last revised: april 25, 2006

Scherzer International Privacy Policy

Scherzer International (“Scherzer,” “we, “us”) shares your concerns about the protection of your personal information, whether it is collected online or by other means. This Privacy Policy (the “Policy”) describes our practices regarding the collection and use of information in the United States, whether through our web site located at www.scherzer.com (collectively, the “Site”) or through off-line contact with individuals and entities. By using the Site, you signify your agreement to the terms and conditions of this Policy. If you do not agree to this Policy, please do not use the Site.

Please note that Scherzer reviews its privacy practices from time to time, and that those practices are subject to change. We ask that you bookmark and periodically review this page to ensure continuing familiarity with the most current version of our Privacy Policy. You can determine when this Policy was last revised by checking the “Last revised” legend at the top of the Policy. To contact Scherzer about privacy issues, to report a violation of our Privacy Policy or to raise any other issue, please e-mail us at privacy@scherzer.com.

This Policy is the sole authorized statement of Scherzer's practices with respect to the online and offline collection of personally identifiable information and the usage of such information. Any summaries of this Policy generated by third party software or otherwise (for example, in connection with the "Platform for Privacy Preferences" or "P3P") shall have no legal effect, are in no way binding upon Scherzer, shall not be relied upon in substitute for this Policy, and neither supersede nor modify this Policy.

Our Background investigations.

Scherzer is a leading provider of background investigation search reports. We provide a variety of targeted investigation products, including litigation assistance reports, key vendor reports, specialized risk reports, corporate governance reports, prospective client reports, credit/underwriting risk reports, money manager reports, pre-employment reports at various levels and corporate management and financial reports (collectively, our “Search Services”). Please review the information on our Site for a complete description of our services, or contact us for additional information.

The Information We Collect.

Scherzer collects personally identifiable information (that is, information from which an individual can be identified, such as full name, email address, physical address, Social Security Numbers, employment history and other information that both individuals and entities choose to provide to us. Currently, we do not collect this data through our web site, but we do transmit data to and from individuals and entities by email and other internet links. We also collect information from our clients and others in the course of the various Search Services that we provide, as well as by conducting research using the Internet and other resources.

We do not knowingly collect personally identifiable information from children (that is, minors younger than eighteen years of age).

How We Use and Disclose the Information We Collect.

We generally use the information that we collect for the purposes for which it is provided and to enhance our Search Services. The following paragraphs describe various specific ways in which we may use personally identifiable and other information. These descriptions are examples, and should not be considered as a complete list of the ways in which we may use or disclose information we have collected.

(1) Background Information

· Checking Resumes and Other Background Information. We use information that we have collected concerning individuals and entities to check their representations in resumes and in other contexts to verify educational, employment and other data and to obtain information from public data bases, including, on occasion, court records.

· Providing data to clients and references. We generally provide personally identifiable information regarding candidates to our clients or reference sources only if the candidate has requested or otherwise consented that we do so. However, on rare occasions we are engaged to conduct highly confidential searches, and on those rare occasions, information may be provided to the client without the individual’s or entity’s prior request or knowledge.

· Refining our Search Services. We may use information that we collect concerning candidates for purposes of developing and improving our Search Services, and for purposes of collecting and disclosing statistical information regarding our activities.

(2) Client Data. We collect information pertaining to our clients, including business contact information, and retain and use such information in providing our Search Services

(3) Other Uses of Information.

· Updating your data. We may contact you from time to time to ensure that the information we have collected about you is accurate and current.

· Responding to inquiries. If you contact us by email through the Site or otherwise, we may keep a record of your contact information and correspondence, and we may use any information you provide in your message to respond to your inquiry.

· Other communications. Scherzer may send from time to time informational or promotional e-mails concerning its services.

· Disclosure to service providers. Scherzer works with third parties who provide services that may include, but are not necessarily limited to, assessment services, including assessment validation services, web site hosting, data analysis, resume verification, background checking and other administrative and back-up and security services. We reserve the right to share personally identifiable and other information with such third parties for the purpose of providing their services. In addition, our software development partners may use such information for purposes of modifying, improving, refining and validating their technology, and research and development.

· Disclosure to affiliates. We share the information that we collect with our affiliated companies and we may share the information that we collect with our strategic partners.

· Compliance; emergencies. Subject to applicable law, we reserve the right to use and release any information that we have collected when we believe in good faith that the law requires it, that unlawful activity may have taken place, to enforce our other policies or published guidelines, to protect the rights, property, safety or security of Scherzer, our visitors or the public, or to respond to an emergency.

Use of Data by Clients and Others.

We cannot and do not assume any responsibility for the actions or omissions of third parties, such as clients, service providers or strategic partners, including the manner in which they use information received either from Scherzer or from other independent sources.

The Site may contain links to other Internet web sites. Unless otherwise expressly stated, we are not responsible for the privacy practices or the content of these web sites, including these sites’ use of any information collected through cookies or other technologies when visitors to our site click through links to those sites. You should review the privacy policies associated with these other sites to understand how their operators collect and use information. THIS POLICY DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES.

Compliance with Law

Certain of our activities require us to comply with fair credit reporting and other similar laws. Some of those laws may require that we observe privacy restrictions beyond those specifically stated in this Policy. When these laws apply, we undertake our activities in conformance with their requirements and, if the privacy restrictions conflict in any way with these guidelines, we abide by the stricter requirements of the relevant laws, rules and regulations.

Tracking Data.

Scherzer monitors visitor traffic patterns throughout the Site by logging Tracking Data, which is collected automatically from each Site visitor. Tracking Data may include information such as the IP address of the visitor’s computer, its browser type and operating system, the referring site, which pages of the Site were visited, the order in which they were visited and which hyperlinks were “clicked.”

Scherzer uses Tracking Data and other non-personally identifiable information in aggregate form to perform statistical analyses of the collective characteristics and behavior of our visitors, and by measuring demographics and interests regarding specific areas of the Site. We may provide this information to affiliates, current and potential clients, and other business partners.

Cookies.

We use “cookies” — that is, small text files placed on a visitor’s computer hard drive — and other technologies to help us determine information such as the type of content to which a visitor to the Site links, and the length of time each visitor spends at any particular area of the Site. Scherzer cookies are only read by Scherzer servers and are unable to execute any code or virus.

You can configure your browser to accept all cookies, reject all cookies or notify you when a cookie is set. (Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences).

Additional Guidelines.

Scherzer may from time to time sponsor special features or promotions on the Site and additional privacy information may be posted. That privacy information, to the extent it conflicts with this Policy, will govern that particular feature or promotion.

Security.

Scherzer has security measures in place to protect against the loss, misuse and alteration of personal information which is under our control. Unfortunately, however, no security system, or system of transmitting data over the Internet, can be guaranteed to be 100% secure. As a result, while we strive to protect your personally identifiable information, we cannot guarantee the security of our servers, the means by which information is transmitted between your computer and Scherzer's servers or between Scherzer’s Computers and our clients, or any information provided to us or to any third party through or in connection with the Site.

Business Transfers.

Scherzer reserves the right to transfer, without your further consent, any and all information that we collect from visitors, or that we otherwise collect concerning the Site, to a third party in connection with a strategic alliance with such third party, or in the event of a sale of our company or one of our affiliates, a merger or consolidation involving Scherzer or one of its affiliates, or a sale or transfer of assets or of any portion of our business or the business of one or more of our affiliates.

Offline vs. Online Practices.

Please note that this Policy applies both to our online and offline information-gathering and dissemination practices in the United States. We operate exclusively within the United States and have no offices or representatives outside the United States. If we have a need to obtain information from sources outside the United States, we access the sources from within the United States or contract with independent third parties to obtain the information.

Questions?

Questions regarding this Policy should be directed to Scherzer at privacy@scherzer.com or, if by postal mail, at Scherzer International; 6351 Owensmouth Ave Suite 213 Woodland Hills, CA 91367, Attn: Privacy Coordinator.