Polaris EPDMS Privacy Statement (last updated: Mar 2, 2012)

Introduction
Polaris is committed to protecting your privacy. This privacy statement explains data collection and use practices of our Expentia application (the "Application"); it does not apply to other online or offline Polaris sites, products or services. By using the Application, you are consenting to the information collection and use practices described in this privacy statement.
Polaris collects and stores certain human resource data necessary to facilitate global mobility. This includes tax compliance, payroll, budgeting, and accounting of payroll expenses. Because some of the information we collect relates to employees within EU member states and Switzerland, we adhere to the U.S.-EU and U.S.-Swiss Safe Harbor Principles. For more detail on the Safe Harbor program, please visit http://www.export.gov/safeharbor

Collection of Your Personal Information
We will ask you when we need information that personally identifies you or allows us to contact you. The personal information we collect may include name, address, social security number, employee ID number, dependants' names, dependants' ages, bank account information, work permit details, personal tax information, email address, phone number.
The Site may collect certain information about your visit, such as the name of the Internet service provider and the Internet Protocol (IP) address through which you access the Internet; the date and time you access the Site; the pages that you access while at the Site and the Internet address of the Web site from which you linked directly to our Site. This information is used for the operation and improvement of the Site.

Use of Your Personal Information
In support of these uses, Polaris may use personal information to provide you with more effective customer service, to improve the Site and any related Polaris products or services, and to make the Site easier to use by eliminating the need for you to repeatedly enter the same information or by customizing the Site to your particular preference or interests.
Polaris occasionally hires other companies to provide limited services on our behalf. We will only provide those companies the personal information they need to deliver the service. They are required to maintain the confidentiality of the information and are prohibited from using that information for any other purpose.
Polaris may disclose personal information if required to do so by law or in the good faith belief that such action is necessary to (a) conform to the edicts of the law or comply with legal process served on Polaris or the Site; (b) protect and defend the rights or property of Polaris and our family of Web sites; or (c) act in urgent circumstances to protect the personal safety of your company's employees or agents, users of Polaris products or services, or members of the public.
Personal information collected on the Site may be stored and processed in the United States or any other country in which Polaris or its affiliates, subsidiaries or agents maintain facilities, and by using the Site, you consent to any such transfer of information outside of your country. Polaris abides by the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of data from the European Union and Switzerland.

Control of Your Personal Information
Except as otherwise described in this statement, personal information you provide on the Site will not be shared outside of Polaris and its controlled subsidiaries and affiliates without your permission.

Access to Your Personal Information
You can review and edit the personal information you provided at this Site by signing into the site and accessing your profile.

Security of Your Personal Information
Polaris is committed to protecting the security of your personal information. We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. For example, we store the personal information you provide on computer servers with limited access that are located in controlled facilities. Additionally, when we transmit sensitive personal information over the Internet, we protect it through the use of encryption, such as the Secure Socket Layer (SSL) protocol.

Changes to this Privacy Statement
We may occasionally update this privacy statement. When we do, we will also revise the "last updated" date at the top of the privacy statement. For material changes to this privacy statement, we will notify you either by placing a prominent notice on the home page of our web site or by directly sending you a notification. We encourage you to periodically review this privacy statement to stay informed about how we are helping to protect the personal information we collect. Your continued use of the service constitutes your agreement to this privacy statement and any updates.

Enforcement for Safe Harbor
For complaints that cannot be resolved between Polaris and the complainant, Polaris has agreed to participate in the dispute resolution procedures of the panel established by the EU data protection authorities to resolve disputes pursuant to the Safe Harbor Privacy Principles, as well as to cooperate and comply with the Swiss Federal Data Protection and Information Commissioner.

Contact Information
Polaris welcomes your comments regarding this privacy statement. If you believe that Polaris has not adhered to this privacy statement, please contact us by e-mail at privacy@polarisgm.com or via postal mail at the address provided below, and we will use commercially reasonable efforts to promptly determine and remedy the problem.

Polaris Payroll Consulting, Inc.
3290 146th Place SE
Suite A Bellevue, WA 98007