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Safe Harbor Compliance.

We self-certify compliance with safeharbor.export.gov

WebQA, Inc. (“WebQA”) is a leading Web and Mobile Applications developer for customer communication and service platforms and is currently serving local and state governments, commercial entities, education and financial institutions. Protecting the privacy of our clients is of the utmost importance to WebQA. WebQA complies with the U.S.-EU 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. WebQA 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 Intelligent Discovery Management’s certification, please visit http://www.export.gov/safeharbor/

Accordingly, we follow the Safe Harbor Principles published by the U.S. Department of Commerce (the “Principles”) with respect to all such data. If there is any conflict between the policies in this privacy policy and the Principles, the Principles shall govern.

WebQA’s privacy policy outlines our general policy and practices for implementing the Principles, including the types of information we gather, how we use it and the notice and choice affected individuals have regarding our use of and their ability to correct that information. This privacy policy applies to all personal information received by the Company whether in electronic, paper or verbal format. WebQA’s privacy policy can be viewed online at http://webqa.net/index.php/privacy-policy/

Definitions
“Personal Information” or “Information” means information that (1) is transferred from the EU to the United States; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and (4) can be linked to that individual.

“Sensitive Personal Information” means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual’s health.

WebQA’s Safe Harbor Principles

Notice
How Personal Information is Collected

Web Visitors
WebQA collects Personal Information about a visitor to our Web site only when the visitor chooses to provide such information. On certain pages, for example, a visitor has the opportunity to provide his/her personal information such as his/her name, company, address, phone number, and e-mail address. We may use this information for three general purposes: to customize the content you see, to fulfill your requests for certain services and information, and to contact you.

Web Site / Cookies
In order to improve the content and format of our site, WebQA may at times use Web site tracking software to automatically capture technical information that is then stored in our server’s log files. This information may include, but is not limited to, user domain, the type of Internet browser being used, which of our Web pages is visited, and the amount of time spent on our site. WebQAs’ web server log files and click path tracking do not contain any personally identifiable information.

In addition, some of WebQA’s Web pages may contain “cookies.” A cookie is a small amount of data which our Web site stores on your computer, and which we can later retrieve. The cookie cannot be read by a site other than ours. We use cookies for a number of administrative purposes; for example, to store your preferences for certain kinds of information. No cookie will contain information that will allow anyone to contact you via telephone, e-mail, or any other means. You can monitor our use of cookies on your computer by setting your Web browser to inform you when cookies are set, or you can prevent the cookies from being set entirely. The “help” portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Please understand that if you disable the use of cookies on your computer, you may be unable to access certain portions or services on our Web sites.

Customers
WebQA may collect certain Personal Information from our customers who use our solution. The information may be collected through our SaaS solution, or by members of our support team who provide support to customers. The type of Personal Information collected varies based on the type of interactions the customer is having with the website or SaaS solution, but is typically limited to email address, and name.

Choice
Use of Your Personal Information
We use your Personal Information to provide you with the services which WebQA is contractually obligated to provide to you, or to assist you in completing a transaction, or communicate with you about our products or services. We use Personal Information from Web site visitors to respond to any inquiries such visitors make to our Web site and to provide you with related information of interest to you. We do not sell or rent your Personal Information to third parties.

We may disclose your Personal Information if we are required to do so by law or we in good faith believe that such action is necessary to (1) comply with the law or with legal process; (2) protect and defend our rights and property; (3) protect against misuse or unauthorized use of our Web site; or (4) protect the personal safety or property of our users or the public (among other things, this means that if you provide false information or attempt to pose as someone else, information about you may be disclosed as part of any investigation into your actions).

Other than as stated in this Privacy Policy, we will endeavor not to release your Personal Information to unknown or unaffiliated third parties, and we will not cross-reference your Personal Information with that of any other customer or entity.

Onward Transfers
Sharing of Your Personal Information
WebQA may contract with third-party providers to perform certain functions on our behalf or to enhance our existing product and service offerings. Examples include providing marketing assistance, product, and service support.
These third parties may have access to your Personal Information only to the extent necessary to permit them to do their jobs, however, they are bound by confidentiality agreements before any information is provided to them, and they are restricted from using the information for other purposes.

Links to Non-WebQA Web Sites and Third Parties
WebQA’s Web sites may contain links to third-party sites for your convenience and/or information. If you access those links, you will leave WebQA’s Web site and be re-directed to a third-party site. WebQA does not control those sites or the privacy practices of those third-party sites, which may differ from WebQA’s privacy practices. We do not endorse or make any representations about third-party Web sites, and the personal data you choose to provide to third-party Web sites is not covered by this Privacy Policy. We encourage you to review the privacy policy of any Web site or company before submitting your Personal Information to them.

Access
WebQA will take reasonable steps to ensure that your Personal Information is accurate, complete, and current, to its intended use. We provide individuals with reasonable access to the Personal Information that they provide to us, as well as the ability to review and correct such information.

To protect your privacy and security, we also take reasonable steps to verify your identity, before granting access to your Personal Information. In addition, we may limit or deny access to Personal Information where providing such access would be unreasonably burdensome or expensive in the circumstances, or as otherwise permitted by the Safe Harbor Frameworks.

Security
To prevent unauthorized access or disclosure, to maintain data accuracy, and to allow only the appropriate use of your Personal Information, we utilize physical, technical, and administrative controls and procedures to safeguard the information we collect.

To protect the confidentiality, integrity, and availability of your Personal Information, WebQA utilizes a variety of physical and logical access controls, firewalls, intrusion detection/prevention systems, network and database monitoring, anti-virus, and backup systems. We use encrypted sessions when collecting or transferring sensitive data through our Web sites.

We limit access to your Personal Information and data to those persons who have a specific business purpose for maintaining and processing such information. WebQA’s employees who have been granted physical access to your Personal Information will be made aware of their responsibilities to protect the confidentiality, integrity, and availability of that information and have been provided training and instruction on how to do so.

Data Integrity
WebQA will take reasonable steps to ensure that Personal Information is accurate, complete, and current, to its intended use. WebQA will only use Personal Information in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual.

Enforcement and Verification
WebQA will conduct periodic assessments to validate its continued adherence to this Privacy Policy. Where WebQA has knowledge that one of WebQA’s employees or third parties is using or disclosing Personal Information in a manner contrary to this Policy, WebQA will take reasonable steps to prevent or stop the use or disclosure. WebQA holds its employees and agents accountable for maintaining the trust that our customers place in our company.

Changes to This Privacy Policy
The practices described in this Policy are the current Personal Information protection policies as of June 29, 2011. WebQA reserves the right to modify or amend this Policy at any time consistent with the requirements of the Safe Harbor Frameworks. Updates will be posted to this site.

Recourse for Safe Harbor privacy complaints
Privacy Complaints by U.S. and European Union Citizens
In compliance with the Safe Harbor Principles, WebQA, commits to resolve complaints about your privacy and our collection or use of your personal information. U.S. and European Union citizens with inquiries or complaints regarding this privacy policy should first contact WebQA at:

Gregory Pengiel
Chief Technology Officer
WebQA, Inc.
900 S. Frontage Rd., Suite 110
Woodridge, IL 60517

Dispute Resolution
WebQA will investigate and attempt to resolve complaints and disputes regarding the use and disclosure of Personal Information in accordance with the principles contained in this Policy. For complaints that cannot be resolved between WebQA and the complainant, WebQA has agreed to participate in the dispute resolution procedures of the panel established by the EU Data Protection Authorities (DPAs) to resolve disputes pursuant to the Safe Harbor Privacy Principles, as well as to cooperate and comply with the Federal Data Protection and Information Commissioner of Switzerland.

Effective date: May 1, 2011