TraCorp, Inc. Privacy Policy and Statement

TraCorp, Inc. (“TraCorp”) is committed to protecting your privacy and earning your trust. This Privacy Statement describes TraCorp’s privacy practices for both the web site located at www.tracorp.com and the Customer Web Sites which TraCorp creates, configures and hosts on behalf of its customers. These practices implement the requirements prescribed by the United States-European Union “Safe Harbor” arrangement for compliance by U.S.-based organizations with the provisions of the European Union’s Directive regarding the protection of personal information. To learn more about the Safe Harbor program, and to view TraCorp’s certification, please visit http://www.export.gov/safeharbor/

Information Collection & Use – Customer Web Sites

TraCorp provides online knowledge, training, management and other services to employees of TraCorp’s customers and others designated by TraCorp’s customers to participate in TraCorp’s programs (“Users”). TraCorp’s customers are typically businesses or other organizations. TraCorp typically provides its services via Customer Web Sites that TraCorp creates, configures and hosts on behalf of customers. TraCorp operates its programs and collects and uses data about Users at the direction of, and in accordance with, the instructions of TraCorp’s customers. TraCorp’s arrangements with its customers may require TraCorp to obtain certain personal information about Users, either from the customer or a User, in order for a User to access the online knowledge, training and other services provided on a Customer Web Site. Among other things, TraCorp may collect the following data: (i) User name; (ii) User identification; (iii) User password; (iv) User email address; and (v) User department(s) and location within the customer organization. TraCorp may also track the amount of time a User spends on the Customer Web Site, the applications the User employs, the self-tests the User performs, the User’s performance on such tests, and other activities in which the User engages while the User is on the Customer Web Site. TraCorp only uses personal information to provide feedback about a User’s activity on a Customer Web Site. For example, TraCorp may use personal information to inform a User of his or her performance on tests, or the number of training modules that a User has used. TraCorp may also use personal information to send emails to a User, such as reminder emails that the User has not completed certain online courses. TraCorp’s arrangements with its customers require TraCorp to provide all User information in TraCorp’s possession, including a User’s personal information, directly to the customer with which the User is associated (i.e. the User’s employer). If a User corresponds with TraCorp, TraCorp may keep a record of that correspondence. TraCorp may also forward correspondence to the customer with which the User is associated. TraCorp does not transfer any personal User information to any third party (other than to the TraCorp customer with which the User is associated) unless it is authorized to do so by the customer with which the User is associated , in connection with the services that TraCorp provides to the customer, or required to do so by applicable law.

www.tracorp.com

TraCorp actively collects information from visitors to its website at www.TraCorp.com both by asking specific questions on the site and by permitting visitors to communicate directly with TraCorp via email. Some of the information that visitors to the website submit may be personally identifiable (that is, information that can be uniquely identified with an individual, such as name, address, email address, phone number, etc.). TraCorp uses this information to send visitors to its website further information regarding TraCorp. TraCorp does not provide, sell, or otherwise make available to third parties personal information that is collected from visitors to the website. TraCorp may collect, store or accumulate certain non-personally identifiable information concerning visitors’ use of this site, such as information regarding which pages are most often visited. TraCorp may share with or transfer to third parties such non-personally identifiable information for the purpose of maintaining the site, responding to direct inquiries or measuring traffic and traffic trends at this site. TraCorp does not otherwise provide or sell any of this information to third parties.

Data Integrity & Data Security

TraCorp has taken commercially reasonable and appropriate steps to protect personal information that TraCorp collects, processes or maintains. These steps include, among other things, limiting the number of people who have physical access to TraCorp’s database servers, utilizing electronic security systems, and using password protections which guard against unauthorized access. TraCorp employs these and other safeguards and practices to provide for the security of personal information in its possession, but cannot guarantee that such measures will be infallible. TraCorp also requires its vendors to take commercially reasonable and appropriate steps to protect personal information in their possession.

Correcting & Updating Personal Information

TraCorp is committed to ensuring that the personal information it collects, processes, and maintains is accurate. At the direction of, and in accordance with, the instructions of TraCorp’s customers, TraCorp allows Users of TraCorp’s Customer Web Sites to access their personal information in TraCorp’s possession and to correct, amend, or delete inaccurate information. Users of TraCorp’s Customer Web Sites who have questions about personal information on file with TraCorp may, if the customer so provides, access the Customer Web Site to make such corrections or may contact TraCorp at the address below. Visitors to TraCorp’s website may update, or request the deletion of, previously submitted personal information via the Contact page.

Cookies & Session IDs

www.TraCorp.com. TraCorp also uses cookies and session IDs to authenticate Users as they navigate various parts of Customer Web Sites. For example, cookies may be used to enable a User to move through a Customer Web Site without having to retype the User’s password. Cookies and session IDs may also be used to automate certain data entry functions associated with Customer Web Sites. TraCorp does not obtain personal information via cookies or session IDs, and does not link any data collected through cookies or session IDs to any personal information. Links TraCorp web sites may contain links to other web sites. TraCorp is not responsible for the privacy practices or the content of such other sites.

Disclaimers

This Privacy Statement describes TraCorp’s privacy practices only. It does not describe, and TraCorp makes no representations about, the privacy practices of any other parties, including TraCorp’s customers, who may receive personal information from TraCorp about Users associated with that customer in the course of TraCorp’s performance of services for the customer. Opt-out Recipients may unsubscribe from future email communications from TraCorp by following the instructions in such communications.

Questions & Complaints

If anyone has any questions or complaints about this Privacy Statement, the practices of, or his or her dealings with, any of TraCorp’s web sites, he or she should contact TraCorp at the following address:

Webmaster

TraCorp, Inc. 5621 W. Beverly Lane Glendale, AZ 85306 A citizen of a country within the European Union may also address any privacy-related questions or problems to the appropriate data protection authority in his or her E.U. member state or the United States Council for International Business (USCIB). If an individual covered by this Privacy Statement has a complaint about the processing or use of that individual’s personal information and the complaint is not resolved to the individual’s satisfaction through TraCorp’s internal procedures, then TraCorp will make arrangements for the USCIB to offer an independent, third-party dispute resolution mechanism to resolve the complaint. Business Transfers In the event of a sale, assignment, liquidation or other transfer of all or substantially all of the stock, assets or business of TraCorp, personal information may be transferred to a relevant successor entity, subject to the applicable privacy policy.

Changes to this Privacy Statement

This Privacy Statement may be amended from time to time. When we do update the Privacy Statement, we will also revise the “Last Updated” date at the bottom of this document. Any changes to this Privacy Statement will be posted on TraCorp’s website.