Safe Harbor Privacy Policy

Introduction

Valtech and its subsidiaries comply with the requirements of the US-EU Safe Harbor Framework and the US-Swiss Safe Harbor Framework established by the US Department of Commerce with respect to personally identifiable information (PII) within the scope of the Valtech Entities Safe Harbor certification that is transferred from the European Economic Area or Switzerland to the United States. The Valtech Entities adhere to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access and enforcement with respect to such PII.

Certain types of PII may be subject to more specific privacy requirements, which are consistent with the Safe Harbor requirements. For example:

PII obtained from or relating to clients or former clients of any of the Valtech Entities is subject to the terms of any contractual arrangements with the client, applicable laws and professional standards.

PII about personnel of any of the Valtech Entities is subject to internal personnel privacy policies, which are available to such personnel.

Certain websites of the Valtech Entities may have their own privacy policies, accessible on their respective websites, regarding the collection and use of PII by those websites.

For further information about the Safe Harbor Program, see the US Department of Commerce website at http://www.export.gov/safeharbor/.