Safe Harbor Customer Privacy Policy

Volusion, LLC, and its parents, affiliates and subsidiaries ("Volusion") has created this Safe Harbor Customer Privacy Policy (the "Policy") to help you learn about how we handle Personal Information that is collected by entities located in the European Economic Area ("EEA") or Switzerland ("CH") (collectively, "EEA/CH") and transferred to Volusion in the United States. This Safe Harbor Customer Privacy Policy supplements the VolusionPrivacyPolicy. Unless specifically defined in this policy, the terms in this Safe Harbor Customer Privacy Policy have the same meaning as in the Volusion Privacy Policy. Volusion, protects all Personal Information that we receive from the EEA/CH, however, this Safe Harbor Customer Privacy Policy applies only to Personal Information received from the EEA/CH that is not otherwise covered by an alternative mechanism such as the Terms of Service.

Volusion has subscribed to and adheres to the U.S.-EU and US-Swiss Safe Harbor programs (collectively, the "Safe Harbor Program") by adopting and implementing the Safe Harbor Privacy Principles. More information about the Safe Harbor Program can be found at http://www.export.gov/safeharbor/.

Volusion acquires Personal Information when data is entered by you in the course of an ecommerce transaction with a Volusion customer.

Information Received from the EEA/CH
Volusion provides a variety or ecommerce software, hosting, design, marketing and related services to EEA/CH Clients. In order to provide these services, Volusion may receive information about the Client and/or the customers of these EEA/CH Clients including but not limited to: name, office and personal telephone numbers, company and home address, card account numbers and transaction details, card website login credentials, and email address (collectively, Personal Information).Volusion will only collect as much personal informationas we need for specific, identified purposes.

Use of Personal Information
Volusion uses Personal Information to perform its obligations under its EEA/CH Client agreements, including the following activities:
1. Credit card primary account number (PAN), expiration, customer zip code and customer name are sent to credit card processors for authorization and settlement of credit card transactions;
2. Personally Identifiable Information (PII) is accessed by the merchant (client of Volusion);
3. PII is sent to 3rd parties for shipping purposes;
4. PII (email) is utilized in outbound marketing campaigns; and
5. PII is utilized in fraud scoring.

If we intend to use your information for a purpose that is incompatible with these purposes or if we intend to disclose it to a type of third party not previously identified, we will notify you and offer you the opportunity to opt out of such uses and/or disclosures.

Use of Cookies
Volusion uses a browser feature known as a cookie, which assigns a unique identification to your computer. Cookies also allow Volusion to make our sites more responsive to your needs, by delivering a better and more personalized experience to you. The cookies are typically stored on your computer's hard drive and are used by Volusion to help track your clicks as you go through the pages within a Volusion Web site. In addition, Volusion uses cookies to help keep track of support requests and to tell us whether you have previously visited a Volusion website. This allows registered users to avoid reentering information upon every new visit to our site Volusion may also use the information obtained through cookies to refine our marketing strategies, such refinement may include sharing such non-PII information with third party marketing and analytic providers (i.e. Google, etc.).

Agents and Service Providers
We sometimes contract with other companies and individuals to perform functions or services. These agents and service providers may have access to Personal Information needed to perform their functions, but are restricted from using the Personal Information for purposes other than providing services for us. Volusion requires that its agents and service providers that have access to Personal Information received from the EEA/CH either subscribe to the Safe Harbor Privacy Principles or are subject to the EU Data Protection Directive or Swiss Federal Act on Data Protection or another adequacy finding or enter into a written agreement with us that requires them to provide at least the same level of privacy protection as is required by the relevant Safe Harbor Privacy Principles.

Data Security
We use reasonable physical, electronic, and administrative safeguards to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. Volusion processing technologies and operations employ a wide range of security measures including: physical, electronic, and procedural safeguards; sophisticated security monitoring tools; documented security policies; use of encryption and/or private leased lines for transmissions of Personal Information to and from EEA/CH Clients; restricted access of personally identifiable information only to those of its employees that need to know the information; and, periodic security audits by internal governance, compliance and audit groups and third party security experts.

Data Integrity & Retention
We take reasonable steps to ensure that Personal Information we process is reliable for its intended use, accurate, complete, and current to the extent necessary for the purposes for which we use the Personal Information. We will provide the EEA/CH Client with a method for reviewing and/or updating their Personal Information by logging into their account or by contacting us at the address below. We will keep your personal information for only as long as we need it for the purposes for which we collected it, or as permitted by law.

Safe Harbor Enforcement and Dispute Resolution
If you have any questions or concerns about this Policy or the Safe Harbor practices of Volusion, please write to us at the address listed below. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the Safe Harbor Privacy Principles.

Compliance Officer
Volusion, LLC
1835A Kramer Lane #100
Austin, TX 78758
(f) 512.686.3761
Email: Legal@volusion.com

If after contacting the EEA/CH Client and Volusion, an individual's complaint or dispute has not been resolved, s/he can contact the International Centre for Dispute Resolution of the American Arbitration Association at www.adr.org. This organization will provide independent dispute resolution.

Amendments

Volusion, in its sole and absolute discretion, may change or modify this Policy at any time and such modifications shall be effective immediately upon the post of the amended Policy to Volusion.com.