Global Privacy Policy

Vector Psychometric Group, LLC

Vector’s Global Privacy Policy was developed and is consistent with the Safe Harbor Privacy guidelines.

This policy was last updated on March 5, 2015.

Vector Psychometric Group is committed to the security and privacy of individual and organizational data. Vector Psychometric Group’s internal procedures and guidance were put in place to ensure personal and organizational information is treated in accordance with applicable data protection/privacy laws. This global privacy policy (the “Policy”) describes the keys principals prescribed to by Vector Psychometric Group when transferring personal and organizational data.

Vector Psychometric Group’s Policy is intended to ensure timely compliance with all international laws and regulations including: the U.S. Health Insurance Portability and Accountability Act (HIPAA), the European Union’s Data Protection Directive (EUDP), Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA), and Japan’s Personal Information Protection Action (PIPA), as applicable.

Contact Information

All questions regarding Vector Psychometric Group’s Global Privacy Policy should be directed to:

Vector Psychometric Group, LLC

847 Emily Lane

Chapel Hill, NC 27516

or by emailing Data.Security@vpgcentral.com

Safe Harbor

The data protection policies of Vector Psychometric Group, LLC comply with the U.S.-EU Safe Harbor Framework, as well as the U.S.-Swiss Safe Harbor Framework. Vector Psychometric Group has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access and enforcement. More information about the Safe Harbor program can be obtained from the US Department of Commerce (http://www.export.gov/safeharbor). Vector Psychometric Group’s Safe Harbor certification can be found herehttps://safeharbor.export.gov/list.aspx

Definitions

For purposes of the Policy, the following definitions apply:

“Agent” refers to any third party that uses personal information provided to it by Vector Psychometric Group to perform tasks on behalf of and under the instructions of Vector Psychometric Group.

“Vector Psychometric Group” or “VPG” refers to Vector Psychometric Group, LLC and their successors, subsidiaries, divisions and groups located in the United States.

“Personal information” refers to any information, set of information, or data that does or can be used to identify an individual. Personal information does not include information that is encoded, anonymized, or publicly available information that has not been combined with non-public personal information.

“Sensitive personal information” refers to personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns health or sex life. In addition, Vector Psychometric Group will treat as sensitive, any information received from a third party where that third party treats and identifies the information as sensitive.

Notice

Where Vector Psychometric Group collects personal information directly from individuals in the European Union and Switzerland, it will inform them about the purposes for which it collects and uses personal information about them, the types of non-agent third parties to which Vector Psychometric Group discloses that information, and the choices and means, if any, that Vector Psychometric Group offers individuals for limiting the use and disclosure of their personal information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to Vector Psychometric Group, or as soon as practical thereafter, and in any event before Vector Psychometric Group uses the information for a purpose other than that for which it was originally collected.

Vector Psychometric Group may not need to furnish notice when responding to a government inquiry; is required / authorized by applicable laws, court orders or government regulations; or is necessary to protect Vector Psychometric Group’s legal interests and providing notice would interfere with the above requirements.

Choice

Vector Psychometric Group will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. Unless otherwise stated, Vector Psychometric Group does not disclose any personal information, including email addresses, to non-agent third parties, Vector Psychometric Group does not authorize any of its third party affiliates to use personal information for any objective other than the objectives that were stated at the time of data collection. Vector Psychometric Group does not use any personal information for any reason other than that originally stated at the time of data collection.

Unless required or authorized by law, Vector Psychometric Group will not process sensitive personal information about individuals for purposes other than those for which the information was originally obtained or subsequently authorized by the individual unless the individual affirmatively and explicitly consents to the processing (“opt-in”). Vector Psychometric Group provides reasonable mechanisms to exercise these choices.

Data Integrity

Vector Psychometric Group will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Vector Psychometric Group will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, current, and otherwise reliable in relation to the purposes for which the information was obtained. Vector Psychometric Group employees, contractors, and agents have a responsibility to assist Vector Psychometric Group in maintaining accurate, complete and current personal information.

Transfer to Agents

Vector Psychometric Group may share an individual’s information with agents, contractors, or partners of Vector Psychometric Group in connection with services that these individuals or entities perform for, or with, Vector Psychometric Group. Vector Psychometric Group may, for example, provide an individual’s personal information to agents, contractors, or partners for hosting our databases, for data processing services, or to send to that individual the information that he or she requested. Vector Psychometric Group will obtain assurances from these third parties that they will safeguard personal information consistently with this Policy. Examples of appropriate assurances that may be provided include: a contract with provisions obligating these third parties to provide at least the same level of protection as is required by the relevant Safe Harbor Principles, being subject to the European Union’s Data Protection Directive, Safe Harbor certification by these third parties, or having Binding Corporate Rules approved by the European Commission.

Where Vector Psychometric Group knows that an agent, contractor, or partner is using or disclosing personal information in a manner contrary to this Policy, Vector Psychometric Group will take reasonable steps to prevent or stop the use or disclosure.

Access and Correction

Upon request, and as required by law, Vector Psychometric Group will provide individuals with reasonable access to the personal information that Vector Psychometric Group holds about them, subject to permitted exemptions. In addition, upon request, Vector Psychometric Group will take reasonable steps to provide individuals with a means to correct, amend, or delete information that is found to be inaccurate or incomplete. Due to regulatory, statistical, and contractual requirements, Vector Psychometric Group is unable to grant direct access to research data to research participants, clinical investigators, or any other individual for whom the access to the data may: 1) violate confidentiality agreements, 2) reduce the integrity of the data, or 3) reduce the integrity of the research itself.

Vector Psychometric Group takes all possible steps to destroy personal information in a timely fashion. No personal data is maintained longer than is required for the stated purpose or by law.

Security

Vector Psychometric Group will employ reasonable safeguards to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

Enforcement

Vector Psychometric Group Managing Partners have implemented internal, self-assessment procedures for periodically conducting random reviews of compliance of its relevant privacy practices to verify adherence to the company’s Safe Harbor Privacy Policy. Vector Psychometric Group encourages individuals covered by this Policy to raise concerns about the processing of personal information about them by contacting Vector Psychometric Group through the contact information provided below. Any employee or contractor that Vector Psychometric Group determines is in violation of this Safe Harbor Privacy Policy will be subject to disciplinary action up to and including termination of employment or contract.

Dispute Resolution

Any questions or concerns regarding the use or disclosure of personal information should be directed to Vector Psychometric Group’ Managing Partners through the contact information given above. Vector Psychometric Group will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Policy.

For complaints involving all other personal data other than human resources data that cannot be resolved between Vector Psychometric Group and the employee, such disputes will be referred to the American Arbitration Association for resolution.

For internal complaints by individuals involving human resources data that cannot be resolved between Vector Psychometric Group and an employee after following the internal review, complaint, and appeal procedures, Vector Psychometric Group has agreed to participate in the dispute resolution procedures of the applicable national data protection authority.

Reservation of Rights

Vector Psychometric Group reserves the right to share an individual’s information as required or authorized by law or in response to duly authorized information requests of government authorities.

Changes to the Policy

This Policy may be amended from time to time, consistent with the requirements of the United States of America and the European Union Safe Harbor Privacy Principles. Appropriate public notice will be given concerning such amendments.

If you feel that Vector Psychometric Group may not have abided by the United States of America and/or the European Union Safe Harbor Privacy Principles, you may contact Vector Psychometric Group or the U.S. Federal Trade Commission.