Harris Interactive is a licensee of the TRUSTe Privacy Program. Harris Interactive and its subsidiaries, abide by the principles set forth in the Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of data from the European Union. Information about the U.S. Department of Commerce Safe Harbor certification can be found at www.export.gov/safeharbor.

Harris Interactive strives to conform to the Council of American Survey Research Organizations (CASRO) Code of Standards and Ethics for Survey Research, the European Society of Opinion and Marketing Research (ESOMAR) Codes and Guidelines for Survey Research, the European Commission Directive on Data Protection, SNYTEC in France, the French law on "Informatique et Libertés", CNIL, the American Association for Public Opinion Research (AAPOR) Code of Professional Ethics and Practices, the Federal Trade Commission (FTC) Fair Information Practice Principles, the FTC’s Children’s Online Privacy Protection Act (COPPA) Final Rule, the Children’s Advertising Review Unit (CARU) Guidelines for Advertising on the Internet and Online Services, the Health Insurance Portability and Accountability Act (HIPAA), the Graham-Leach Bliley Act (GLB), the CAN-SPAM Act, and other privacy regulations and guidelines in the U.S. and abroad.

Harris Interactive routinely reviews its security features and privacy practices, and enhances them to better protect your privacy.

1. Company Background and Websites
2. Information Collected on Harris Interactive Websites
3. How Information Is Used
4. Accessing the Information You Provided
5. Your Options on Harris Interactive Websites and Opt-out Policies
6. Safety and Security
7. Notification of Changes
8. How to Contact Us

1) Company Background and Websites

Harris Interactive is a worldwide market research and consulting firm most widely known for The Harris Poll and for its pioneering leadership in the online market research industry. This privacy statement covers the following of our sites: www.harrisinteractive.com, www.novatris.com, www.hisbonline.com, and www.harrispollonline.com. Harris Interactive is not responsible for the privacy practices or the content of other websites. We recommend that you carefully read the privacy policies of each site you visit.

Harrisinteractive.com is Harris Interactive’s corporate website including our European operations. Novatris.com is managed by our French subsidiary. Hisbonline.com is the website for HISB (Harris Interactive Service Bureau) a division of Harris Interactive that provides research services to other market research companies.

Harrispollonline.com is our panel members’ website which registers and conducts surveys with individuals aged 13 and over. Children under age 13 are only contacted to participate in surveys through their parents; they are not offered the opportunity to register for our online panels directly. For research with teenagers between the ages of 13 and 18 and children under 13, we are careful to respect their privacy and parental concerns.

Our survey websites provide survey respondents with the opportunity to express opinions and attitudes about the most current issues. We conduct research that involves people from around the world, and provide the aggregated results of our research (stripped of any personally identifiable information) to a wide variety of clients, including important decision-makers in government, major corporations, and news organizations. In addition, certain survey findings are published on our websites so that our respondents can be among the first to hear about the concerns and interests of people around the world. Our survey research is what allows us to offer the services and features on our sites free of charge.

2) Information Collected on Harris Interactive Websites

Information Collected During the Registration Process

Individuals can join our growing databases of survey respondents by registering at our harrispollonline.com website. When registering on the websites of third parties with whom we have developed business relationships, registration through these various means work as follows:

During the registration process on harrispollonline.com (a site directed towards, intended for, and appealing to individuals age 13 and over) we require individuals to provide us with contact information (e.g., email address) and demographic information (e.g., gender, birth year, zip code, and country). To allow individuals to modify their submissions at a later point in time, we also ask registrants to establish a unique password. Individuals under the age of 13 are prevented from registering based upon their birth year entry on the registration form. Individuals who are age 13 are required to enter their month and day of birth to verify they are at least 13 years of age.

Harris Interactive, and its subsidiaries, may provide registration opportunities for our survey databases via surveys we conduct with individuals age 13 or over.

Potential survey site members age 13 or over may also have been recruited on our behalf by third party websites, who forwarded to us your information, with your consent. Any additional information we collect from you, for example, to complete registration (if it was not already completed by the third party) or during a survey is subject to this privacy policy.

Individuals have the opportunity, in certain cases, to register in their native language by selecting from a set of available languages on the main registration page.

Once you become a panel member you agree to receive other Harris Poll Online communications regarding survey invitations and reminders, sweepstakes notification in the event you are a winner, updates to our privacy policy, regional-specific communications in the event of a natural or other disaster, responses to inquiries that you submit to our Survey Help Desk, and inquiries should we receive communication from your ISP regarding your status as an Harris Poll Online member.

Other Information Collected on Harris Interactive Websites

As part of the survey process, we will ask Harris Poll Online panel members other demographic information (e.g., income level), and other information related to interests, hobbies, and product/technology usage. We collect this information so that we can send surveys to members that correspond with their interests. We aggregate the responses received by various broad categories to report the aggregated results to our clients. We also summarize information about the Harris Poll Online panel to develop statistics ensuring that the panel is representative of the general population. We may also use information provided by Harris Poll Online panel members to pre-qualify them for future market research that target certain demographics (male vs. female, age, etc.).

Harris Interactive offers an incentive program, HIpoints, through which participants of certain surveys can accumulate points towards award redemption based on the number of eligible surveys in which they participate. This program is offered in limited countries. To redeem HIpoints, panelists must provide full name and shipping information so that we can deliver the selected items.

Visitors to certain areas of our websites are provided online forms to contact us if they have questions, comments, are interested in job opportunities, or require further information on our products or services. Responses to such inquiries may be sent via email or regular mail within 30 days upon receipt.

Children’s Privacy

Harris Interactive believes that it's especially important to protect children's privacy online and encourages parents and guardians to spend time online with their children to participate and monitor their Internet activity.

Harris Interactive complies with all applicable national and international children's privacy regulations. We comply with the Children’s Online Privacy Protection Act of 1998 (“COPPA”). We do not collect any personal information from children under 13 years of age. As part of the validation process for our clients, we may collect the names of individuals who participated in a market research study, but we do not ask the names of children who are under 13 years of age. From time to time, we may also ask our adult panel members or respondents whether they have children under 13 residing with them who might want to participate in a survey. In such event, we will never collect personally identifiable information from the child, nor will we combine other information that we collect from the child with personally identifiable information about the child or parent.

If you would like to contact us about your information, any information about your child, or to find out how you can have your child's information removed from our database, please see the “Accessing the Information Your Provided” section of this policy.

3) How Information Is Used

Surveys

If you have joined the Harris Poll Online panel, we will use the information you provide us primarily to contact you about surveys in which we would like you to participate, or to provide you with the results of the surveys. We may also notify you about new features on our websites, or other products or services related to the primary purpose of our business in which we think you may be interested. From time to time we may also invite our members to enter a sweepstakes or participate in other incentive programs, most of which are related to the running of our surveys. Any additional information you provide when participating in an online sweepstakes or other online incentive program we host is subject to this privacy policy.

Harris Interactive does not send unsolicited commercial emails. When we send emails on behalf of a client, we abide by CASRO and ESOMAR standards.

Although not covered by the Controlling the Assault of Non-Solicited Pornography and Marketing Act (“CAN-SPAM Act”), Harris Interactive voluntarily complies with the key privacy and disclosure provisions of the CAN-SPAM Act, including:

• providing truthful sender information;
• including a physical address for Harris interactive or the Harris Interactive affiliate sending the email message; and,
• providing a clear and simple opt-out method which is always honored.

All survey invitations sent via email are consistent with the CASRO Code of Standards and Ethics for Survey Research.

As part of our survey research process, we gather, aggregate, and analyze information from our panelists and survey respondents. We provide the results of our research (which contain no personally identifiable information) to our clients, which include governmental agencies, major corporations, and other organizations. Your survey responses are valuable in guiding the development and designing of products and services. Survey responses are often used by our clients to make decisions on key issues.

Sharing Information

Harris Interactive is not in the business of selling your personally identifiable information. We use the information you provide to us for internal purposes, and share it only for the limited purposes described here:

In order to provide you with the services on our sites, we may need to share your information with third parties, our agents, who perform services on our behalf, such as merchandise (HIpoints rewards) fulfillment, web hosting, and the like. They may also collect information on our behalf. Any personal information collected by a third party website is in accordance to this privacy policy. For example, the HIpoints program is managed by our agent, Incentive Logic. A limited amount of your registration information is provided to Incentive Logic for purposes of running the HIpoints program. This information is kept in confidence and not used for any other purpose than to establish and track your earned HIpoints. Incentive Logic operates the HIpoints program in accordance with our privacy guidelines and does not share your personal information with any third party without your permission.

As a company conducting market research, protecting survey participants’ privacy has been an important part of our business long before the advent of the Internet. We know that you will not want to complete a survey if your personally identifiable information is shared with third parties, which is why we participated in industry-wide efforts to protect consumer information, even before we began conducting surveys online. We follow local laws and industry best practices with respect to the release of personally identifiable information. Clients that receive personally identifiable information are required to sign and abide by CASRO’s "Standards Regarding Disclosure of Respondent-Identifiable Data to Clients," indicating that their use of the data will be limited to research purposes and the information will remain confidential.

Harris Interactive is a thriving and expanding business, and like other companies, we sometimes acquire or spin off new business units. As part of such transfers, we convey the business assets of the particular business unit, including survey participant data. If a change of ownership occurs, a notice will be posted on harrisinteractive.com or an email will be sent to you directly.

Harris Interactive will periodically be engaged by our clients to build Proprietary Panels (database of survey participants). With respect to Proprietary Panels, data from the resulting database of respondents may also be made available for use by the client who commissioned the research. Such information will only be made available to the client pursuant to an agreement with Harris Interactive that the information will be kept confidential and will be used exclusively for research purposes. Harris Interactive’s use of personal information you provide as part of such panels is subject to the same provisions as indicated herein for Harris Poll Online registrants.

Harris Interactive websites may contain links to information on other websites. We do not have any control over these other websites, and therefore we cannot be responsible for the protection and privacy of any information that you provide while visiting those sites. Those sites are not governed by this privacy policy, and if you have questions about how a site uses your information, consult that site's privacy statement.

Legal Disclaimer

Though we make every effort to preserve user privacy, we may need to disclose personal information when required by law wherein we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process served on our website.

Passively Collected and Stored Information - Cookies and Log Files

We passively collect information to make your browsing experience more pleasant, and to understand what areas of our sites are more popular, what areas may require improvement, and what technologies are being used by members of our sites. This information helps us to update and improve our sites. We also use this information for security purposes, to detect and to block security breaches, to detect violations of our quality standards, for example, detecting multiple memberships from the same user which is not permitted by the Harris Poll Online Terms Of Use, and to provide you with a safe online environment.

Cookies are small text files stored on your computer by a website that assigns a numerical user ID and stores certain information about your online browsing. When we use cookies, we do so to help us recognize you as a prior user of this site. The cookie file does not store your personal information. If you prefer not to receive cookies from our website you can disable their use in your browser settings. By doing so you may reduce the functionality of the web pages you view.

As is true of most websites, we gather certain information automatically and store it in log files. This information includes Internet Protocol addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and click stream data.

4) Accessing the Information You Provided

For panel members, not only is it important for our members to be able to correct their information, it is important to us. The results from our public surveys (which report aggregate, non-identifiable information) often get reported by the media. We encourage members to keep their account profiles up-to-date, so that we continue to have accurate demographic information behind our results.

Personal information previously provided when responding to a survey, through the Harris Poll Online site or through our French subsidiary, Novatris, may be changed or modified by the following options:

Visit the Harris Poll Online website, log in, and update your information.

Survey Help Desk
Harris Interactive Inc.
60 Corporate Woods
Rochester, NY 14623-1457 USA

Online Survey Help: surveyhelp.harrispollonline.com

Email: surveyhelp@hpol.harrisinteractive.com

Telephone: (800) 600-2493 or (585) 482-2210 Ext. 8003

For all other users of Harris Interactive sites who may have provided personal information when contacting us regarding any of our products or services and would like to change or modify their information should send an email directly to info@harrisinteractive.com.

Responses to such inquiries may be sent via email or regular mail within 30 days upon receipt. If the user does not receive acknowledgement of their inquiry, or if their inquiry is not satisfactorily addressed, they should then contact TRUSTe through the TRUSTe Watchdog Dispute Resolution Process (http://www.truste.org/consumers/watchdog_complaint.php). TRUSTe will serve as a liaison with the website to resolve users’ concerns.

5) Your Options on Harris Interactive Websites and Opt-out Policies

For panel members, we are committed to giving you the maximum amount of flexibility in accessing your information, and in the level of participation you have with our sites. In each email invitation sent to members of our respondent database, we provide the opportunity to opt-out of receipt of further mailings. This opt-out opportunity deactivates the member's account and terminates their membership with Harris Interactive. Our survey invitations inform you about the subject matter of the survey in which we would like your input, whether it is in the category of public opinion, current trends and activities, or products/services. Any personally identifiable information that you provide during the survey process will be subject to your consent prior to release to our client. Should you grant release of such information, and then change your mind, all you need do is to send an email to surveyhelp@hpol.harrisinteractive.com.

If at any point you decide that you no longer wish to be a member of Harris Interactive’s respondent databases, you may send an email request with the word "unsubscribe" to surveyhelp@hpol.harrisinteractive.com. Panel members can also opt out by filling out a request on the Member Services section of the website. We will retain your information in our "unsubscribe" database, to ensure that we do not contact you in the future for Harris Poll Online surveys. In the event we receive your email address from a client as part of a customer database whom we will be contacting for a survey for that client, we may contact you regarding that specific survey. You will be provided with a separate opt-out opportunity from that survey.

For panel member parents, if we invite your 13-to-17 year old children to participate in surveys covering sensitive topics, we may notify you first, depending on the nature of the survey involved. If notified, you will be asked if you will allow your child to participate. In such cases, we will not notify the child about the survey or ask him or her to participate without your permission. For the most sensitive of subjects, we typically ask the adult members of our harrispollonline.com website if they have any children in the appropriate age level that they would be willing to have participate in the survey in question. Again, children under age 13 are only contacted to participate in surveys through their parents.

For subscribers to any Harris Interactive newsletter, you may unsubscribe by sending an email to newsletters@harrisinteractive.net or simply click on the "One-Click Unsubscribe" in the footer of the email in which you received with this newsletter.

For all other users of Harris Interactive sites who may have provided personal information when contacting us regarding any of our products or services and would like to be removed from our contact list should send an email directly to info@harrisinteractive.com.

6) Safety and Security

The Harris Interactive websites have security measures in place to prevent the loss, misuse, and alteration of the information under our control. We will not activate a potential registrant’s account without confirmation. Once the registration process is completed, the individual is sent an email that requests he or she confirm his or her registration. The account will not be activated until confirmation is received. Additionally, all website members are required to use their passwords and usernames (email addresses) when registering, updating their contact information, or when accessing "members only" sections of the websites. If a member cannot remember his or her password, he or she can send a message to the website’s Help Desk to retrieve it. To protect the security of our members’ contact information, requests to retrieve passwords must include information to allow us to verify the member’s identity.

We employ standard technology and internal processes to protect the information our members release to us. Additionally, only select, authorized employees have access to process the data collected and maintain the database that stores member contact information.

While navigating Harris Interactive websites you may be directed to content or functionality that is hosted by a third party supplier, not on a Harris Interactive owned domain. For example, this is done on our Careers webpages. When information is collected on behalf of Harris Interactive exclusively, Harris Interactive privacy policy will be referenced on the site and will govern how your information is used. For other, non-Harris Interactive sites, the site owner's privacy policy will be referenced.

Harris Interactive also safeguards all information it collects through its websites from unauthorized access. Only authorized Harris Interactive employees or agents carrying out permitted business functions are allowed to access this information. In addition, each employee of Harris Interactive is required to sign a confidentiality agreement requiring him or her to keep confidential all personal information of panel members. Employees who violate the confidentiality agreement are subject to disciplinary actions, including termination when appropriate.

In the unlikely event that Harris Interactive suffers a breach of its security systems and an individual or entity gains unauthorized access to any information stored on Harris Interactive servers, Harris Interactive will immediately investigate such security breach, and will provide prompt notice to any individual whose information was affected.

7) Notification of Changes

We will use information in accordance with the privacy policy under which the information was collected. If we are going to use users' personally identifiable information in a manner different from that stated at the time of collection, we will notify users via email. If users have opted out of all communication with the site, or deleted/deactivated their account, then they will not be contacted, nor will their personal information be used in this new manner. In addition, if we make any material changes in our privacy practices that do not affect user information already stored in our database, we will post a prominent notice on our website notifying users of the change. In some cases where we post a notice we will also email users who have opted to receive communications from us, notifying them of the changes in our privacy practices.

It is the responsibility of the user of any Harris Interactive website to check for updates to this privacy policy which was most recently updated on September 1, 2006.

8) How to Contact Us

If you are a panel member and have questions or comments about this privacy statement, please contact us as follows:

Survey Help Desk
Harris Interactive Inc.
60 Corporate Woods
Rochester, NY 14623-1457 USA

Online Survey Help: surveyhelp.harrispollonline.com

Email: surveyhelp@hpol.harrisinteractive.com

Telephone: (800) 600-2493 or (585) 482-2210 Ext. 8003

For all other inquiries regarding this privacy statement please contact us by email at info@harrisinteractive.com.

Responses to such inquiries may be sent via email or regular mail within 30 days upon receipt. If the user does not receive acknowledgement of their inquiry, or if their inquiry is not satisfactorily addressed, they should then contact TRUSTe through the TRUSTe Watchdog Dispute Resolution Process (http://www.truste.org/consumers/watchdog_complaint.php). TRUSTe will serve as a liaison with the website to resolve users’ concerns.

Revised: September 1, 2006