DATE:   July, 2008

 We self-certify
compliance with

OVERVIEW:  NFC Global, LLC ("NFC") respects individual privacy and values the confidence of its customers, employees, vendors, consumers, business partners and others.  NFC strives to collect, use and disclose Personal Information (as defined below) in a manner consistent with the laws of the countries in which it does business, and has a tradition of upholding the highest ethical standards in its business practices. NFC abides by the Safe Harbor Principles developed by the U.S. Department of Commerce and the European Commission and the Frequently Asked Questions (FAQs) issued by the Department of Commerce on July 21, 2000.  This Safe Harbor Privacy Policy (the "Policy") sets forth the privacy principles that NFC follows with respect to transfers of Personal Information anywhere in the world, including transfers from the European Economic Area (EEA) (which includes the twenty-five member states of the European Union (EU) plus Iceland, Liechtenstein and Norway) to the United States.  

NFC adheres to the privacy principles of the Safe Harbor Program administered by the United States Department of Commerce and as described below.  Information regarding the Safe Harbor Program can be found at the program’s website:  http://export.gov/safeharbor.

I.  SAFE HARBOR

The United States Department of Commerce and the European Commission (“EC”) have agreed on a set of data protection principles and frequently asked questions (the "Safe Harbor Principles") to enable US companies to satisfy the requirement under European Union (“EU”) law that adequate protection be given to Personal Information transferred from the EU to the United States.  The EC also has recognized the Safe Harbor Principles as providing adequate data protection (OJ L 45, 15.2.2001, p.47).  Consistent with its commitment to protect personal privacy, NFC adheres to the Safe Harbor Principles.

NFC has appointed a Chief Security Officer who is responsible for NFC's compliance with and enforcement of this Policy. NFC educates its employees concerning compliance with this Policy and has self-assessment procedures in place to assure compliance. NFC's Chief Security Officer, Tim Tangye, is available to any of its employees, customers, vendors, business partners or others who may have questions concerning this Policy or data security practices. Relevant contact information is provided herein.

II.  SCOPE

This Policy applies to all Personal Information received by NFC in any format including electronic, paper or verbal.  NFC collects and processes Information concerning visitors to it's website and client requests for due diligence, through its Internet websites, electronic mail and manually.  NFC is the sole owner of information it collects from visitors to it's website.  Information collected from clients is owned by NFC's client unless otherwise specified in a contractual agreement between NFC and the client.  NFC will not sell or share this information with third parties in ways different than what is disclosed in this Privacy Policy.  On a global basis, NFC will, and will cause its affiliates to, establish and maintain business procedures that are consistent with this Policy.

Personal Information collected by NFC from clients is maintained at its corporate offices in Horsham, Pennsylvania.  NFC collects Personal Information for, among other things, legitimate due diligence business reasons such as bank account openings, vendor due diligence, mergers, acquisitions, pre-employment background checks, litigation support, etc.  NFC does not request or gather information regarding political opinions, religion, philosophy or sexual preference.  To the extent NFC maintains information on an individual's medical health or ethnicity (as legally required), NFC will protect, secure and use that information in a manner consistent with this Policy and applicable law.

Personal Information collected by NFC from prospective customers, consumers, vendors, business partners and others may be maintained at its corporate offices in Horsham, Pennsylvania. NFC collects Personal Information for, among other things, legitimate business reasons such as customer service; product, claims administration; meeting governmental reporting and records requirements; maintenance of accurate accounts payable and receivable records; internal marketing research; safety and performance management; financial and sales data; and contact information. All Personal Information collected by NFC will be used for legitimate business purposes consistent with this Policy.

III. DEFINITIONS

For purposes of this Policy, the following definitions shall apply:

"Agent" means any third party that uses Personal Information provided by NFC to perform tasks on behalf of or at the instruction of NFC.

"NFC" means its predecessors, successors, assigns, subsidiaries, divisions and groups.

"Personal Information" means any information or set of information that identifies or could be used by or on behalf of NFC to identify an individual.  Personal Information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public Personal Information.

"Sensitive Personal Information" means Personal Information that reveals race, ethnic origin, trade union membership, or that concerns health. In addition, NFC will treat as sensitive Personal Information any information received from a third party where that third party treats and identifies the information as sensitive.

IV. PRIVACY PRINCIPLES

The privacy principles in this Policy are based on the seven Safe Harbor Principles.

(1) NOTICE:  Where NFC collects Personal Information directly from individuals, 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 NFC discloses that information, and the choices and means, if any, NFC 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 NFC, or as soon as practicable thereafter, and in any event before NFC uses the information for a purpose other than that for which it was originally collected. NFC may disclose Personal Information if required to do so by law or to protect and defend the rights or property of NFC.

(2) CHOICE: NFC 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.

For Sensitive Personal Information, NFC will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

NFC will provide individuals with reasonable mechanisms to exercise their choices should requisite circumstances arise.

(3) DATA INTEGRITY:  NFC will use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual.  NFC will take reasonable steps to ensure that Personal Information is relevant to its intended use, accurate, complete and current.

(4) TRANSFERS TO AGENTS:  NFC will obtain assurances from its Agents that they will safeguard Personal Information consistently with this Policy.  Examples of appropriate assurances that may be provided by Agents include:  a contract obligating the Agent to provide at least the same level of protection as is required by the relevant Safe Harbor Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), Safe Harbor certification by the Agent, or being subject to another European Commission adequacy finding (e.g., companies located in Switzerland).  Where NFC has knowledge that an Agent is using or disclosing Personal Information in a manner contrary to this Policy, NFC will take reasonable steps to prevent or stop the use or disclosure. NFC holds it Agents accountable for maintaining the trust our employees and customers place in the company.

(5) ACCESS AND CORRECTION:  Upon request, NFC will grant individuals reasonable access to Personal Information that it holds about them.  In addition, NFC will take reasonable steps to permit individuals to correct, amend or delete information that is demonstrated to be inaccurate or incomplete. Any employees that desire to review or update their Personal Information can do so by contacting the Human Resources Department.

(6) SECURITY:  NFC will take reasonable precautions to protect Personal Information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. NFC protects data in many ways.  Physical security is designed to prevent unauthorized access to database equipment and hard copies of sensitive Personal Information.  Electronic security measures continuously monitor access to our servers and provide protection from hacking or other unauthorized access from remote locations.  This protection includes the use of firewalls, restricted access and encryption technology.  NFC limits access to Personal Information and data to those persons in NFC's organization, or as agents of NFC, that have a specific business purpose for maintaining and processing such Personal Information and data.  Individuals who have been granted access to Personal Information are aware of their responsibilities to protect the security, confidentiality and integrity of that information and have been provided training and instruction on how to do so.

(7) ENFORCEMENT:  NFC will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy and the US Department of Commerce Safe Harbor Principles.  Any employee that NFC determines is in violation of this Policy will be subject to disciplinary action up to and including termination of employment.

V.  DISPUTE RESOLUTION

Any questions or concerns regarding the use or disclosure of Personal Information should be directed to the NFC Privacy Office at the address given below.  NFC 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 that cannot be resolved between NFC and the complainant, NFC has agreed to participate in the dispute resolution procedures of the panel established by the European data protection authorities to resolve disputes pursuant to the Safe Harbor Principles.

VI. INTERNET PRIVACY

NFC sees the Internet, intranets and the use of other technologies as valuable tools for communicating and interacting with consumers, employees, vendors, business partners and others.  NFC recognizes the importance of maintaining the privacy of Personal Information collected through websites that it operates.  In general, visitors can reach NFC on the Web without revealing any Personal Information. Visitors on the Web may elect to voluntarily provide Personal Information via NFC websites but are not required to do so.  NFC collects information from visitors to the websites who voluntarily provide Personal Information by filling out and submitting online questionnaires requesting products or services.  The Personal Information voluntarily provided by website users is contact information limited to the user's name, business address, phone numbers and email address.  NFC collects this information so it may answer questions and forward requested information.    NFC uses the information it collects from a visitor’s online application or form submittal to fulfill the research or services requested, and this information is not disclosed to non-agent third parties.  NFC also uses the information it collects from a visitor for network security purposes and to assess the usage of its Website to determine the areas of its Website that are most frequently visited. This information is used to assist NFC in protecting its Website and network and in making the site more useful to its visitors. NFC does not sell or share this information with non-agent third parties.  NFC may, however, disclose relevant information to authorities or other non-agent third parties regarding abusive or unauthorized activity taking place on it’s network or sites, or in the event of a legal obligation such as a subpoena or court order.NFC may also collect anonymous information concerning website users through the use of "cookies" in order to provide better customer service.  "Cookies" are small files that websites place on users' computers to identify the user and enhance the website experience. None of this information is reviewed at an individual level. Visitors may set their browsers to provide notice before they receive a cookie, giving the opportunity to decide whether to accept the cookie. Visitors can also set their browsers to turn off cookies.  If visitors do so, however, some areas of NFC websites may not function properly.

None of NFC's websites are directed toward children.  Nevertheless, NFC is committed to complying with applicable laws and requirements, such as the United States' Children's Online Privacy Protection Act ("COPPA").

NFC website users have the option to request that NFC not use information previously provided, correct information previously provided, or remove information previously provided to NFC. Those that would like to correct or suppress information they have provided to NFC should forward such inquiries to:

NFC Global, LLC
Address: 300 Welsh Road, Building 4, Suite 200, Horsham, PA  19044
Attn:     Tim Tangye, Chief Security Officer
Phone: (215)657-0800
E-Mail:  privacy@nfcglobal.com

The inquiries should include the individual's name, address, and other relevant contact information (phone number, email address).  NFC will use all reasonable efforts to honor such requests as quickly as possible.

NFC websites may contain links to other "non-NFC" websites. NFC assumes no responsibility for the content or the privacy policies and practices on those websites.  NFC encourages all users to read the privacy statements of those sites; their privacy practices may differ from those of NFC.

VII. CHANGES TO THIS SAFE HARBOR PRIVACY POLICY

The practices described in this Policy are current personal data protection policies.  NFC reserves the right to modify or amend this Policy at any time consistent with the requirements of the Safe Harbor Principles.  Appropriate public notice will be given concerning any such revisions.