Privacy

Browz is in business to help suppliers exchange compliance and other business information with their customers who are our clients. Our core value is eliminating wasted time and money in the process of sharing data. The Browz Supply Chain Verification Service (the "Service") accomplishes this goal by sharing and verifying information while at the same time taking certain steps to protect your privacy and confidentiality.

Overview

Browz Group, LC and its affiliates collect limited information to assist Browz clients ("clients") who subscribe to the Browz Supply Chain Verification Service in evaluating and verifying the performance and contractual compliance of their current and prospective vendors, service providers, suppliers and sub-contractors ("suppliers") who participate in the Browz Service.

The core of our business is the limited sharing of certain basic business information, including information verified by us, so that our clients can rely on the qualifications and compliance of their suppliers who participate in the Browz Service. Participating suppliers also benefit from reduced costs by eliminating the need to provide duplicate information and documentation in paper form to their current and prospective customers.

Clients and suppliers can access the Service only through IDs and passwords. The information available on the Service is limited as explained in detail below. The Browz Service is designed so that confidential information about a supplier can generally be viewed by no clients other than the supplier's current and prospective customers and in such case only with the supplier's knowledge or consent.

Every client must sign a Subscription Agreement requiring compliance with applicable laws and privacy rules and imposing restrictions on use of the Service and the information available to the client and its employees from the Service. Every participating supplier must sign a Supplier Registration Agreement requiring compliance with applicable laws and privacy rules. These agreements define the rights between us and the supplier or client, as the case may be. Note that a client can also be a supplier in the Service, and a supplier can also be a client of the Service.

Collection of Information

We generally only collect information about a supplier which the supplier has either (1) provided to us or the supplier's customer (i.e., our client) or (2) authorized us to collect. We may also collect other information as part of the verification process or in the course of a special project. We collect information from:

• Clients - Information from clients primarily consists of clients identifying their suppliers by name and contact information. We or the client notifies a supplier when a client identifies it as a supplier, whether that supplier already participates in the Service or not. A participating supplier may notify us at any time that it does not want to grant a particular client access to that supplier's information, and we will honor that request as soon as practicable thereafter.
• Suppliers - Suppliers provide information to us on paper forms and/or electronically over the Internet.
• Commercial and governmental sources such as third-party reporting agencies and information services. These sources are contacted to verify and provide information as appropriate. Examples might include the Bureau of Labor Statistics of the U.S. Department of Labor, OSHA, NCCI (National Council on Compensation Insurance), State workers' compensation boards, A.M. Best Company, State departments of business and industry, Federal and state courts, State tax commissions, Dun & Bradstreet, West Group (Westlaw®), LexisNexis, and Moody's Investor's Service.
• Other third parties that may help verify supplier information requested by clients, such as insurance certificates provided by insurance carriers and brokers.

We also collect some personal information in the course of collecting supplier information and in certain other limited circumstances described below. We collect personal information in the following circumstances:

• In order to be able to contact and list a supplier, we need the name and business contact information (address, phone number, e-mail address, etc.) of an employee(s) designated by the supplier for receiving communications. Suppliers can change individual names and contact information by contacting us at any time on our web site, by mail, by e-mail or by phone. An employee of a supplier who does not wish to be listed as a contact person should first notify his or her employer; if unsuccessful, please contact us.
• Personal information may be collected as a necessary part of the verification process (for example, identifying injured employees may be necessary to verify a supplier's OSHA statistics) or for specific special projects requested by clients (such as verifying licensing or compliance with a specific rule by employees of a client or a supplier).
• Personal information may be collected and used when a supplier's business address, phone number or taxpayer identification number also happens to be an individual's home address, phone number or social security number. The supplier controls this situation, not us.

We may use and share information for the following purposes:

• We communicate with suppliers and clients using the contact information available to us.
• We obtain and verify supplier information requested by clients.
• We disclose certain information about a supplier to each client of the Service who has identified that supplier as its supplier, but only if that supplier has not requested us to deny that client access to the supplier's information. The information disclosed is that which the client has requested, which is normally summary information, and generally does not include all the raw data which we may collect for verification purposes.
• We provide a type of services registry for clients seeking pre-qualified suppliers to identify and contact prospective suppliers. Suppliers may opt into this registry during the registration process. Thereafter, they may contact us at any time to opt in or opt out. The registry shows clients limited identifying information about those suppliers who opt in, such as the supplier's name, contact information, industry classification, and minority and women business status. This may result in additional bidding opportunities for a supplier.
• We or our business partners or collaborators may contact suppliers when their information evidences compliance issues or for other business reasons. For example, we may suggest ways to help a supplier meet its customer's required level of performance.
• We may use and share information with our affiliates and third parties to operate our business and provide other services to our clients or participating suppliers. We rely on various service providers and other contractors to support our business operations, including credit card processors, call centers, reviewers, auditors and lawyers. We require those service providers and contractors with whom we share information to agree to use the information only on our behalf and in accordance with this Policy.
• We may store, process and analyze information in any country in the world in order to provide services to operate our business and provide services to our customers, clients and suppliers.
• We may aggregate information - for example, to create and publish industry safety statistics.
• We may use and share information to fulfill legal or regulatory requirements; to respond to subpoenas, court orders, or legal process; to cooperate with law enforcement authorities or other governmental authorities; to defend ourselves in a lawsuit; to protect our legal rights; to prevent harm to us or any other person or entity; to investigate, prevent, or take action regarding illegal activities, suspected fraud or situations involving potential threats to the physical safety of any person; as otherwise required by law; if we have a reasonable belief that such use or disclosure is necessary; or if we find that your actions constitute improper use of our web site or the Service or violate this Policy or any contract with us.
• We may transfer or sell your information to any person or entity that acquires all or part of the stock, assets or business of, or merges with, Browz or any of its affiliates.

Any supplier may contact us at any time and request that their information be removed from the Service, and we will honor that request as promptly as practicable after confirming that the request is genuine.

Data Quality

Ensuring that information is as up-to-date and accurate as practicable benefits suppliers, clients and us. Our Service relies on each supplier's reporting of its information in the first instance, followed by our periodic verification of that information. We and our clients rely on suppliers updating their information as appropriate and in a timely manner. Our clients have access to the verification procedures and timing used for the supplier information that they request so that our verification of information is sufficiently reliable, accurate, complete and current for their use as reasonably possible.

Confidentiality and Security Safeguards

The security of your information is critical to our mission and critically important to us. We maintain industry-standard security measures to reduce the risk of the loss, misuse, alteration or destruction of the information we collect and save and the unauthorized access to and disclosure of personal, confidential or proprietary information. Those individuals who handle information collected by us are required to keep it strictly confidential and may not disclose it except in conformance with this Policy.

Access to personal, confidential or proprietary information is limited to those people or entities who fulfill the applicable function, such as verification of data or customer assistance. Internal security procedures include password protection, physical protection or encryption, as applicable.

Access by clients and suppliers to the limited information placed on our web site as part of our Service is available only with IDs and passwords. Clients and suppliers should take reasonable precautions to protect the security of these IDs and passwords. However, we do not warrant that any transmission over the Internet or storage of data is completely secure.

Our Secure Sockets Layer software is the industry standard and among the best software available today for secure online commerce transactions. It encrypts your credit card number, name and address if applicable, so that it cannot be read as the information travels over the Internet. Once information reaches us, it resides on a server that is heavily protected, so your personal information is available only to authorized users. We maintain physical, electronic and procedural safeguards that comply with federal regulations for personal and financial information to guard your information.

Cookies and Other Files

Cookies are small pieces of information transferred from a web site to your computer's hard drive through your web browser to enable the web site to recognize your browser and provide features such as allowing you to return to the web site several days after to continue where you left off.

Cookies are stored by your browser on your computer's hard drive. Cookies do not contain any personally identifying information. Once you close your browser, some cookies simply terminate, while others remain, depending upon the web site.

Our cookies terminate when you close your browser since we do not store cookies permanently on your browser, except that we do save certain navigation elements as a cookie on your computer for your return browsing convenience if you request.

In addition, we may temporarily collect some information indirectly from users of our web site, such as IP addresses, to administer a web site user?s movement and administer and improve our web site. We will also use IP addresses to identify a user if we believe that someone may be using our web site improperly or it may be necessary or useful to enforce any governmental law, rule or regulation, this Policy or any contractual agreement.

Other People and Companies

This Policy does not apply to companies which we do not own or control nor to people whom we do not employ, such as clients and suppliers. Those companies or people may have their own policies about how they use your information, although they may have entered into agreements with us, as described above, which restrict such use.

Changes

Our business, just like yours, needs to be flexible to address changing business conditions and to meet new and changed business needs. As a result, our information uses may evolve. We therefore reserve the right to change this Policy. Any material changes to this Policy that may significantly affect the practices described will be posted on this web site and communicated by e-mail to any client or supplier requesting actual notice.

Contact Us

If you have any questions or comments or wish to elect any option available to you according to this Policy, please contact us in any of the following ways:

• A supplier may make most changes on-line using your User ID and password.
• By e-mail at clientservices@browz.com.
• In the United States, by phone at 877-392-7699.
• By mail to: Client Services, Browz Group, 13997 South Minuteman Drive, Draper, UT 84020.

Effective date: 10 February 2005

Copyright © 2004-2005 Browz Group, LC. All rights reserved.