Last revised January 11, 2007

eePulse adheres to the principles set forth in the Safe Harbor framework as established by the U.S. Department of Commerce in conjunction with the European Commission regarding the collection, use and retention of personally identifiable information provided to us from the European Union. This Privacy Policy applies to all eePulse Web sites. It does not apply to the Web sites or operations of third parties.

Your privacy is important to us. We respect the privacy of visitors to our marketing web site and that of our clients and their respondent populations. We do not sell, rent or trade data submitted to us.

The Types of Information we collect

eePulse, Inc. collects a wide range of data through our secure site https://secure.eepulse.net about and from respondents (anyone submitting data via a survey conducted by eePulse, Inc.) depending on the information needs of the client. In addition, clients may provide us with demographic information such as respondent name, respondent job title, department, geographic region, etc. This information gives us the flexibility to create group reports of respondent data sorted by department, location etc. Personal information is NEVER connected with any of the data or reports seen by any client or third party unless authorized by the individual respondent. However, to make sure you do not inadvertently identify yourself, when submitting your response to comment questions, please refrain from writing comments like, "I just got back from vacation and found..." or anything that might cause you to disclose your identity or your company's identity directly or indirectly within your comment.

Before a user (a survey participant or manager viewing reports) can view secure information (e.g. individual or manager reports), the user must complete a registration process and establish logon credentials including user name and password. Users that only submit data via surveys typically are not required to complete the registration process or to enter logon credentials to complete a survey.

Visitors to our marketing web site (www.eepulse.com) may also submit data on our "Contact Us", "Join Our Team" or other data submission pages.

We also receive information from registrants to our self service web site (www.myeepulse.com) including registrant name, company name, title, address, phone number, email address and credit card information for subscription payments. The registrant may also supply email lists, employee names, titles and other demographics related to the target population they survey in the MyeePulse system. The use of the MyeePulse Web site, the survey process and data collected by the registrant through MyeePulse is subject to the Terms of Use policy for MyeePulse.

Maintenance of data, user identification and passwords:

If you have a user account on one of our Web sites, you may access your information to update your registrant information through the Web site. You may also request that we remove your registration information from our current database by contacting us in the USA at 734-996-2321 or info@eepulse.com.

Use and Disclosure of Respondent Data

We will only share your personally identifiable information ("Personally identifiable information" means data that individually identifies you, such as your name, email address, phone number, address, etc.) to any third party if one or more of the following occur:

• we have your consent
• we consider that we are required to do so by law
• we find that you are in breach of our terms and conditions or any of our policies or usage guidelines for specific products or services
• it is necessary in our opinion to do so to prevent, investigate, detect or prosecute criminal offences or attacks on the technical integrity of our site(s) or our network
• it is necessary in our opinion to do so to protect the rights, property, or safety of eePulse and its employees, the users of our site(s), or the public.

Anonymity vs. Confidentiality

In the typical eePulse, inc. survey process, the data we receive from respondents are confidential to eePulse and anonymous to the client. eePulse knows who submitted data and stores the responses with the respondent's name. This allows us to: 1) provide individual reports to the respondent so the respondent can compare himself or herself to department and company level results; 2) group data into various categories allowing reports to be generated immediately; 3) give managers the ability to respond directly to groups or individuals within an organization while maintaining individual respondent anonymity; 4) give coaches (either eePulse, Client or Third Party) the ability to respond directly to the individual for the purpose of clarifying information provided by the respondent or to provide information to the respondent while maintaining individual respondent anonymity. At all times, the respondent's name and other identifying information previously loaded into our database are kept confidential to eePulse and anonymous to the client and third party.

What happens to respondent comments that are included in surveys?

At times, respondents say things in the open-ended comments that can identify them to anyone reading a report. For example, if you say:

"I was on vacation last week and I can't believe they moved my desk to the third floor in front of the big window. I can't work because the sun is too bright."

Anyone reading this comment would know that the person on the third floor whose desk was just moved wrote the comment.

Under our standard contract terms, comments go directly into reports to managers and the staff at eePulse does not read, edit or make changes to respondent comments. If respondents do not want it to be known that they participated or made a comment, they must make sure to write comments so that they do not disclose information that will identify them to the reader of a group report (that puts multiple comments together in one large report).

Measures to protect Respondent Confidentiality and Anonymity

eePulse, Inc. has implemented internal controls and procedures that are designed to preserve the confidentiality and anonymity of the respondents. These include: 1) Each client must agree that eePulse, Inc. will not reveal information to the client or any third party that identifies the respondent. 2) Data that has been previously loaded into our database that may identify or be identifiable to a respondent, such as name, title, etc., are not included with any reports to the client or in any other data provided to clients. 3) Any information provided by the respondent during the technical support process is used only for the intention of providing technical support. 4) All eePulse employees sign non-disclosure agreements obligating them to maintain the confidentiality of the data. 5) Multi-tier security technology is utilized to prevent and detect unauthorized access to the eePulse Measurecom website, including using a secured (SSL) line for data transmission. Unfortunately, no method of transmission over the Internet, or method of electronic storage, is completely secure. Therefore, while we take safeguards to protect the personal information that you transmit to us, we cannot guarantee its absolute security.

How we use Cookies

A cookie is a small piece of data that is sent to your browser from a web server and stored on your computer's hard drive. A cookie can't read data off your hard disk or read cookie files created by other sites. Cookies do not damage your system. We use cookies to store your client id., user name, and if you choose, your password, so that you don't have to re-enter them each time you visit our website. eePulse, Inc. does not store any other personally identifiable information in cookies.

You can choose whether to accept cookies by changing the setting of your browser. You can set your browser to refuse all cookies, or allow your browser to show you when a cookie is being sent. If you choose not to accept these cookies, your experience at our site and other websites may be diminished and some features may not work as intended.

We collect and analyze web site traffic

We use log file analysis tools and outside services to collect and analyze our web traffic. None of these tools personally identifies our visitors to the www.eepulse.com web site. They are used to help us understand our marketing effectiveness, enhance our web interface, and improve your overall online experience with eePulse.

Links to other Web Sites

Our web sites contain links to other, third party web sites. Please be aware that eePulse is not responsible for the privacy practices of such other sites. We encourage you to read the privacy statements of the destination sites.

Right to Change Policy

We reserve the right to change this Privacy Statement. If we make any changes to this policy we will change the date at the top of this statement to reflect the effective date of the change. You are encouraged to check the date of this Privacy Statement to insure your awareness of any updates.

Contact for Privacy Inquiries

If you have any questions about this Privacy Statement please contact: info@eepulse.com