Safe Harbor Privacy Policy

Successful Channels respects individual privacy and values the confidence of its customers, employees, , business partners and others. Not only does Successful Channels strive to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business, but it also has a tradition of upholding the highest ethical standards in its business practices. This Safe Harbor Privacy Policy (the “Policy”) sets forth the privacy principles Successful Channels follows with respect to transfers of personal information from the European Economic Area (EEA) (which includes the twenty-eight member states of the European Union (EU) plus Iceland, Liechtenstein and Norway).

Safe Harbor

The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EEA to the United States (the " Safe Harbor Principles"). The EEA 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, Successful Channels adheres to the principles set forth in the Safe Harbor Principles.

Successful Channels complies with the U.S.-EU Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. Successful Channels has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Successful Channels’s certification, please visit http://www.export.gov/safeharbor/.

Scope

This Safe Harbor Privacy Policy (the "Policy") applies to all personal information received by Successful Channels in the United States from the EEA, in any format, including electronic, paper or verbal.

Definitions

For purposes of this Policy, the following definitions shall apply: "Agent" means any third party that collects or uses personal information under the instructions of, and solely for, Successful Channels or to which Successful Channels discloses personal information for use on Successful Channels' behalf.

"Successful Channels" means Successful Channels Incorporated, its predecessors, successors, affiliates, divisions and groups in the United States.

"Personal information" means any information or set of information that identifies or could be used by or on behalf of Successful Channels 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, political opinions, religious or philosophical beliefs, trade union membership, views or activities, that concerns health or healthcare, information about social security benefits, or information on criminal or administrative proceedings and sanctions other than in the context of pending proceedings. In addition, Successful Channels will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.

Successful Channels Privacy Principles

The privacy principles in this Policy have been developed based on the Safe Harbor Principles.

Summary

• 1) Notice: Informs app users about purpose of data collected and if it is shared for any purpose
• 2) Choice: Any app user is provided the option to opt out
• 3) Data Integrity: Only relevant data collected and will be complete
• 4) Transfers to Agents: If any data transfers happen, Successful Channels will only do with compliant agents
• 5) Access and Correction: Individuals have the ability to view, edit, and update data
• 6) Security: Strict security policies are followed to keep data secure
• 7) Enforcement: Safe Harbor audits are completed 2x per year

NOTICE: Where Successful Channels collects personal information directly from individuals in the EEA, 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 Successful Channels discloses that information, the choices and means, if any, Successful Channels offers individuals for limiting the use and disclosure of personal information about them, and how to contact Successful Channels. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to Successful Channels, or as soon as practicable thereafter, and in any event before Successful Channels uses or discloses the information for a purpose other than that for which it was originally collected.

Where Successful Channels receives personal information from its subsidiaries, affiliates or other entities in the EEA, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.

CHOICE: Successful Channels 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, Successful Channels 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.

Successful Channels will provide individuals with reasonable mechanisms to exercise their choices.

DATA INTEGRITY: Successful Channels will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Successful Channels will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.

TRANSFERS TO AGENTS: Successful Channels 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 Canada). Where Successful Channels has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, Successful Channels will take reasonable steps to prevent or stop the use or disclosure.

ACCESS AND CORRECTION: Upon request, Successful Channels will grant individuals reasonable access to personal information that it holds about them. In addition, Successful Channels will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. Successful Channels will not provide such access where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where the rights of persons other than the individual would be violated.

SECURITY: Successful Channels will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

ENFORCEMENT: Successful Channels will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that Successful Channels determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.

DISPUTE RESOLUTION: Successful Channels has put in place mechanisms to verify our ongoing adherence to these privacy principles. We encourage individuals covered by this Policy to raise any concerns that they have about the way that we process their personal data by contacting us at the address below, and we will do our best to resolve them. We have also agreed to participate in the dispute resolution program provided by the European Data Protection Authorities Panel.

Limitation On Application Of Principles

Adherence by Successful Channels to these Safe Harbor Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations; and (c) to the extent expressly permitted by an applicable law, rule or regulation.

Internet Privacy

Successful Channels sees the Internet and the use of other technology as valuable tools to communicate and interact with consumers, employees, healthcare professionals, business partners, and others. Successful Channels recognizes the importance of maintaining the privacy of information collected online and has created a specific Internet Privacy Policy (the "IPP") governing the treatment of personal information collected through web sites that it operates. With respect to personal information that is transferred from the European Economic Area to the U.S., the IPP is subordinate to this Policy. However, the IPP also reflects additional legal requirements and evolving standards with respect to Internet privacy. Successful Channels's Internet Privacy Policy can be found at http://www.Successfulchannels.com/safeharbor/

Contact Information

Questions or comments regarding this Policy should be submitted to the Successful Channels Privacy Office by mail to:

Successful Channels Privacy Office c/o Successful Channels Inc. 1672 Falmouth Road, PO Box 735 Centerville, MA 02632

Or by e-mail to the Successful Channels Privacy Office

AMENDMENTS This privacy policy may be amended from time to time consistent with the requirements of the Safe Harbor Principles. We will post any revised policy on this website.

INFORMATION SUBJECT TO OTHER POLICIES The Company is committed to following the Safe Harbor Principles for all Personal Information within the scope of the Policy. However, certain information is subject to policies of the Company that may differ in some respects from the general policies set forth in this Policy.

EFFECTIVE DATE: January 1st 2017