etouches.com — Privacy Policy

Our Commitment To Privacy

Your privacy is important to us. To better protect your privacy we provide this notice explaining our online information practices and the choices you can make about the way your information is collected and used. To make this notice easy to find, we make it available on our homepage and at every point where personally identifiable information may be requested.

Who We Are

We are etouches, a division of Global Executive Business Services, incorporated in the state of New York, USA.

The etouches Website

This notice applies to all information collected or submitted on the etouches website (www.etouches.com).

The Information We Collect

On some pages, you can make requests, and register to receive materials. The types of personal information collected at these pages are:

• Name
• Address
• Email address
• Phone number
• Other information, from time to time

The Way We Use Information

You can register with our website if you would like to receive updates on our new products and services. We use phone numbers and email addresses to contact you. Such addresses are not used for any other purpose and are not shared with outside parties. We do not use any tracking technology on our website to record your visit so, unless you register for product or service updates as described above, no information about you will be stored. If you wish to review, change or delete any of the information that you have entered, please contact us at privacy@etouches.com.

The etouches Event Management System

This notice applies to all information collected or submitted on event registration sites which are powered by etouches.

The Information We Collect

On some pages, you will be asked to fill in personal information and credit card data in order to register and pay for attendance at an event being run by an etouches client. The types of personal information collected at these pages are:

• Name
• Address
• Email address
• Phone number
• Conference/Event Preferences
• Credit card details
• Other information

The Way We Use Information

The etouches Event Management System service collects event attendee preferences, travel and enrollment information from a secure online registration site for our clients. This information is provided only to the client who has organized the conference or event for use in managing the event. etouches in no way uses or distributes any attendee data to any third parties. We do not use any additional tracking technology on our registration sites to record your visit. However, as part of the registration process, as soon as you enter an email address any further personal information that you enter will be stored, even if you do not complete the registration process. If you wish to review, change or delete any of the information that you have entered, please contact that event organizer in the first instance. If you are unable to resolve your issue in this way, please contact us at privacy@etouches.com.

Our Commitment To Data Security

To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online. We are fully compliant with the US Department of Commerce "Safe Harbor" initiative (as described below) outlining appropriate use and storage of personal data for both US and European standards. We never use or share the personally identifiable information provided to us online in ways unrelated to the ones described above without also providing you an opportunity to opt-out or otherwise prohibit such unrelated uses.

EU Safe Harbor Privacy Statement

General Information

This section describes how we collect, use, and disclose EU personal information, which is certain personally identifiable information that we receive in the United States about individuals resident in the European Union. We comply with the US-EU Safe Harbor Privacy Principles as set forth by the U.S. Department of Commerce, with respect to the collection, use, and retention of data from the EU. Compliance with the Principles may be limited, however in certain cases to the extent necessary to meeting national security, public interest or law enforcement requirements. For further background and information about the EU Safe Harbor, please refer to the U.S. Department of Commerce's website at http://export.gov/safeharbor.

Notice

We collect personal information from you via etouches websites and etouches-Powered registration sites for the purposes of (a) providing etouches Services; (b) facilitating communications between you and third parties; (c) our marketing activities; and (d) all credit and other financial checks in relation to any payments made by you for etouches Services.

We may disclose personal information to third parties when such disclosure is necessary or appropriate for the provision of services to our clients or otherwise for the operation of our business. We may also disclose personal information to third parties in circumstances described in the "Onward Transfer to Third Parties" section below.

Any complaints or questions should be first sent to us by email at privacy@etouches.com. We will respond to personal information change requests within 30 days of receiving such requests.

When we receive personal information from the EU merely for processing purposes and do not control the collection of the personal information, we may not provide notification of this EU Safe Harbor Privacy Statement to you. In such event, we reserve the right to process personal information in the course of providing etouches Services to our clients or otherwise for the operation of our business without your knowledge.

Choice

Except as provided below, we give you the opportunity to opt out from allowing us to disclose personal information to a third party or to use it for a purpose incompatible with the purpose for which it was originally collected. For sensitive personal information, we require you to affirmatively opt in and give consent if the data is to be disclosed to a third party or used for a purpose other than its original purpose.

If you wish to opt-out you should contact us by email at privacy@etouches.com. If we wish to collect sensitive personal information you will be advised of how to opt in and give the required consent at the time the data is collected, if the data is to be disclosed to a third party or used for a purpose other than its original purpose.

When we receive personal information merely for processing purposes and do not control the collection of the personal information, we may not provide such choices to you.

Onward Transfer to Third Parties

We may disclose personal information to a third party if (a) we have received your permission to make the disclosure, (b) the disclosure is required by law, (c) the disclosure is reasonably related to the sale or other disposition of all or part of etouches' business, (d) the information in question is publicly available, and/or (e) the disclosure is reasonably necessary for the establishment of a legal claim.

Additionally, we may disclose personal information to a third party if the disclosure is to an etouches affiliate or to persons or entities providing services on our behalf or an etouches client, consistent with the purpose for which the information was obtained, if the transferee, with respect to the personal information in question (a) is subject to law providing an adequate level of privacy protection (e.g. transferees that are located within the EU), (b) has agreed in writing to provide an adequate level of privacy protection, and/or (c) subscribes to the US-EU Safe Harbor Privacy Principles.

Security

We take security measures designed to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures designed to guard against unauthorized access to systems where we store personal information.

We restrict access to personal information to etouches employees, contractors, customers and partners who need to know that information in order to operate, develop or improve our services. These individuals and third parties are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

Data Integrity

We take reasonable steps to ensure that personal information is reliable, accurate, complete, current and relevant for the purposes for which it was collected.

Access

Upon request and consistent with any applicable client commitments, we will permit you to access your personal information and to correct any erroneous information. You may need to provide sufficient identifying information (e.g. name, address, birth date, and social security or national health insurance or an equivalent number). Such access may be denied or limited by us if providing such access is unreasonably burdensome, expensive under the circumstances, and/or if in giving such access would violate another person's rights. In some circumstances, we may charge a reasonable fee for access to personal information. You can contact us at privacy@etouches.com to request access to change personal information.

Enforcement

We will conduct an annual self-assessment to ensure that this Statement is published and disseminated within etouches and on our website and that it conforms to the US-EU Safe Harbor Privacy Principles. In addition, we have deployed internal processes to monitor etouches' compliance with the US-EU Safe Harbor Privacy Principles and to address all questions or complaints. We will also self-certify annually with the U.S. Department of Commerce as being in compliance with the US-EU Safe Harbor Privacy Principles. Users may raise any concerns or complaints regarding their personal information directly with etouches by first contacting us by email at privacy@etouches.com. If you raise a concern or complaint, we will investigate the matter and attempt to resolve all issues to your satisfaction.

What If You Do Not Get A Satisfactory Response

We will try our best to see that you will always get a satisfactory response from us. If you do not believe that we have responded in a satisfactory manner, then we will agree to a process of arbitration conducted by the American Arbitration Association.

How To Contact Us

If you have inquiries or concerns about any information we may have collected about you, please send us an email at privacy@etouches.com.

Noticed dated: 6/1/2008