The following describes the Equus Software, LLC ("Equus" or the "Company") privacy policy and the manner in which Equus handles information that it receives that may constitute either personal or sensitive information concerning individuals. Equus’ intent is to comply with all applicable legal and regulatory requirements of those jurisdictions in which it does business, including the European Union Directive on Data Protection and the Switzerland Federal Act on Data Protection.  Equus complies with the U.S. - E.U Safe Harbor Framework and the U.S. - Swiss Safe Harbor Framework as set forth by the U.S. State Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland.  Equus has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.  To learn more about the Safe Harbor program, and to view Equus' certification, please visit http://www.export.gov/safeharbor.

Collection of Commercial Information
Equus collects certain information involuntarily from visitors to its website, and those of its subsidiaries, including the IP address, time visited, pages viewed and related information. The Company also collects certain information voluntarily when someone sends a direct mail inquiry, an email or online registration, participates in seminars or webinars, or requests Company information at tradeshows. Examples of such information include individual names, telephone numbers, email addresses, Company name, person’s title, and other personally identifiable information. Equus uses such information to monitor the performance, and improve the quality of, its website, respond to requests about the Company and its business, provide information about products and services, fulfill customer requests, marketing and other business purposes and to comply with various legal and/or regulatory requirements. The Company may share this information with business partners to respond to customer needs, or to engage in joint marketing behalf; e.g., providing notice of an upcoming webinar or tradeshow that may be of interest to the target audience, or during solicitation for business purposes.

Collection of Personal and Sensitive Information
Equus collects personal information only directly from the individuals affected. Personal information is information that identifies a particular individual, and does not include aggregated, compiled or publicly available data. Personal information that is related to commercial purposes is used as described in the preceding section. Sensitive information is personal information that reveals a particular person’s: (i) race; (ii) religion; (iii) ethnicity;(iv) sexual orientation; (v) political or philosophical beliefs; (vi) trade union membership; (vii) or information regarding a person’s medical status or condition. Sensitive information is collected solely for employment-related and other internal business matters, as well as to comply with legal and regulatory obligations. Use and treatment of Personal and Sensitive Information gathered by others From time to time Equus may have access to Personal and Sensitive Information gathered by others, including our clients. Equus will use reasonable methods to secure all personal and sensitive information by a variety of methods, including restricting access to such information only to those people who have a legitimate need to know in order to discharge their job responsibilities on behalf of Equus, securing access to the facility where the information is stored, and the use of technology and physical controls to secure the information.

Other Uses of Personal and Sensitive Information
In addition to the uses described above, Equus will inform individuals of any other intended uses of their personal or sensitive information at the time such information is collected, or before such use is implemented, including disclosure to third parties that are not agents of Equus. The individual will have the ability to advise the Company if he/she does not consent to such intended or additional use (i.e., "opt-in"). For other personal or commercial information, the individual has the ability to advise the Company at any time that he/she no longer wishes to allow such intended or additional use (i.e., "opt-out"), again, including disclosure to third parties that are not agents of Equus.

Data Security
Equus will use reasonable methods to secure all personal and sensitive information by a variety of methods, including restricting access to such information only to those people who have a legitimate need to know in order to discharge their job responsibilities on behalf of Equus, securing access to the facility where the information is stored, and the use of technology and physical controls to secure the information.

Use of Information by Third Parties That are Agents of Equus Equus will require that all third parties that are acting on behalf of Equus, and to which personal or sensitive information is provided, give Equus adequate assurances that they will safeguard all such information in a manner consistent with both this policy and the Safe Harbor Principles.

Ability to Access and Correct Information
Upon an individual’s request, Equus will provide reasonable access to any personal or sensitive information it has about that person. Equus will also take reasonable steps to allow such individuals to correct, change, modify or delete any such information that is shown to be incorrect, inaccurate or incomplete.

Resolving Disputes
Equus will investigate any complaints about the use and disclosure of personal or sensitive information that are not in accordance with this policy. If Equus is unable to informally resolve any such matter to the individual’s reasonable satisfaction, it will participate in the dispute resolution procedures of the legal or regulatory body having jurisdiction over the matter (e.g., the Federal Trade Commission), including, as appropriate, the Swiss Federal Data Protection and Information Commissioner or a panel established by the European Data Protection Authorities, so that disputes are resolved according to the Safe Harbor Principles.

Enforcement and Compliance
Equus will conduct regular audits to monitor compliance with this policy and will provide annual certifications to the U.S. Department of Commerce that it has done so. Violations of this policy will subject the violator to disciplinary action, up to and including termination.

Changes
Equus may amend or modify this policy from time to time by posting the amended or modified version on its website at http://www.equusoft.com. Amendments and modifications will be made in a manner so as to remain consistent with the Safe Harbor Principles. This policy may also be changed, or limited, to comply with legal or regulatory requirements, or as otherwise allowed or required by law.

Contact Information
Questions or comments about this policy, or concerns or complaints about possible violations, should be sent to: Equus Software, 1331 17th Street, Denver, CO 80202, 303 292 4200 or inquiries@equusoft.com