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ClearStar, Inc. Privacy Statement

ClearStar, Inc. ("we," "us" or "our") is a trusted provider of technology solutions for background screening companies (ClearStar Technology Customers). ClearStar, Inc. is committed to protecting privacy and providing a safe and secure online experience. This Privacy Statement applies to ClearStar, Inc. Web sites and governs data collection and usage. By using the ClearStar, Inc. Web sites, you acknowledge and consent to the data practices described in this Privacy Statement.

This ClearStar, Inc. Privacy Statement (Privacy Statement) applies to the ClearStar, Inc. Web sites used and controlled solely by ClearStar, Inc. (collectively the ClearStar, Inc. Web sites). This Privacy Statement is not applicable to any ClearStar Technology Customer Web site or Web page, including without limitation any ClearStar, Inc. Web site or Web page utilized by a ClearStar Technology Customer.

Protecting consumer privacy is important to ClearStar, Inc. This Privacy Statement outlines our general policy and practices relating to information privacy, including the types of information we gather, how we use it and the notice and choice affected individuals have regarding our use of and their ability to correct that information.

Definitions
In this Privacy Statement Section:

"Personal Information" or "Information" means information that (1) is recorded in any form; (2) is about, or pertains to a specific individual; and (3) can be linked to that individual.

"Sensitive Personal Information" means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual's health.

ClearStar Technology Customers' Privacy Policies
This ClearStar, Inc. Privacy Statement is not applicable to any ClearStar Technology Customer. ClearStar, Inc. does not and cannot control the privacy policies of its ClearStar Technology Customers, including without limitation the types of information they gathers, how they use that information, the notice and choice affected individuals have regarding their use of that information, or the ability of affected individuals to correct that information. While the ClearStar, Inc. technology is configured to allow any ClearStar Technology Customer to have the same or similar privacy policies and practices as ClearStar, Inc., whether or not a ClearStar Technology Customer adopts such privacy policies and practices is at a customer's sole discretion.

Any individual affected by a ClearStar Technology Customer's collection or use of Personal Information or Sensitive Personal Information is strongly encouraged to obtain and review any Privacy Statement, privacy policy and/or privacy practice of that specific ClearStar Technology Customer, rather than rely on ClearStar, Inc.'s Privacy Statement for guidance as to the policy and practices of any specific ClearStar Technology Customer.

Collection and Use of Personal Information and Sensitive Personal Information
The Personal information of customers, prospective customers, business partners, prospective business partners, vendors, and prospective vendors, is collected and used by ClearStar, Inc. for legitimate business reasons such as customer service, account management, business administration, accounts payable and receivable, other financial purposes, marketing, and sales. ClearStar, Inc. does not collect or use any Sensitive Personal Information of customers, prospective customers, business partners, prospective business partners, vendors, and prospective vendors, except as required by law. ClearStar, Inc. may share some of your Personal Information or any collected Sensitive Personal Information with trusted third-part agents of ClearStar, Inc. to help us perform statistical analysis, send you email or postal mail, provide customer service, or arrange for deliveries. Any such disclosure will be limited to the minimum Personal information required to fulfill the purpose of the disclosure. Further, all third-party agents are prohibited from using your Personal information or Sensitive Personal Information except to provide these services as a third-party agent of ClearStar, Inc. All such third-party agents are required to maintain the confidentiality of your Personal Information and Sensitive Personal Information.

The Personal Information of employees, employees' family members, and prospective employees, is collected and used by ClearStar, Inc. for legitimate human resources business reasons such as: recruiting, screening and hiring applicants; payroll and employee benefits administration, employee performance management; employee security, health and safety management; company network access and administration; and meeting governmental reporting requirements. ClearStar, Inc. does not collect or use any Sensitive Personal Information of employees, employees' family members, and prospective employees, except as required by law. ClearStar, Inc. may share some of Your Personal Information or any collected Sensitive Personal Information with trusted third-part agents of ClearStar, Inc. to help us perform human resources and security related administrative functions, send you email or postal mail, or arrange for deliveries. Any such disclosure will be limited to the minimum Personal Information required to fulfill the purpose of the disclosure. Further, all third-party agents are prohibited from using your Personal Information and Sensitive Personal Information except to provide these services as a third-party agent of ClearStar, Inc. All such third-party agents are required to maintain the confidentiality of your Personal Information and Sensitive Personal Information.

ClearStar, Inc. does not collect the Personal Information or Sensitive Personal Information of individuals who are the subject of ClearStar Technology Customers' background checks. To the extent ClearStar, Inc. uses the Personal Information and Sensitive Personal Information collected by ClearStar Technology Customers, ClearStar, Inc. uses such Personal Information and Sensitive Personal Information for the legitimate business reason of providing technology services to ClearStar Technology Customers.

The Personal Information and Sensitive Personal Information of individuals who are the subject of ClearStar Technology Customers' background checks is collected and used by ClearStar Technology Customers for their own purposes and the purposes of their respective customers. The privacy policy and practices of ClearStar's Technology Customers are outside of the control of ClearStar, Inc. and are not applicable to this Privacy Statement. If you are an individual affected by the collection or use of your Personal Information or Sensitive Personal Information by a ClearStar Technology Customer, ClearStar, Inc. strongly encourages you to obtain and review any Privacy Statement, privacy policy and/or privacy practice of that specific ClearStar Technology Customer, rather than rely on ClearStar, Inc.'s Privacy Statement for guidance as to the policy and practices of any specific ClearStar Technology Customer.

ClearStar, Inc. does not disclose any Personal Information or Sensitive Personal Information to any non-agent third-parties unless: required to do so by law; acting in the good faith belief that such action is necessary to conform to the edicts of the law or comply with legal process served on ClearStar, Inc. or a ClearStar Technology Customer; protecting or defending the rights or property of ClearStar, Inc. or a ClearStar Technology Customer; or acting under exigent circumstances to protect an individual's personal safety or public safety.

All Personal Information and Sensitive Personal Information collected or used by ClearStar, Inc. will be protected, secured and used in a manner consistent with this Policy and applicable law.

Please do not provide any Personal Information or Sensitive Personal Information on any ClearStar, Inc. public message board. Any Personal Information and Sensitive Personal Information disclosed by you through a ClearStar, Inc. public message board is publicly accessible and may be collected and used by a third-party without your or ClearStar, Inc.'s knowledge or consent. ClearStar, Inc. is not responsible for the unauthorized collection or use of any Personal Information or Sensitive Personal Information you disclose in any public ClearStar, Inc. message board.

In addition, ClearStar, Inc. strongly encourages you to review the privacy statements of Web sites you choose to link to from ClearStar, Inc. so that you can understand how those Web sites collect, use and share your information. ClearStar, Inc. is not responsible for the privacy statements or other content on Web sites outside of the ClearStar, Inc. Web sites.

Use of Tracking Technology and Cookies
ClearStar, Inc. keeps track of the ClearStar, Inc. Web sites and Web pages visited and how users navigate throughout the site for the purposes of improving the user experience, and delivering customized content and ClearStar, Inc. advertising to customers whose behavior indicates that they are interested in a particular subject area. ClearStar, Inc. also collects anonymous demographic information about the computer hardware and software used to access the ClearStar, Inc. Web sites.

The ClearStar, Inc. Web sites use "cookies" to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a Web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize ClearStar, Inc. pages, or register with ClearStar, Inc. sites or services, a cookie helps ClearStar, Inc. to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same ClearStar, Inc. Web site, the information you previously provided can be retrieved, so you can easily use the ClearStar, Inc. features that you customized.

You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the ClearStar, Inc. services or Web sites you visit.

Notice
ClearStar, Inc. will inform an individual of the purpose for which it collects and Uses PERSONAL INFORMATION and Sensitive Personal Information and the types of non-agent third-parties to which ClearStar, Inc. discloses or may disclose that Information, at the time of ClearStar, Inc.'s collection of Personal Information or Sensitive Personal Information. ClearStar, Inc. will also provide the individual with the choice and means for limiting the use and disclosure of their Personal Information or Sensitive Personal Information, at the time of ClearStar, Inc.'s collection of Personal Information or Sensitive Personal Information. Notice will be provided in clear and conspicuous language when individuals are first asked by ClearStar, Inc. to provide Personal Information or Sensitive Personal Information, or as soon as practicable thereafter, and in any event before ClearStar, Inc. uses or discloses the Information for a purpose other than for which it was originally collected.

Choice and Onward Transfers
ClearStar, Inc. will not disclose any Personal Information or Sensitive Personal Information to a non-agent third-party for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual , nor use the Personal Information or Sensitive Personal Information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

Data Security
ClearStar, Inc. will take reasonable steps to protect the Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. ClearStar, Inc. has put in place appropriate physical, electronic and managerial procedures to safeguard and secure the Information from loss, misuse, and unauthorized access, disclosure, alteration and destruction. ClearStar, Inc. cannot guarantee the security of Information on or transmitted via the Internet.

ClearStar, Inc. secures your Personal Information and Sensitive Personal Information from unauthorized access, use or disclosure. ClearStar, Inc. secures the Personal Information and Sensitive Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. When personal information (such as a credit card number) is transmitted to other Web sites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol.

Data Integrity
To the extent ClearStar, Inc. processes Personal Information and Sensitive Personal Information, ClearStar, Inc. will only process Personal Information and Sensitive Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, ClearStar, Inc. will take reasonable steps to ensure that Personal Information and Sensitive Personal Information is accurate, complete, current and reliable for its intended use.

Access Where ClearStar, Inc. originally collected the Personal Information or Sensitive Personal Information, ClearStar, Inc. will allow an individual access to their Personal Information or Sensitive Personal Information and allow the individual to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated. The individual seeking the correction, amendment or deletion of inaccurate Personal Information or Sensitive Personal Information has the burden of proving the Personal Information or Sensitive Personal Information is inaccurate to the satisfaction of ClearStar, Inc.

The preceding paragraph is inapplicable to any Personal Information or Sensitive Personal Information originally collected by a ClearStar Technology Customer. Whenever the Personal Information or Sensitive Personal Information was originally collected by a ClearStar Technology Customer, an individual's access and to their Personal Information or Sensitive Personal Information and their ability to correct, amend or delete inaccurate information, is outside of ClearStar, Inc.'s control at the sole discretion of the ClearStar Technology Customer who originally collected the Individual's PERSONAL INFORMATION or Sensitive Personal Information.

Enforcement
ClearStar, Inc. uses a self-assessment approach to assure compliance with this privacy policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with this Privacy Statement. We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Information or Sensitive Personal Information in accordance with this Privacy Statement.

Amendments
This privacy policy may be amended by ClearStar, Inc. from time to time. ClearStar, Inc. will post any revised policy on the ClearStar, Inc. Web sites.

Information Subject to Other Policies
ClearStar, Inc. is committed to following this Privacy Statement for all Personal Information and Sensitive Personal Information. However, certain information is subject to policies of ClearStar, Inc. that may differ in some respects from the general policies set forth in this privacy policy.

Changes to this Statement
ClearStar, Inc. will occasionally update this Privacy Statement to reflect company and customer feedback. ClearStar, Inc. encourages you to periodically review this Statement to be informed of how ClearStar, Inc. is protecting your information.

Contact Information
Questions, comments or complaints regarding ClearStar, Inc.'s Privacy Policy can be mailed or emailed to:

ClearStar, Inc.
Attn: Privacy Administrator
PO Box 1003
Cumming, GA 30028
877.796.2559
privacy@clearstar.net

Effective date: January 1, 2012

ClearStar Logistics, Inc. Privacy Statement

ClearStar Logistics, Inc. ("ClearStar Logistics," "we," "us" or "our") is a leading consumer reporting agency. Protecting consumer privacy is important to ClearStar Logistics. ClearStar Logistics is committed to protecting your privacy and providing a safe and secure online experience. This Privacy Statement applies to ClearStar Logistics Web sites and governs data collection and usage. By using ClearStar Logistics Web sites, you consent to the data practices described in this statement.

Definitions
In this Privacy Statement Section:

"Personal Information" or "Information" means information that (1) is recorded in any form; (2) is about, or pertains to a specific individual; and (3) can be linked to that individual.

"Sensitive Personal Information" means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual's health.

Collection and Use of Personal Information and Sensitive Personal Information
ClearStar Logistics collects Personal Information and Sensitive Personal Information. ClearStar Logistics also collects anonymous demographic information, which is not unique to you, such as your ZIP code, age, gender, preferences, interests and favorites.

There is also information about your computer hardware and software that is automatically collected by ClearStar Logistics. This information can include: your IP address, browser type, domain names, access times and referring Web site addresses. This information is used by ClearStar Logistics for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the ClearStar Logistics Web sites.

Please keep in mind that if you directly disclose Personal Information or Sensitive Personal Information through ClearStar Logistics public message boards, this information may be collected and used by others.

ClearStar Logistics encourages you to review the privacy statements of Web sites you choose to link to from ClearStar Logistics so that you can understand how those Web sites collect, use and share your information. ClearStar Logistics is not responsible for the privacy statements or other content on Web sites outside of the ClearStar Logistics family of Web sites.

Use of your Personal Information
ClearStar Logistics collects and uses your Personal Information and Sensitive Personal Information, if applicable, to operate ClearStar Logistics Web sites and deliver the services you or ClearStar Logistics customers have requested. ClearStar Logistics may also use your Personal Information to inform you of other products or services available from ClearStar Logistics and its affiliates. ClearStar Logistics may also contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered.

ClearStar may transfer your Personal Information and Sensitive Personal information to third parties for the purposes of delivering the services you or ClearStar Logistics customers have requested. These third parties are prohibited from using your Personal Information and Sensitive Personal Information except to assist ClearStar Logistics in delivering the services you or ClearStar Logistics customers have requested, and they are required to maintain the confidentiality of your information.

ClearStar Logistics does not sell, rent or lease its customer lists to third parties. ClearStar Logistics may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your unique Personal Information and Sensitive Personal Information are not transferred to the third party. In addition, ClearStar Logistics may share data with trusted partners to help us perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. These third parties are prohibited from using your Personal Information or Sensitive Personal Information except to provide these services to ClearStar Logistics, and they are required to maintain the confidentiality of your information.

ClearStar Logistics keeps track of the Web sites and pages our customers visit within ClearStar Logistics, in order to determine what ClearStar Logistics services are the most popular and to improve the user experience. This data may also be used to deliver customized content and advertising within ClearStar Logistics to customers whose behavior indicates that they are interested in a particular subject area.

ClearStar Logistics will disclose your Personal Information and Sensitive Personal Information, to other third parties, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on ClearStar Logistics or the site; (b) protect and defend the rights or property of ClearStar Logistics; and, (c) act under exigent circumstances to protect the personal safety of users of ClearStar Logistics, or the public.

Use of Cookies
The ClearStar Logistics Web sites use "cookies" to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a Web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize ClearStar Logistics pages, or register with ClearStar Logistics sites or services, a cookie helps ClearStar Logistics to recall your specific information on subsequent visits. This simplifies the process of recording your Personal Information, such as billing addresses, shipping addresses, and so on. When you return to the same ClearStar Logistics Web site, the information you previously provided can be retrieved, so you can easily use the ClearStar Logistics features that you customized.

You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the ClearStar Logistics services or Web sites you visit.

Security of your Personal Information
ClearStar Logistics secures your Personal Information and Sensitive Personal Information from unauthorized access, use or disclosure. ClearStar Logistics secures the Personal Information and Sensitive Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. When Personal Information (such as a credit card number) is transmitted to other Web sites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol.

Personal information Disclosure: United States or Overseas
Your Personal Information and Sensitive Personal information may be transferred to third parties outside the United States or its territories for the purposes of delivering the services you or ClearStar Logistics customers have requested. These third parties are prohibited from using your Personal Information and Sensitive Personal Information except to assist ClearStar Logistics in delivering the services you or ClearStar Logistics customers have requested, and they are required to maintain the confidentiality of your information.

Changes to this Statement
ClearStar Logistics will occasionally update this Privacy Statement to reflect company and customer feedback. ClearStar Logistics encourages you to periodically review this Statement to be informed of how ClearStar Logistics is protecting your information.

Contact Information
Questions, comments or complaints regarding ClearStar Logistics' Privacy Policy can be mailed or emailed to:

ClearStar Logistics, Inc.
Attn: Privacy Administrator
PO Box 1003
Cumming, GA 30028
877.796.2559
privacy@clearstar.net

Effective date: January 1, 2012

Safe Harbor Policy

Introduction
ClearStar Logistics adheres to the Safe Harbor Agreement concerning the transfer of personal data from the European Union ("EU") and Switzerland to the United States of America. Accordingly, we follow the Safe Harbor Principles published by the U.S. Department of Commerce (the "Principles") with respect to all such data. This Privacy Statement outlines our general policy and practices for implementing the Principles, including the types of information we gather, how we use it and the notice and choice affected individuals have regarding our use of and their ability to correct that information.

Definitions
In this Safe Harbor Policy Section:

"Personal Information" or "Information" means information that (1) is transferred from the EU and/or Switzerland to the United States; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and (4) can be linked to that individual.

"Sensitive Personal Information" means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual's health.

Principles

Notice
ClearStar Logistics will inform an individual of the purpose for which it collects and uses the Personal Information and the types of non-agent third parties to which ClearStar Logistics discloses or may disclose that Information. ClearStar Logistics will provide the individual with the choice and means 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 ClearStar Logistics, or as soon as practicable thereafter.

Choice and Onward Transfers
ClearStar Logistics will not disclose any Personal Information or Sensitive Personal information to a non-agent third party for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual, nor use the Personal Information or Sensitive Personal Information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

Data Security
ClearStar Logistics will take reasonable steps to protect the Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. ClearStar Logistics has put in place appropriate physical, electronic and managerial procedures to safeguard and secure the Information from loss, misuse, and unauthorized access, disclosure, alteration and destruction. ClearStar Logistics cannot guarantee the security of Information on or transmitted via the Internet.

Data Integrity
ClearStar Logistics will only process Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, ClearStar Logistics will take reasonable steps to ensure that Personal Information is accurate, complete, current and reliable for its intended use.

Access
ClearStar Logistics will allow an individual access to their Personal Information and allow the individual to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated. Except where other applicable laws or regulations shift this burden to ClearStar Logistics, the individual seeking the correction, amendment or deletion of inaccurate information has the burden of proving the Personal information is inaccurate to the satisfaction of ClearStar Logistics.

Enforcement
ClearStar Logistics uses a self-assessment approach to assure compliance with this Privacy Statement and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Principles. We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Information in accordance with the Principles.

If a complaint or dispute cannot be resolved through our internal process, we agree to dispute resolution using the European Data Protection Authorities and Swiss Data Protection Authorities as a third party resolution provider.

Amendments
This Privacy Statement may be amended from time to time consistent with the requirements of the Safe Harbor. We will post any revised policy on the ClearStar Logistics Web sites.

Information Subject to Other Policies
ClearStar Logistics is committed to following the Principles for all Personal Information within the scope of the Safe Harbor Agreement. However, certain information is subject to policies of ClearStar Logistics that may differ in some respects from the general policies set forth in this Privacy Statement.

Privacy Complaints by European Union Citizens and Switzerland Citizens:
In compliance with the Safe Harbor Principles, ClearStar Logistics commits to resolve complaints about your privacy and our collection or use of your personal information. EU citizens or Switzerland citizens with inquiries or complaints regarding this privacy policy should first contact:

ClearStar Logistics
Attn: Privacy Administrator
418 Pirkle Ferry Road, Ste 109
Cumming, GA 30040
privacy@clearstarlogistics.net

ClearStar Logistics has further committed to refer unresolved privacy complaints under the Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU Safe Harbor, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by ClearStar Logistics, you may contact:

Council of Better Business Bureaus, Inc.
BBB EU Safe Harbor
4200 Wilson Boulevard, Suite 800
Arlington, VA 22203
Phone: 703-276-0100
Web: www.bbb.org/us
Email: eusafeharbor@council.bbb.org

Effective date: January 1, 2012