Website Privacy and Security Policy

Last modified: September 20, 2012

If you have any questions about this Website Privacy and Security Policy, please contact us at

feedback@clearrisk.com.

1. Protecting Your Privacy

(1) ClearRisk Inc. respects your privacy and is committed to protecting it in accordance with

this Website Privacy and Security Policy. This policy explains ClearRisk Inc.’s treatment of your

personally identifiable information collected in connection with your activities on ClearRisk Inc.’s

website (www.clearrisk.com) and all ClearRisk Inc. services made available thereon. This policy

also explains how you can ask questions and make suggestions about ClearRisk Inc.’s privacy

practices and review and update your personal information.

(2) ClearRisk Inc. urges you to read this policy carefully and to check back periodically, as this

policy may change from time to time. Please note that this policy does not apply to practices

of companies or websites which are not owned or controlled by ClearRisk Inc., including those

which are subject to links posted on ClearRisk Inc.’s website.

2. Information Collected

(1) In the course of operating the website, ClearRisk Inc. may collect two types of information

about you: Personal Information and Non-Personal Information.

(2) “Personal Information” is personally identifiable information, such as your name, address,

telephone number, e-mail address and credit card information. Personal Information is collected

by ClearRisk Inc. when you provide it in the course of subscribing to the website. In addition, if

you contact ClearRisk Inc., a record of that correspondence and of any Personal Information

you provide in the course of such contact may be created and retained by ClearRisk Inc.

ClearRisk Inc. may also receive Personal Information from its business partners and other third

parties, but only in circumstances where such third parties confirm that you have specifically

and knowingly permitted them to share such information. ClearRisk Inc. does not otherwise

collect Personal Information about you.

(3) “Non-Personal Information” is information of an anonymous nature, such as an internet

protocol address (“IP address”), the domain used to access ClearRisk Inc.’s website, and the

type and version of browser or operating system being used. Aggregate information, such as

demographic statistics of users, number of visitors and average time spent on the website, is

also considered Non-Personal Information.

(4) Non-Personal Information is collected or derived by ClearRisk Inc. in the course of operating

its website. Non-Personal Information is used by ClearRisk Inc. as described here:

(a) Cookies: When you visit ClearRisk Inc.’s website, one or more cookies – a small file

containing a string of characters – is sent to your computer that uniquely identifies your browser.

ClearRisk Inc. uses cookies to improve quality of service by storing user preferences and

tracking user trends, such as how people search.

(b) Log information: When you visit ClearRisk Inc.’s website, servers automatically record

information that your browser sends whenever you visit a website. These server logs may

include information such as your web request, IP address, browser type, browser language, the

date and time of your request and one or more cookies that may uniquely identify your browser.

ClearRisk Inc. uses this information to improve the provision of its website services.

(c) Links: ClearRisk Inc. may present links in a format that enables it to keep track of whether

these links have been followed. ClearRisk Inc. uses this information to improve the quality of its

search technology, customized content and advertising.

(5) The ClearRisk Inc. website may contain links to other websites and services, including

social media websites and blogs. Please understand and be aware that this Website Privacy

and Security Policy applies only to the ClearRisk Inc. website and that information voluntarily

disclosed by you on other websites, including social media websites and blogs, may be

collected and used by others.

3. Use of Personal Information

ClearRisk Inc. uses your Personal information for the following purposes:

(a) Providing you with the services and information you have requested from Clear Risk Inc.,

including your use of the ClearRisk Inc. website, and maintenance and improvement of that

use. This includes processing, administering and managing your subscription with ClearRisk

Inc. ClearRisk Inc. may from time to time use your Personal Information to contact you about

changes, enhancements or similar notices related to the website.

(b) Responding to your inquiries and correspondence, should you choose to contact ClearRisk

Inc.

(c) If you indicate that you are interested in receiving offers or information from ClearRisk Inc. or

certain of our selected sponsors or advertisers, ClearRisk Inc. or such sponsors or advertisers

may send you e-mail materials and other mailings about products and services that may be

of interest to you. If at any time you would like to end your subscription(s) to any such e-mail

materials, you may follow the directions posted at the bottom of the e-mail materials.

(d) If you enter a contest or other promotion offered on the ClearRisk Inc. website, ClearRisk

Inc. may, under the rules of the promotion, use your name and certain other information to

administer the promotion, such as contacting, announcing and promoting the winners of the

promotion.

(e) ClearRisk Inc. may also use Personal Information to meet any legal, regulatory or

security requirements that involve use or disclosure of your Personal Information, including

where ClearRisk Inc. has reasonable grounds to believe the information could be useful to

investigation of a contravention of law, including federal, provincial and foreign laws. ClearRisk

Inc. may also use Personal Information in order to protect or defend its legal interests.

4. Disclosure of Personal Information

(1) ClearRisk Inc. will not sell, rent or disclose your Personal Information to third parties, except

in any one of the following circumstances:

(a) Where you have specifically and knowingly given us your consent to disclose your Personal

Information for a designated purpose.

(b) Where the third parties are acting on behalf of ClearRisk Inc. as agents, suppliers or service

providers, solely to enable ClearRisk Inc. to more efficiently provide you with the website

services and information. Such entities act under strict contractual controls, requiring them to

maintain the confidentiality of all such Personal Information and to use such information solely

for purposes related to the provision of the website services and information.

(c) As may be set out in the Website Terms and Conditions.

(d) As required by law, including by an order of any court, institution or body with jurisdiction or

authority to compel the production of information, or in order to protect or defend a legal interest.

(e) In connection with a corporate reorganization of ClearRisk Inc., merger or amalgamation

with another entity, or a sale of all or a substantial portion of the assets of ClearRisk Inc.,

provided that the Personal Information disclosed continues to be used by the entity acquiring it

solely for the purposes permitted by this policy.

(2) Where ClearRisk Inc. discloses information to its third party agents, suppliers or service

providers, as permitted by this policy, such information may be stored by the third parties

in the United States or other foreign jurisdictions. In such circumstances, the information in

the possession of the third parties is subject to the laws of the United States or other foreign

jurisdiction, as the case may be, and may be subject to disclosure by the third parties to foreign

governments, courts or law enforcement agencies through the application of such laws.

5. Links to Other Sites and Advertisements

The ClearRisk Inc. website may contain links to other websites and services. While ClearRisk

Inc. tries to link only to sites and services that share its high standards and respect for privacy,

please understand that ClearRisk Inc. is not responsible for the content of, or the privacy

practices employed by, other companies or websites. This Website Privacy and Security Policy

applies only to the ClearRisk Inc. website.

6. Security

(1) The security of your Personal Information is important to ClearRisk Inc. ClearRisk Inc. takes

technical, contractual, administrative and physical security steps to protect Personal Information

that you provide to us. Clear Risk Inc. takes various security measures, including the use

of secured networks, to protect against unauthorized access to, or unauthorized alteration,

disclosure or destruction of, your Personal Information. These measures also include internal

reviews of ClearRisk Inc.’s data collection, storage and processing practices. ClearRisk Inc.

instructs its employees with access to your Personal Information that it is to be used only in

adherence with the principles set forth in this Website Privacy and Security Policy and the laws

applicable to each specific business.

(2) You can help protect the security of your Personal Information as well. For instance, never

give out your password, since this is what is used to access your account or registration

information. Also, remember to log out of your account and close your browser window when

you finish using the ClearRisk Inc. website or surfing the Web, so that other people using

the same computer will not have access to your information. You must notify ClearRisk Inc.

immediately of any unauthorized use of your password or account, or of any other breach of

security. ClearRisk Inc. is not liable for any loss or damage arising from your failure to protect

your password or account information.

7. Accessing and Changing Account Information

ClearRisk Inc. provides you with the means to access your Personal Information and either

correct this data if it is inaccurate or delete such data that is not otherwise required to be

retained by law or for a legitimate business purpose. ClearRisk Inc. requires that you identify

yourself and the information requested to be accessed, corrected or removed before processing

your request. ClearRisk Inc. may decline to process requests that are unreasonably repetitive

or systematic, require disproportionate technical effort, jeopardize the privacy of others, or that

would be extremely impractical to satisfy (for instance, requests concerning information residing

on backup tapes), or for which access is not otherwise required.

8. Changes to this Website Privacy and Security Policy

ClearRisk Inc. may from time to time change its Website Privacy and Security Policy. Changes

will be effective when notice of such change is posted on the ClearRisk Inc. website. Please

check this policy regularly for updates by checking the date of “Last Modified” at the top of this

document.

9. Questions, Comments or Suggestions

If you have any questions, comments or suggestions about this Website Privacy and Security

Policy or ClearRisk Inc.’s privacy practices that were not answered here, please contact us at

feedback@clearrisk.com.