SAFE HARBOR PRIVACY POLICY

LuciData Inc. respects individual privacy and values the confidence of its customers, employees, consumers, business partners and others. Not only does LuciData Inc. strive to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business, but it also has a tradition of upholding the highest ethical standards in its business practices.

LuciData has joined the U.S. Department of Commerce’s “Safe Harbor” program with respect to personal information collected from consumers who reside in the European Union and Switzerland.  We adhere to the seven Safe Harbor Privacy Principles as explained more fully in the following policy.  Additional information related to the Safe Harbor program can be found by visiting the U.S. Department of Commerce’s Safe Harbor website at www.export.gov/safeharbor.

NOTICE:  LuciData does not typically collect personal information directly from individuals in the European Union and Switzerland.  Personal information may exist in Electronically Stored Information that is received by LuciData for processing.  To the extent permitted, we reserve the right to process personal information in the course of providing electronic discovery and other services to our clients without the knowledge of individuals involved.  In cases where LuciData collects personal information directly from custodians in the European Union and Switzerland, we will inform the individual of the purpose for which it collects and uses the Personal Information the types of non-agent third parties to which LuciData discloses or may disclose that information.  LuciData 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 LuciData, or as soon as practicable thereafter, and in any event before LuciData uses or discloses the Information for a purpose other than for which it is originally collected.

CHOICE:  LuciData 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, LuciData 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. LuciData will provide individuals with reasonable mechanisms to exercise their choices.

ONWARD TRANSFER:  Prior to disclosing Personal Information to a third party, LuciData shall notify the individual of such disclosure and allow the individual the choice (opt out) of such disclosure.  LuciData shall ensure that any third party to 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.

SECURITY:  LuciData will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.  LuciData 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.  LuciData cannot guarantee the security of Information on or transmitted via the Internet.

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

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

ENFORCEMENT:  LuciData will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy.  Any employee that LuciData determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.  Any questions or concerns regarding the use or disclosure of personal information should be directed to the LuciData Privacy Office at the address given below. LuciData 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.  LuciData has further committed to refer unresolved privacy complaints under the US-EU and US-Swiss Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by LuciData, please visit the BBB EU SAFE HARBOR web site at www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.

CONTACT INFORMATION:  Questions or comments regarding this Policy should be submitted to the LuciData Privacy Office by mail to:

          LuciData Privacy Office
          LuciData Inc.
          50 South Sixth Street, Suite 1410
          Minneapolis, MN  55402 (E-mail to info@lucidatainc.com)

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 LuciData web page (/index_page_id_467.html).

EFFECTIVE DATE: May 01, 2012