Privacy Commitment

Introduction

• Greater ease of use
• Updated content areas
• Continued emphasis on our privacy mission

Lee Bruder Associates is a privacy conscious global organization and is strongly committed to your right to privacy. The Privacy Statement follows the guidelines set by the Online Privacy Alliance and is in accordance with international data protection legislation. By submitting identifying data, a visitor to our Web site is agreeing to Lee Bruder Associates' use of such data as described in this privacy statement. Should you have questions however, feel free to direct these to Lee Bruder.

The Lee Bruder Associates Privacy Mission

Generally, Lee Bruder Associates only collects identifiable information that is specifically and voluntarily provided by a visitor to our site. A visitor to our site may choose to provide this information to register for certain areas of the site, apply for a job, or order a publication. When a visitor provides this type of identifiable information to us, we use it solely for the purposes for which it was provided. Our policy is not to share personally identifiable information with third parties, unless required by law, or unless explicitly requested by a visitor. We recognise that your information is valuable and we take all reasonable measures to protect your information while it is in our care. We use small text files called cookies to improve the overall site experience, however, these are not used to track individual visitors to our site. The use of cookies is now standard operating procedure for most Web sites, however if you are uncomfortable with the use of cookies, most browsers now permit users to opt-out of receiving them. Our full privacy policy clearly states our commitment to creating a safe and enjoyable online experience for visitors to our site.

Internet Privacy Policy

The data controller collecting the data described herein is Lee Bruder Associates, professional services firm. Personal data collected by Lee Bruder Associates may be transferred to other individual Lee Bruder Associates' firms, which are member firms of the worldwide Lee Bruder Associates organization, where it is necessary to meet the purpose for which the visitor has submitted the information. By submitting data on Lee Bruder Associates' Web site, the visitor is providing explicit consent to transborder transmission of data collected on the Web site for the fulfilment of their voluntary requests.

Data Collection

We collect only personally identifiable information that is specifically and voluntarily provided by visitors to Lee Bruder Associates' Web site. Lee Bruder Associates receives limited identifiable information, such as name, Title, company address, email address, and telephone and fax numbers, from Web site visitors. Typically, identifying information is collected to:

• Register for certain areas of the site
• Inquire for further information
• Distribute requested reference materials, or
• Submit resumes.

Demographic information, including gender and occupation, is not actively sought, but may be submitted when a visitor responds to an online job application. It is Lee Bruder Associates' policy to limit the information collected to only the minimum information required to complete a visitor's request. In any instance where non-mandatory information is sought, the Web site visitor will be notified of this at the point of collection.

Although most publications are provided as downloads, visitors may also have the opportunity to purchase Lee Bruder Associates' publications either online, by calling toll free numbers, or by faxing order forms to our fulfilment houses. We will collect order information and a customer's credit card information, where applicable, in order to facilitate shipment and payment for the publication.

Visitors are also able to send email through the site. Their messages will contain the user's screen name and email address, as well as any additional information the user may wish to include in the message. Because we use the Web site as a recruiting tool, a visit to the Web site may also result in the user sending a resume to an individual within Lee Bruder Associates.

Lee Bruder Associates intention is not to seek any sensitive information through our Web site unless legally required for recruiting purposes. Sensitive information includes a number of types of data relating to: race or ethnic origin; political opinions; religious or other similar beliefs; trade union membership; physical or mental health; sexual life or criminal record. We suggest that you do not provide sensitive information of this nature. If you do wish to provide sensitive information for any reason, Lee Bruder Associates accepts your explicit consent to use that information in the ways described in this privacy statement or as described at the point where you choose to disclose this information.

Use of Data

A user may choose to provide personal information in the following examples:

• Order publications
• Submit resumes or work history information
• Participate in "join our mailing list" initiatives
• Participate in bulletin boards, discussion or message forums
• Contact us for further information
• Enter Quick Surveys, Quiz's or Benchmarking Surveys
• Register for events and conferences
• Register for premium online services

If you would like to find out more about the different categories of information collected, please review the data collection section.

Information attained by the site is used only for the intended purpose stated at the time that the information is collected. This data is not shared with other entities in the Firm for secondary or unrelated purposes, or shared with a third party, unless otherwise disclosed at the point of collection. If there is an instance where such information may be shared, the visitor will be asked for permission beforehand.

Lee Bruder Associates makes every practical effort to avoid excessive or irrelevant collection of data. If a visitor believes the site has collected excessive information, we encourage the visitor to contact Lee Bruder to raise any concerns.

Except for the mailing list initiative described above, where visitors explicitly choose to receive specific Lee Bruder Associates' marketing or other materials, Lee Bruder Associates will not use personal data collected from our Web sites to facilitate unsolicited marketing activities.

Cookies and Log Files

Cookies may be used on some pages of our site. "Cookies" are small text files placed on your hard drive that assist us in providing a more customised Web site experience. For example, a cookie can be used to store registration information in an area of the site so that a user does not need to re-enter it on subsequent visits to that area. It is Lee Bruder Associates' policy to use cookies to make navigation of our Web sites easier for visitors and to facilitate efficient registration procedures.

If you are concerned about cookies, most browsers permit individuals to decline cookies. In most cases, a visitor may refuse a cookie and still fully navigate our Web sites.

In order to properly manage our Web site we may anonymously log information on our operational systems, and identify categories of visitors by items such as domains and browser types. These statistics are reported in the aggregate to our webmasters. This is to ensure that our Web site presents the best web experience for visitors and is an effective information resource.

Third Parties

It is Lee Bruder Associates' policy only to disclose information to third parties under the following circumstances:

• as required by law through subpoena, search warrant or other legal process
• when explicitly requested by a visitor
• when required to deliver publications or reference materials requested by a visitor
• When required to facilitate conferences or events hosted by a third party.

Lee Bruder Associates' policy is to disclose information to third parties upon visitors submitting their requests (e.g. when ordering a publication, we display the party fulfilling the order).

Lee Bruder Associates' Web sites do not collect or compile personally identifying information for dissemination or sale to outside parties for consumer marketing purposes, or host mailings on behalf of third parties.

Third Party Links

There are several places throughout leebruderassociates.com that may link to other Web sites that do not operate under leebruderassociates.com's privacy practices. When you link to other Web sites, Lee Bruder Associates' privacy practices no longer apply. We encourage visitors to review each site's privacy policy before disclosing any personally identifiable information.

Data Retention

Some of the information we receive is not retained. For example, we usually do not keep mailing addresses for white papers. Contact information about visitors (such as information generated though registration for access to areas on the site) will be kept as long as the information is required to completely service the contact request or until a user requests that we delete that information. Mailing list information, discussion posts and email are kept for only the period of time considered reasonable to facilitate the visitor's requests. Resumes are disposed of when they are either no longer under consideration, or are considered dated by our Human Resources departments.

Choices

As a policy, visitors are not required to register to gain access to areas of the Lee Bruder Associates Web sites. In certain cases in the future, as your Lee Bruder Associates Web site experience expands, we may require visitors to register in order to obtain a user-id and password for authentication and secure access to a transaction or certain business confidential or proprietary information services on premium Web sites.

Personally identifiable information provided to Lee Bruder Associates through its Web site is provided voluntarily by visitors. Should visitors subsequently choose to unsubscribe from mailing lists or any registrations, we will provide instructions, on the appropriate Web site area or in communications to our visitors; or a visitor may contact the webmaster of the appropriate site by contacting Lee Bruder.

Access

Each visitor has the right of access to personal data they have submitted through the Web sites to Lee Bruder Associates.

User updates of information should be handled by going back through the registration process. Inquiries about the accuracy of identifying information previously submitted to Lee Bruder Associates through its Web site, or requests to have outdated information removed, should be directed to Lee Bruder. Lee Bruder Associates is committed to providing reasonable and practical access to visitors to allow them the opportunity to identify and correct any inaccuracies. When requested and practical, Lee Bruder Associates will delete identifying information from current operational systems.

When personally identifiable information is retained, Lee Bruder Associates assumes responsibility for keeping an accurate record of the information once a visitor has submitted and verified the data. Lee Bruder Associates does not assume responsibility for verifying the ongoing accuracy of the content of personal information. When practically possible, if Lee Bruder Associates is informed that any personal data collected through a Web site is no longer accurate, Lee Bruder Associates will make appropriate corrections based on the updated information provided by the authenticated visitor.

Security

Lee Bruder Associates has implemented generally accepted standards of technology and operational security in order to protect personally identifiable information from loss, misuse, alteration or destruction. All Lee Bruder Associates employees follow a firm wide security policy. Only authorised Lee Bruder Associates personnel are provided access to personally identifiable information and these employees have agreed to ensure confidentiality of this Lee Bruder information. Lee Bruder Associates' policy is to use secure socket layer technology for the protection of credit card information submitted through web forms when e-commerce solutions are provided. This policy is also required for any fulfilment agents of our firm.

Children

Lee Bruder Associates understands the importance of protecting children's privacy especially in an online environment. The Lee Bruder Associates' sites covered by this privacy statement are not intentionally designed for or directed at children 13 years of age or younger. It is Lee Bruder Associates' policy never to knowingly collect or maintain information about anyone under the age of 13.

Modifications

Lee Bruder Associates reserves the right to modify or amend this Statement at any time. The effective date will be displayed at the beginning of this statement. To keep visitors informed, Lee Bruder Associates will notify users of changes to our Privacy Statement by prominently identifying the alteration for a period of not less than two weeks on our global home page at http://www.leebruderassociates.com.

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Lee Bruder Associates ~ 141 Prospect Hill Road ~ Hancock, New Hampshire 03449