Oceanos Privacy Policy

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OVERVIEW

Oceanos balances privacy rights with its legitimate business needs to collect, maintain, and communicate information, both internally and externally. The intent of our Privacy Policy is to define a high standard of protection for personally-identifiable information (hereafter referred to as "personal information").

Oceanos aims to comply with the applicable laws and regulations protecting the privacy of personal information in the jurisdictions in which the Company operates. Where appropriate, laws within specific jurisdictions may require supplemental terms to comply with local laws.

SCOPE

This policy applies to personal information that is processed by Oceanos, and may be supplemented by communications from the Oceanos Legal Department. All associates, clients, prospects, employees, workers and other individuals whose responsibilities include the processing (e.g. collection or storage) of personal information are expected to protect such data by adherence to this policy.

Oceanos complies with the Safe Harbor Agreement concerning the transfer of Personal Information from the European Union and Switzerland to the United States of America. When collecting Data Subject Personal Information during the provision of our Services, we follow the privacy principals of and comply with the requirements of the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework established by the U.S. Department of Commerce, regarding the collection, use and retention of Personal Information from the European Union and Switzerland.

To learn more about the Safe Harbor program, and to view Oceanos certification, please visit http://www.export.gov/safeharbor/. Oceanos may amend this policy should it become necessary or advisable to do so.

GENERAL DEFINITIONS

(Please note that the definitions could be slightly different in local data-protection laws.)

"Agent" refers to a third party that processes personal information solely on behalf of and under the instructions of Oceanos.

"Associate(s)" refers to any employee of Oceanos. "Oceanos" or "The Company" equates to Oceanos Marketing, Inc.

"Data Subject" refers to the user of the Oceanos service.

"Personal Information" is any information relating to an identified or identifiable natural person recorded in any medium (e.g. PDA, computer, paper). It includes information such as name, address, title, topics of interest, and communication preferences (fax, e-mail, phone, etc). It also includes certain highly sensitive information about an individual, such as religion, dietary requirements, race, sexual orientation, health and political beliefs. Additional safeguards apply in the case of sensitive personal data (see below).

"Processing" translates to any operation which is performed upon personal information, via manual or automatic means, such as collection, recording, organization, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination (or otherwise making available), alignment, combination, blocking, erasure and destruction.

"Third party" is any natural or legal person, public authority, agency or any other body other than the Data Subject, Oceanos, or agents.

COLLECTION AND USE

Oceanos processes personal information in a reasonable and lawful manner for relevant and appropriate purposes. Personal information shall not be processed in a way which is incompatible with such purposes and will be kept for no longer than necessary for the purposes for which it was collected.

Due to the nature of Oceanos business, services and benefits are not marketed to minors. Oceanos does not knowingly attempt to solicit or receive any information from children.

Oceanos collects information at several different points, including but not limited to the following:

Employment

Associates and candidates for employment must provide personal information related to recruiting and hiring, and once employed, to process, tax, compensation, benefits, and other employment-related functions.

Registration for Oceanos web sites

When Data Subjects register on Oceanos web sites, or for Oceanos events, or purchase products, Oceanos requests personal information. Oceanos may use this personal information to provide advice and service, as well as to provide offers deemed relevant by Oceanos. In circumstances where data processing is not permitted under local law, Oceanos will request explicit consent from Data Subjects. Oceanos may also contact Data Subjects regarding web site problems or other customer service-related issues.

Purchases and Fulfillment

When Data Subjects place an order or register for a Oceanos event, additional information such as credit card number and expiration date maybe be requested. This information is used for confirmation and billing purposes. The contact information provided is used to service the order. Also, when individuals register for an event, Oceanos may request additional information regarding hotel, meal and other travel preferences. This information is used only for the specific event.

Oceanos uses third-party service providers such as credit card processing companies, shipping companies, mailing houses and event coordinators together with other service providers as required to satisfy client requests. When Data Subjects register for a Oceanos event, Oceanos provides necessary information to hotels and to facilities hosting events. These parties are allowed to use that personal information only to provide services relevant to the event.

Usage Tracking

Oceanos may monitor how Data Subjects use its web sites including search terms entered, pages visited and documents viewed. For registered users, this information is stored within the registration information. It is unique-number identifiable, and is used solely for purposes of enabling Oceanos to provide users with a personalized web experience. Aggregated (not personally-identifiable) forms of this data may also be used in order to help Oceanos understand areas for future research and to identify worthwhile features and functions to develop for Oceanos web sites. This data may also be used by Oceanos, in the aggregate, to identify appropriate product offerings and subscription plans. This same data is also used by Oceanos clients to help them understand how their subscriptions are being used by their employees, and in this case, is personally identifiable to the specific client.

Cookies

Oceanos may employ a cookie, or small piece of computer code that enables web servers to "identify" visitors, each time an individual initiate a session on Oceanos web sites. A cookie is set in order to identify Data Subjects and determine user access privileges. Cookies do not store any of the personal information that is provided to the Oceanos web site; they are simply identifiers.

Data Subjects have the ability to delete cookie files from their own hard drive at any time. However, individuals should be advised that cookies may be necessary to provide access to much of the content and many of the features of Oceanos web sites. Oceanos uses cookie technology to enable registered users to move quickly and securely through access-controlled areas of the sites. Cookie technology also enables registered users to take advantage of certain useful features on the sites, including "remember my password."

Social Media

Generally, online social media resources are interactive tools that enable Data Subjects to collaborate and share information with others. Social media resources include but are not limited to: social networks, discussion boards, bulletin boards, blogs, wikis, and referral functions for sharing web site content and tools with a friend or colleague. Oceanos may collect personal information to enable Data Subjects to use online social media resources. Oceanos may also enable Data Subject to use these social media resources to post or share personal information with others. When using social media resources, Data Subjects should take into careful consideration what personal information they share with others. Oceanos provides additional notice and choices about how personal information is collected, used and disclosed on its web sites and other online resources that offer social media.

Mobile Computing

Some Oceanos web sites and online resources are specifically designed to be compatible and used on mobile computing devices. Mobile versions of Oceanos web sites may require that users log in with an account for a given web site. Information regarding the use of each mobile version of the web site will be associated with user accounts. Further, some of Oceanos's web sites and online resources enable individuals to download an application, widget or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools may transmit personal information to Oceanos to enable Data Subjects to access user accounts and to enable Oceanos to track use of these tools. Some of these tools may enable users to e-mail reports and other information from the tool. Oceanos may use personal or non-identifiable information transmitted to Oceanos to enhance these tools, to develop new tools, for quality improvement and as otherwise described in this policy or in other notices provided by Oceanos.

NOTICE

Oceanos notifies all identified Data Subjects about (i) the purposes for which personal information is collected and processed, (ii) the types of Third Parties to which personal information is disclosed, and (iii) the rights under this policy (a) when collecting personal information, (b) when personal information is processed for a purpose other than its original purpose or the purpose authorized subsequently by the Data Subject and (c) upon request.

In certain situations, data is "unidentified" so that the names of the Data Subjects are not known by data processors within Oceanos. In these cases, Data Subjects do not need to be notified.

CHOICE

Oceanos gives each Data Subject the opportunity to opt-out from (i) allowing Oceanos to disclose his/her personal information to a third party unless the disclosure is required by law or for the fulfillment of a contractual obligation (e. g. employment contract), and (ii) allowing Oceanos to process personal information for a purpose other than its original purpose or the purpose authorized subsequently by the Data Subject. An "Unsubscribe" button will be provided at the bottom of each e-mail communication sent by Oceanos so that a Data Subject can opt-out.

Prior to disclosing Sensitive Data to a third party or processing Sensitive Data for a purpose other than its original purpose or the purpose authorized subsequently by the Data Subject, Oceanos will obtain each Data Subject's explicit consent (opt-in).

With regard to personal information that Oceanos receives in connection with the employment relationship, Oceanos will use such personal information only for employment related purposes (e.g. tax, payroll, benefits). Where consent of the Data Subject for the Processing (mainly collection, use, or disclosure) of personal information is required by law or contract, Oceanos will comply with the law or contract.

ONWARD TRANSFER

Oceanos places substantial import on protecting the confidentiality of personal information and seeks the cooperation of all Associates in furthering this goal. Where local law requires a (written) agreement for the transfer of personal information to a third party, Oceanos will comply with local law.

There may also be instances where Oceanos may be required to share personal information with third parties who have not been retained (directly or indirectly). Many entities receiving personal information under these conditions have privacy requirements that apply to their handling of the information.

Oceanos endeavors to ensure that third parties will only transfer personal information to an agent where the agent has provided assurances that they will provide at least the same level of privacy protection as is required by this policy. Where Oceanos has knowledge that a third party or their agent is using or sharing Personal Information in a way that is contrary to this policy, Oceanos will take reasonable steps to prevent or stop such processing.

In addition, Oceanos web sites contain links to other web sites. Individuals should be aware that Oceanos is not responsible for the privacy practices of such other sites. Oceanos encourages users to be aware when they leave Oceanos sites and to read the privacy statements of each and every web site that collects personal information.

Oceanos does not sell, share or rent outside of Oceanos any personal information collected on Company web sites.

SECURITY

Oceanos maintains and implements an information security program that includes appropriate administrative, technical and physical safeguards and other security measures that are designed to: (a) ensure the security and confidentiality of personal information; (b) protect against any anticipated threats or hazards to the security, confidentiality and integrity of personal information; and (c) protect against unauthorized access, disclosure, alteration, or destruction of personal information that could result in the destruction, use, modification, disclosure or substantial harm or inconvenience to Oceanos or any individual. The nature and extent of protection will correspond to applicable local laws and regulations.

In addition, Oceanos provides users of its web sites with a secure online experience by using a variety of security measures to maintain the safety and confidentiality of personal information collected. For any questions about the security at Oceanos, please send an e-mail to privacy@oceanosinc.com.

DATA INTEGRITY

Oceanos takes reasonable steps to ensure that personal information is accurate, complete, and current. All Associates are asked to update their information immediately in the event that personal information changes. Data Subjects who create profiles with personal information on Oceanos's websites can update their information at any time.

ENFORCEMENT

Oceanos has established mechanisms to verify ongoing compliance to this policy. Any associate that violates Oceanos's Privacy Policy will be subject to disciplinary procedures.

CONTACT DETAILS

For any questions regarding this policy, outside parties should contact privacy@oceanosinc.com. Oceanos associates should contact their manager, HR partner or the Legal Department.

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