as soon thereafter as is practicable.

Choice

Brintnall & Nicolini will offer an individual the opportunity to choose (opt out) whether personal data are (a) shared with a non-agent third party or (b) used for a purpose other than that for which the data were originally collected or subsequently authorized by the individual. 

For sensitive personal data, Brintnall & Nicolini will give an individual an affirmative or explicit (opt in) choice if the information is to be disclosed to a third party or used for a purpose other than those for which it was originally collected or subsequently authorized by the individual. 

Access

Brintnall & Nicolini will provide individuals with reasonable access to personal data about them and they may request the correction or amendment of personal data that they demonstrate to be incorrect or incomplete.

Transfers to Agents

Brintnall & Nicolini will only transfer personal data to an agent where the agent has provided assurances that the agent provides at least the same level of privacy protection as is required by these privacy principles.  Where we have knowledge that an agent is using or sharing personal data in a way that is contrary to these principles, Brintnall & Nicolini will take reasonable steps to prevent or stop such processing.

Onward Transfer

Brintnall & Nicolini will only transfer personal data to a non-agent third party where consistent with the notice provided to the individuals who are the subject of the data and any consent that those individuals have given.

Information Integrity

Brintnall & Nicolini will only use and share personal data about individuals in a way that is consistent with the purposes for which the data were collected or subsequently authorized by those individuals.  To the extent necessary for those purposes, Brintnall & Nicolini will take reasonable steps to ensure that the data are accurate, complete, and current.

Information Security

Brintnall & Nicolini will take reasonable precautions to protect personal data from loss, misuse and unauthorized access, disclosure, alteration and destruction.

Enforcement

Brintnall & Nicolini has put in place mechanisms to verify our ongoing adherence to these privacy principles.  We encourage individuals covered by this Policy to raise any concerns that they have about the way that we process their personal data by contacting us at the address below, and we will do our best to resolve them.  We have also agreed to participate in the dispute resolution program provided by the European Data Protection Authorities Panel.

Limitation on Scope of Principles

Adherence by Brintnall & Nicolini to these privacy principles may be limited to the extent required to meet a legal, governmental, national security or public interest obligation.

How to Contact Us

Please contact us with any questions about the way in which we use personal data. 

Privacy Officer

Phone: (215) 854-4200

Fax: (215) 854-8448

privacy_officer@brintnall.com

Changes to this Policy

This Policy may be amended from time to time, consistent with the requirements of the Safe Harbor.  When we do, we will also revise the “last updated” date at the bottom of this Policy.  For material changes to this Policy, we will notify individuals by placing a notice on the following Web site:  www.brintnall.com.

Last Updated: March 10, 2008