Scherzer Inernational | Privacy Policy

last revised: September 2011

Scherzer International Privacy Policy

Scherzer International ("SI", "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, do not use the Site.

SI reviews its privacy practices on a regular basis, and those practices are subject to change. We ask that you periodically review this page to ensure continuing familiarity with the most current version of the Policy. You can determine when this Policy was last revised by checking the "Last Revised" legend at the top of the Policy. To contact SI about privacy issues, to report a violation of the Policy or to raise any other issue, e-mail us at privacy@scherzer.com.

This Policy is the sole authorized statement of SI'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 SI, shall not be relied upon in substitute for this Policy, and neither supersede nor modify this Policy.

Our Background investigations

SI is a leading provider of background investigation reports. We provide a variety of targeted investigation products, including prospective client/client continuation reports, business background reports, credit/underwriting reports, green industry reports, asset/encumbrance reports, board of directors background reports, pre-employment reports for various position levels and international background investigation reports (collectively, our ÏSearch ServicesÓ). A complete description of our products is posted on our Web site.

The Information We Collect

SI collects personally identifiable information (that is, information from which an individual can be identified, such as full name, e-mail address, physical address, Social Security number, employment history and other information that both individuals and entities choose to provide to us. We collect some of this data through our password protected client-access Web site, and we transmit data to and from individuals and entities by e-mail, through our Web site and in some cases through external, third-party Web sites. We also collect information from our clients and others in the course of the various Search Services that we provide, and by conducting research using the Internet and other resources.

We do not knowingly collect personally identifiable information from children (that is, minors younger than 18 years of age).

Use and DisclosURE OF the Information We Collect

We only use the information that we collect for the purposes for which it is provided and to enhance our Search Services. The following describes the specific ways in which we may use personally identifiable data and other information. These descriptions are examples, and should not be considered 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 databases, including court records.

• Refining our Search Services. We may use information that we collect about employment 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 our data. We may contact you occasionally to ensure that the information we have collected about you is accurate and current.

• Responding to inquiries. If you contact us by e-mail 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. Periodically, we may send informational or promotional e-mails concerning our services.

• Disclosure to service providers. We work with third parties which provide services that may include, but are not limited to, assessment services, including validation services, Web site hosting, data analysis, resume verification, background checking and other administrative, 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.

• Compliance and emergencies. Subject to the 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 SI, 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 SI or from other independent sources.

The Site may contain links to other Internet Web sites. Unless expressly stated otherwise, we are not responsible for the privacy practices or the content of these Web sites, including these sitesÌ 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 the Fair Credit Reporting Act ("FCRA") and other 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.

SAFE HARBOR

SI complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. SI has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view SI's certification, visit http://www.export.gov/safeharbor/

Tracking Data

SI 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 visitorÌs 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 Ïclicked.Ó

SI 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. SI cookies are only read by SI 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).

CERTAIN SENSITIVE DATA

From time to time, we encounter various forms of sensitive data which may or may not be relevant to the searches we perform, even though we may not have designed our search criteria to reveal the data. For example, while searching for court records we may discover that records have been sealed or expunged or we may be afforded access to these records or we may encounter divorce, custody or juvenile records. In some instances, we may find evidence of third party claims, such as lis pendens, mechanics liens and the like or of minor civil violations. We treat this information on a case-by-case basis. Absent a specific request from a client, it is our general policy not to include these records in our reports because they are either irrelevant to the investigation or ambiguous as to a personal involvement, fault or culpability. However, this information may remain in our files for some period of time. If a client requests the information, then we will deliver it, if we are legally permitted to do so.

Additional Guidelines

SI may occasionally 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

SI has security measures in place to protect against the loss, misuse and alteration of personal information which is under our control. When we transmit personally identifiable information to our suppliers, we attempt to do so in a secure manner.

Offline vs. Online Practices

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