Effective Date: June 29, 2005

To read our privacy policy for the European Union, click here.

Initiate Systems, Inc. ("Initiate Systems") is committed to protecting your privacy. This Privacy Policy describes how Initiate Systems protects the privacy and security of the general and personally identifiable information that we obtain: (1) from our business clients, in the course of providing customer data integration ("CDI") services ("Customer Data"); and (2) from users of this web site (the "Site"), from whom we may request information in order to respond to inquiries submitted through the "Contact Us" and "Resource Download" pages of the Site ("Web Site Data").

Initiate Systems has self-certified its privacy practices as consistent with the U.S.-European Union Safe Harbor principles.

Security

We understand that storing our data in a secure manner is essential. Initiate Systems stores general and personally identifiable data using industry standard physical, technical and administrative safeguards to secure data against foreseeable risks, such as unauthorized use, access, disclosure, destruction and modification.

Use and Disclosure of Data

Customer Data will be used solely to provide CDI services to the businesses that are Initiate Systems' clients ("CDI Clients"). Initiate Systems' CDI services enable CDI Clients to have more complete, accurate information regarding their individual customers so that they can more efficiently provide their goods and services. Except as described in this Privacy Policy, Initiate Systems will only use Customer Data for the purpose of providing services to the CDI Clients that provided that Customer Data and will not disclose the data to any third parties.

Web Site Data will be used solely for the purpose of responding to the inquiries that you submit to us via the "Contact Us" and "Resource Download" pages of the Site. Except as described in this Privacy Policy, Web Site Data will not be disclosed to any third parties.

Disclosures to Third Parties Assisting In Our Operations

Some personally identifiable information that we maintain may be shared on occasion with outside lawyers, auditors, consultants and others we hire to assist in supporting the Site or the CDI services or performing other functions necessary to operate our business. If we make a disclosure of this type, the recipient must agree to: (i) safeguard the personally identifiable information, (ii) use it only for the purpose that we have specified, and (iii) return it or destroy it as soon as the need for the information expires. For example, Initiate Systems may share information with temporary staffing personnel for the purpose of providing data quality remediation services.

Disclosures Under Special Circumstances

Initiate Systems may be required to disclose personally identifiable information in response to a search warrant, subpoena or court order. This is a possibility that could confront any record keeper. Disclosures may also be necessary to protect our legal rights, to protect the security or integrity of our Site or systems, to take precautions against liability, or during emergencies if physical safety is believed to be at risk.

Aggregate Information

Initiate Systems may provide information about you that does not allow you to be identified or contacted ("Aggregate Information") to third parties. For example, we might inform third parties regarding the number of various types of requests for information regarding our services that we receive through the Site.

Changes In Ownership

Initiate Systems could merge with or be acquired by another business entity or some or all of its assets could be acquired. If such a combination or acquisition occurs, Initiate Systems will make every reasonable effort to notify you in the event we share with the merging or acquiring entity some or all of your personal information to continue serving you.

Cookies

Initiate Systems may place a "cookie" on the browser of your computer. A cookie is a small file of information that a web site transfers to your computer for record-keeping purposes. The cookie itself does not contain any personally identifiable information, but may be used to tell when your computer has contacted the Site, thus enhancing your experience as a user of the Site. For instance, the Site's use of cookies allows you to avoid registering each time you visit the Site to download resources; you must only register once.

Ownership and Control of Customer Data

Customer Data is owned by Initiate Systems' CDI Clients; Initiate Systems merely assists its CDI Clients in more effectively using that customer data. If you are a customer of one of Initiate Systems' CDI Clients and wish to learn more about that company's privacy practices, you should contact the CDI Client directly.

Children

Initiate Systems is committed to protecting the privacy of children. This Site is not intended for minors. No information should be submitted to our Site by users under the age of 13, and we do not collect information from any user we have reason to believe is a child under the age of 13.

HIPAA Compliance

The Health Insurance Portability and Accountability Act of 1996 ("HIPAA") establishes new standards for healthcare privacy and security. Although Initiate Systems is not directly subject to HIPAA's requirements, we receive protected health information ("PHI") from, and on behalf of, our customers that is subject to the protections of HIPAA. Initiate Systems is committed to protecting the privacy and security of our customers' PHI in a manner that is consistent with their legal obligations under HIPAA. Initiate Systems has developed a privacy and security compliance program for its personnel that takes into account HIPAA standards and reasonable practices in the healthcare industry.

Notification of Changes

This Privacy Policy may be revised from time to time as we add new features and services, as laws change, and as privacy and security practices evolve. We display a version number and a date in the upper right corner of this Privacy Policy so that it will be easier for you to know when there has been a change. If we make any change to this Privacy Policy regarding use or disclosure of personally identifiable information, we will provide advance notice on the Site. Small changes and changes that do not significantly affect individual privacy interests may be made at any time.

Your Privacy Choices

When you submit an inquiry via the "Contact Us" pages of the Site, you may receive materials regarding Initiate Systems' products and services by mail or e-mail. You may opt out of receiving these materials by visiting this web page Contact Us or contacting us by e-mail at info@initiatesystems.com.

Updating Your Personal Information

With respect to Web Site Data, you can always contact us in order to: (i) delete your personal information from our systems, (ii) update the personal information that you have provided to us, and (iii) change your preferences with respect to receiving information regarding Initiate Systems' products and services.

Questions

If you have questions or issues regarding this Privacy Policy, the practices of Initiate Systems, or your dealings with Initiate Systems, please contact us at:

Initiate Systems Systems, Inc.
200 West Madison, Suite 2300
Chicago, Illinois 60606
Phone: 1 312 759 5030
E-mail: info@initiatesystems.com