BRIERLEY+PARTNERS CORPORATE PRIVACY POLICY

Brierley+Partners provides loyalty and customer relationship management ("CRM") services to our clients. These services include data collection and bulk e-mail services. The privacy policy applies to our corporate web site, www.brierley.com. Brierley+Partners also adheres to the Privacy Policy of its clients when collecting, storing, and transmitting data for the purposes of loyalty and CRM services.

Brierley+Partners has been awarded TRUSTe's Privacy Seal signifying that this privacy policy and practices have been reviewed by TRUSTe for compliance with TRUSTe's Program Requirements and the TRUSTed Cloud Program Requirements including transparency, accountability and choice regarding the collection and use of your personal information. TRUSTe's mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy trustmark and innovative trust solutions. If you have questions or complaints regarding our privacy policy or practices, please contact us at privacy@brierley.com, or 214-760-8700. If you are not satisfied with our response you can contact TRUSTe here.

Brierley+Partners complies with the U.S. – E.U. Safe Harbor Framework and the U.S. Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries and Switzerland. Brierley+Partners 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 Brierley+Partners's certification, please visit http://www.export.gov/safeharbor/

This Privacy Policy covers our collection, use and disclosure of information we collect through our website www.brierly.com, and our hosted Loyalty and CRM services. The use of information collected through our service shall be limited to the purpose of providing the service for which the Client has engaged Brierley+Partners.

Brierley+Partners is firmly committed to protecting your privacy and the privacy of our clients' customers. Because protecting your privacy is important to us, you may always submit concerns regarding our Privacy Policy to our privacy practices to privacy@brierley.com. If you choose to write us an e-mail, please reference the Privacy Policy in your subject line. Brierley+Partners will attempt to respond to all reasonable concerns and inquiries expeditiously.

The Information We Collect
Brierley+Partners collects information such as name, email address, mailing address, and company information. We also collect unique identifies such as user name and password as necessary for the Loyalty Programs we support and host.

How We Use the Information we Collect
We use the information we collect to respond to your requests for information, administer your account and send you commercial communications.

Choice
We collect information for our clients, if you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the client that you interact with directly. If you are a Client and would like to update your account please contact us at privacy@brierley.com.

Corporate Anti-Spam Policy
Clients of Brierley+Partners have agreed to distribute commercial e-mail through Brierley+Partners systems for the purpose of their marketing efforts. Brierley+Partners and its Clients have agreed to adhere to the CAN-SPAM Act.

You may chose to stop receiving commercial emails by following the unsubscribe instructions included in this emails or contact us at privacy@brierley.com.

If you feel that you have received unsolicited commercial email from Brierley+Partners please send an email to: abuse@brierley.com. Please include or attach the unsolicited e-mail referenced in the abuse e-mail.

Sharing
We may provide your personal information to companies that provide services to help us with our business activities such as providing analytics or offering customer service. These companies are authorized to use your personal information only as necessary to provide these services to us.

We will share your personal information with third parties only in the ways that are described in this privacy statement. We do not sell your personal information to third parties.

We may also disclose your personal information

Website Activity
Brierley+Partners collects anonymous information about visitors to it's corporate web sites and web sites it hosts on behalf of its customers. The type of information collected includes Internet Protocol (IP) addresses which is used to identify information like web pages visited, unique visits, types of browsers used, and web browser session-based activity. This information is not linked to any personally identifiable information.

Use of Cookies
A cookie is a small text file that is stored on a user's computer for record-keeping purposes. We use cookies on this site and the sites we host and support for our clients. We do not link the information we store in cookies to any personally identifiable information you submit while on our site.

We may use both session ID cookies and/or persistent cookies. We may use session cookies to make it easier for you to navigate our site. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser's "help" file.

http://en.wikipedia.org/wiki/HTTP_cookie

http://www.microsoft.com/info/cookies.mspx

If you reject cookies, you may still use our site, but your ability to use some areas of our site, such as contests or surveys, will be limited.

Also, Brierley+Partners may use cookies on our customer web sites in an anonymous fashion to track overall website performance. Additionally, Brierley+Partners may use third party web analytics services to help us track and optimize our website performance. The service uses Scripts and Log Files to track non-personally identifiable information. These third parties are prohibited from using collected data for any purpose other than as a service provider to Brierley+Partners.

Website Security
Information collected through www.brierley.com and client hosted web sites is done via a secure (SSL) web interface and maintained within a secure operating environment. Our team of infrastructure and security professionals continually monitors our web interfaces and ensures technology updates are made regularly to deter any attempts for unwanted intrusion.

We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Web site, you can contact us at privacy@brierley.com.

Access
If your personally identifiable information changes, or if you no longer desire our service, you may correct, update, amend, delete/remove, by making the change on our member information page or by contacting us by telephone, email, or postal mail at the contact information listed below. We will respond to your request to access within 30 days.

Data Retention:
Brierley+Partners will retain your personal data and data we process on behalf of our Clients for as long as needed provide you servicers or services to our Clients. Brierley+Partners will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Appended Information:
The Brierley+Partners may supplement/append the data it collects for their Clients with additional data received from third party sources.

Links
The Brierley+Partners corporate web site may include links to other Internet sites that are not operated or controlled by Brierley+Partners. We cannot control and are not responsible for the privacy practices or the content of such Web sites. This may additionally be true for web sites hosted by Brierley+Partners on behalf of our customers.

Social Media (Features) and Widgets:
Our Web site includes Social Media Features, such as the Facebook and Twitter button [and Widgets, such as the Share this button or interactive mini-programs that run on our site]. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

Notification of Changes to our Privacy Policy
If we decide to change our privacy policy, we will post those changes to this privacy statement hosted at www.brierley.com. We may additionally post these changes in other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

We reserve the right to modify this privacy statement at any time. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

If you have questions or concerns regarding this Policy, you should first contact privacy@brierley.com. If contacting us does not resolve your complaint, you may raise your complaint with TRUSTe by Internet here, or by fax at 415-520-3420 or mail to TRUSTe Safe Harbor Compliance Dept., click for mailing address. If you are faxing or mailing TRUSTe to lodge a complaint, you must include the following information: the name of company, the alleged privacy violation, your contact information, and whether you would like the particulars of your complaint shared with the company. For information about TRUSTe or the operation of TRUSTe's dispute resolution process, click here or request this information from TRUSTe at any of the addresses listed above. The TRUSTe dispute resolution process shall be conducted in English.

Brierley+Partners
Attention: Privacy
5800 Tennyson Parkway
Suite 300
Plano, TX 75024
Phone: 214.760.8700
Fax: 214.743.5514

Email: privacy@brierley.com

Last Updated: December 21, 2011