Walker Privacy Statement

Effective: 19-MAR-2007

At Walker Information, we believe that survey respondents and online visitors are key stakeholders in our company. For this reason Walker prides itself not only on its customer focus, but also on its efforts to protect and be sound advocates for our respondents and online visitors. Walker Information conducts market research surveys using scientific methods. We promise that in obtaining your cooperation we will not mislead you about the nature of the research or the use that will be made of the findings. At a minimum, we will adhere to all legal and ethical standards of conduct for market research firms. We are a member of ESOMAR, the international professional body for market research (www.esomar.org), as well as a member of The Direct Marketing Association (www.the-dma.org), the largest trade association for businesses interested in direct, database, and interactive global marketing and we abide by their standards of conduct. We promise that when collecting personal information in response to marketing or product requests, we will use your information solely for this purpose.

The remainder of this statement will provide insight on what information we may collect about you, how either Walker Information or our clients may use your opinions and personal information as it relates to our services and your rights, and our commitment to your rights.

Our Mission
Walker's mission is to provide our clients with information-based measurement solutions to help improve their performance by enhancing business loyalty and critical relationships with their customers, employees, and other key stakeholders. As a part of our process, we use scientific methods that reveal to clients where they have leverageable strengths and critical weaknesses in their relationships with their stakeholder groups. In assessing these strengths and weaknesses, we encourage our clients to act on the feedback provided by their stakeholders by creating process improvement initiatives. The outcome from these efforts is improved quality of products or services and/or increased value delivered to customers of our clients.

Information We May Collect About You
Walker collects personal data either for surveys or for marketing-related activities.

Surveys
For surveys, Walker Information processes, on behalf of our clients, personal data that has been collected by or on behalf of those clients. "Personal Data" means information relating to an identified or identifiable person. Under the United States/European Union Data Protection Safe Harbor Arrangement, Walker Information acts as a Data Processor and each Walker Information Client acts as a Data Controller. For the purposes of the Safe Harbor and this Privacy Statement: a "Data Processor" is an entity that processes Personal Data on behalf of a Data Controller; a "Data Controller" is an entity that determines the purposes for which Personal Data are processed. To "process" Personal Data means to carry out an operation or set of operations on such Personal Data, such as collecting, recording, storing, disclosing, or organizing it. The "Data Subject" means the person to whom a certain set of Personal Data relate; for example, the person who responds to a survey.

As a Data Processor, Walker Information will only process Personal Data pursuant to the instructions of the applicable Client. At times, the Client may ask that a Data Subject confirm their Personal Data for verification. Walker Information may use the services of third party Data Processors to process Personal Data in accordance with purposes identified for such Personal Data by the applicable Client. Walker information will not use or share, either within Walker Information or with a third party, any information collected for our or our service providers own direct marketing purposes. Walker Information will not be responsible for determining the authenticity of any purported Data Subject's request to access his or her Personal Data. In the absence of express instructions to do so from the applicable Client, Walker Information will not provide a purported Data Subject with access to his or her Personal Data unless it is demonstrated to Walker Information's satisfaction that the applicable Data Controller has refused such access.

Marketing Requests
For marketing-related activities, Walker will abide by Direct Marketing Association (DMA) standards of conduct.

Walker collects personal information when you register for subscriptions to online newsletters and seminars, information downloads and requests for product information, or when you ask to be included in an e-mail or other mailing list. During registration, we require your name, title, company and email address. You also have the option of providing other information such as a salutation and business contact information. We maintain personal information to control access to specific registration sites. We do log your IP address (the Internet address of your computer) to tell us which part of our website you visit and how long you spend there.

Walker Information uses such information, if it has been collected, in accordance with acceptable privacy practices consistent with this policy and applicable laws. Access to certain Walker web pages requires a login and a password. Walker may share your information with one or more of our Global Network Partners so they may provide you with additional information relevant to your request. We will not transfer your personal information to other third parties without your consent.

Walker uses information for several general purposes: to fulfill your requests for certain products and services, to personalize your experience on our website, to keep you up to date on the latest product announcements or other information we think you'd like to hear about, and to better understand your needs and provide you with better services. We may also use your information to send you, or to have our Global Network Partners send you, direct marketing information.

Walker Information subscribes to an "opt-in" policy. This means we will require your affirmative action to indicate your consent before we use your information for purposes other than the purpose for which it was submitted. We will always give you the opportunity to "opt out" of receiving direct marketing information.

For both online surveys and marketing requests, we automatically capture information about your browser type in order to deliver richer context, tailored for a better experience, and suited to your software and preferred language setting. We do no other invisible processing of data from your computer. Additionally, we may use cookies tied to personal information ("cookies" are small text files stored on your PC's hard disk and used for keeping track of settings or data for a particular web site) and other similar devices sparingly and only for quality control and security validation purposes.

Security
If you prefer not to receive cookies while browsing our website, you can set your browser to warn you before accepting cookies and refuse the cookie when your browser alerts you to its presence. You can also refuse all cookies by turning them off in your browser, although you may not be able to take full advantage of Walker's website if you do so.

Our web site has security measures in place to protect the loss, misuse, and alteration of the information under our control. Only certain Walker Information employees have access to the information you provide us. They have access only for data analysis, quality control purposes, and opt-in marketing.

How Your Information May Be Used: Surveys
Respondents are adequately informed about the nature of the survey (who is conducting it, how the information will be used, etc.) and understand that their cooperation is entirely voluntary and agree to participate on this basis. Depending upon the nature of the program, it may be necessary for clients look at information from individual respondents in an effort to better understand specific issues or to develop process improvement initiatives. Over the past years, we have conducted very few surveys that have incorporated the use of a "confidentiality" question. In these instances, when a survey respondent specifically requests to have their answers remain confidential by indicating in their respective survey, reasonable measures will be taken to ensure their answers are viewed in aggregate form only and all captured comments will have no association to their contact information displayed. If a Client wishes to do their own additional study and analysis they are required to independently comply with existing state, federal and international statutes governing data privacy regarding the disclosure, receipt and use of personally identifiable information.

Those no longer wishing to receive invitations to take surveys from Walker Information may reply to the invitation message with "drop" in the subject.

Individuals who need to change personal data submitted to Walker Information may send an e-mail to privacy@walkerinfo.com. If after having submitted personally identifiable information to a survey, a user requests not to have their information associated with their survey responses, their survey record will be marked as 'confidential'.

Your information may be stored and processed in the United States or any other country in which Walker Information or its affiliates, subsidiaries, or agents maintain facilities. By participating in a survey, you consent to any such transfer of information outside of your country. Walker Information abides by 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. Under certain circumstances required by law or court order, Walker Information will collect, use, and/or disclose personal data pursuant to procedures that do not require giving notice or conducting related activities.

How Your Information May Be Used: Marketing Requests
Walker Information uses personal information to respond to your request for marketing materials. We are committed to using this information responsibly. To opt out of receiving Walker Information's online newsletter Creating Loyalty, or another recurring email communication, reply to the corresponding received e-mail message with the word "remove" or "unsubscribe" in the subject.

Walker's Commitment to Respondents and Your Rights
Walker Information is a licensee of the TRUSTe Privacy Program. TRUSTe is an independent, non-profit organization whose mission is to build user’s trust and confidence in the Internet by promoting the use of fair information practices. This privacy statement covers the sites www.walkerinfo.com, http://smartloyalty.walkerinfo.com, http://survey.walkerinfo.com. Because this Web site wants to demonstrate its commitment to your privacy, it has agreed to disclose its information practices and have its privacy practices reviewed for compliance by TRUSTe.

If you have questions or concerns regarding this statement, you should first contact us with the information in the section, “How You Can Reach Us”, below. If you do not receive acknowledgement of your inquiry or your inquiry has not been satisfactorily address, you should contact TRUSTe at http://www.truste.org/consumers/watchdog_complaint.php. TRUSTe will then serve as a liaison with us to resolve your concerns.

As with all forms of marketing and opinion research, your cooperation is voluntary at all times. We participate in the EU Safe Harbor Privacy Framework as set forth by the United States Department of Commerce. As part of our participation in the safe harbor, we have agreed to TRUSTe dispute resolution for disputes relating to our compliance with the Safe Harbor Privacy Framework. If you have any complaints regarding our compliance with the Safe Harbor you should first contact us. If contacting us does not resolve your complaint, you may raise your complaint with TRUSTe by Internet at http://www.truste.org/consumers/watchdog_complaint.php, fax at 415-520-3420, or mail at Watchdog Complaints, TRUSTe, 685 Market Street, Suite 270, San Francisco, CA, USA 94105. If you are faxing or mailing TRUSTe to lodge a complaint, you must include the following information: the name of company, the alleged privacy violation, your contact information, and whether you would like the particulars of your complaint shared with the company. For information about TRUSTe or the operation of TRUSTe's dispute resolution process, see http://www.truste.org/consumers/watchdog_complaint.php or request this information from TRUSTe at any of the addresses listed above. The TRUSTe dispute resolution process shall be conducted in English..

As a member of The Direct Marketing Association, we have agreed to comply with their privacy guidelines. If you have any complaints regarding our compliance The DMA's privacy guidelines, you should first contact us. If contacting us does not resolve your complaint, you may raise your complaint with The DMA by Internet at http://www.the-dma.org, fax at 202-995-0085, email at ethics@the-dma.org, or mail at Direct Marketing Association, 1111-19th Street, NW, Suite 1100, Washington, D.C. 20036-3603.

While Walker Information counsels clients on the appropriate use of survey research data, Walker Information does not review, comment upon or monitor its Clients' compliance with their respective privacy policies, nor does Walker Information review Client instructions to determine whether they are in compliance or conflict with the terms of a Client's published privacy policy. Walker Information will, and reserves the right to, modify and update this policy or its related business practices at any time. Walker Information will not apply changes to this policy that retroactively affects personally identifiable information without your express consent. For material changes affecting personally identifiable information that is not owned by the data controller, we will post a prominent notice on the site for 30 days prior to changes taking effect.

Our Policy for Children under 13
We do not knowingly collect personally identifiable information from users under the age of 13. If for some reason we find that a US user is under the age of 13 we will delete that personal information accordingly.

How You Can Reach Us
You can contact us at support@walkerinfo.com to discuss any problems related to our privacy policy. If you are concerned about our use of your personal data, or would like to file a complaint, please contact us at privacy@walkerinfo.com. You can expect a response to your requests within 30 days.

We can also be reached via mail at the following address:
Walker Information
Attn: Data Privacy Officer
301 Pennsylvania Parkway
Indianapolis, IN 46280