EVEREST GROUP WEBSITE PRIVACY POLICY

Everest Global, Inc., and its corporate affiliates ("Everest Group") are committed to protecting your privacy. As part of this commitment Everest Group has adopted the following Privacy Policy.

Privacy of Information Collected on this Website

Everest Group does not collect personally-identifiable information on this website. Everest Group uses cookies, the small text files a website can use to track the activities of users over time and across different websites. Cookies help us to provide better, faster service with a personalized site experience. You can opt to set your browser to reject cookies; however, this will hinder performance and negatively impact your experience on our site. Users of the website should be aware that links to other Internet sites may be available on the website. If a user leaves the website and goes to another site, users should be aware that those sites may follow privacy policies that differ from the policies of Everest Group. Everest Group is not responsible for, and expressly disclaims any and all liability related to, actions of such linked sites, their privacy policies or the content of such sites.

If Everest Group decides to update or modify this website privacy policy, it will post the updated policy on this website so that users will always have access to the privacy policy. This website was last updated on July 20, 2010. Continued use of the website after any such changes constitutes acceptance of the new terms.

Everest Group maintains other websites through its Everest Research Institute and Outsourcing Center divisions. Those websites, which may collect personally-identifiable information, are governed by separate Privacy Policies, which can be found at www.everestresearchinstitute.com/PrivacyPolicy and www.outsourcing-center.com/privacy-policy.html

Privacy of Data Not Collected Via our Websites

Everest Group may perform consulting services such as strategic analysis or data management for clients, during which it may be given access to personally-identifiable information ("PII") relating to the personnel of such clients or their affiliates, customers or contractors ("Clients' PII") . Everest Group does not disclose clients' data, including Clients' PII, to any third parties without the express consent of the client. Everest Group requires its employees and subcontractors to enter into written agreements to keep all such data confidential and to abide by Everest Group's Global Personnel Policy regarding Privacy and Security of Personally-identifiable Information, which is designed to comply with the European Union's Data Processing Principles. Everest will collect and process any Client PII only as instructed by the client and in accordance with applicable laws and regulations.

Onward Transfer

Everest Group will not transfer Clients' PII to a third party except as authorized by the client. Any transfer of PII among the affiliated Everest Group companies is governed by Data Transfer Agreements between each company, which contain the ICC Standard Contractual Clauses for the Transfer of Personal Data from the Community to Third Countries in the form approved by the Commission of the European Union. Where Everest Group uses third-party sub-contractors or vendors having access to Clients' PII through Everest Group they shall be contractually required to enter into confidentiality agreements and to comply with Everest Group's confidentiality and privacy policies.

Security

Everest Group maintains reasonable and appropriate technical and organizational measures and precautions to protect personally-identifiable information from accidental or unlawful loss, misuse and unauthorized disclosure, access, alteration or destruction. Only authorized users, bound by employee confidentiality agreements, have access to Clients' PII stored by Everest Group.

Enforcement

Everest Group will cooperate with relevant authorities, including the EU Data Protection Authorities and the Department of Commerce, to resolve any complaints and disputes arising in connection with its privacy policies. Everest Group will investigate any reported complaints of violations of its privacy policy and will take prompt remedial action where violations are found. Dispute resolution provisions in Everest Group's client contracts will be followed.

Contacting Everest Group

In order to inquire about or to make requests concerning Everest Group's privacy policies or related to the privacy of personal information handled by Everest Group, please contact Everest Group's Data Protection Officer at Everest Group, 13455 Noel Road, Suite 2100, Dallas, Texas, 75240, attn: Data Protection Officer, or send an email to the Data Protection Officer and General Counsel at the following email address: privacy@everestgrp.com.