Safe Harbor Policy

Oxcyon, Inc.and its subsidiaries respect the privacy of their employees, users and customers and are committed to protecting employee, user and customer data maintained by the company. Due to the global nature of Oxcyon, Inc.’ business, transfers of employee and customer Personal Data, defined below, across national boundaries may occur. As a result, Oxcyon, Inc.has adopted this Safe Harbor Data Privacy Policy and adheres to the Safe Harbor Principles published by the U.S. Department of Commerce, in agreement with the European Commission, with respect to employee and customer Personal Data transferred from the European Union to the United States of America regarding employees, users and customers residing within the European Union.

This Policy applies to all Personal Data received by Oxcyon, Inc.in the United States from the European Union ("EU") in any format. For the purpose of this Policy, "Personal Data" or "Personal Information" is employee, user or customer data about an identified or identifiable EU-based employee, user or customer, received by Oxcyon, Inc.in the U.S. from the EU and recorded in any form.

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 (the "Safe Harbor Principles") to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EU to the United States. The EEA also has recognized the U.S. Safe Harbor as providing adequate data protection (OJ L 45, 15.2.2001, p.47). Consistent with its commitment to protect personal privacy, Oxcyon, Inc.adheres to the Safe Harbor Principles.

DEFINITIONS
For purposes of this Policy, the following definitions shall apply:
"Personal Information" means any information or set of information that identifies or is used by or on behalf of a Company to identify an individual. Personal information does not include information that is encoded or anonymyzed, 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, sexual orientation, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns an individual’s health. In addition, Oxcyon, Inc.will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.

PRIVACY PRINCIPLES
The privacy principles in this Policy are based on the Safe Harbor Principles.

NOTICE: Where Oxcyon, Inc.collects Personal Information directly from individuals in the EU, it will inform them about the type of Personal Information collected, the purposes for which it collects and uses the Personal Information, and the types of non-agent third parties to which Oxcyon, Inc.discloses or may disclose that information, and the choices and means, if any, Oxcyon, Inc.offers individuals 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 Oxcyon, Inc., or as soon as practicable thereafter, and in any event before Oxcyon, Inc.uses or discloses the information for a purpose other than that for which it was originally collected.
Where Oxcyon, Inc.receives personal information from their subsidiaries, affiliates or other entities in the EU, they 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: Oxcyon, Inc.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, Oxcyon, Inc.will give individuals the opportunity to affirmatively and explicitly (opt-out) 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.
Oxcyon, Inc.will provide individuals with reasonable mechanisms to exercise their choices.

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

TRANSFERS TO AGENTS: Oxcyon, Inc.will obtain assurances from their 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. Where Oxcyon, Inc.becomes aware that an agent is using or disclosing personal information in a manner contrary to this Policy, Oxcyon, Inc.will take reasonable steps to prevent or stop the use or disclosure.

ACCESS AND CORRECTION: Upon request, Oxcyon, Inc.will grant individuals reasonable access to personal information that it holds about them. In addition, Oxcyon, Inc.will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.

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

ENFORCEMENT: Oxcyon, Inc.will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Employees will be properly trained to adhere to these principles. Any employee that Oxcyon, Inc.determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment. Oxcyon, Inc.is subject to the laws and regulations of the Federal Trade Commission.

DISPUTE RESOLUTION: Any questions or concerns regarding the use or disclosure of personal information should be directed to the Oxcyon, Inc.Compliance Office at the address given below. Oxcyon, Inc.will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Policy.

LIMITATION ON APPLICATION OF PRINCIPLES
Adherence by Oxcyon, Inc.to these Safe Harbor Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; and (b) to the extent expressly permitted by an applicable law, rule or regulation. Oxcyon, Inc.commit to cooperate with data protection authorities located in the European Union and Switzerland or their authorized representatives.