GROUP Business Software Corporation Personal Information and Safe Harbor Policy

Introduction

GROUP Business Software Corporation and its affiliated United States subsidiaries (hereinafter collectively referred to as “GBS,” “we,” “us” or “our”) adhere to the Safe Harbor Agreement concerning the transfer of personal data from the European Union (“EU”) to the United States of America. Accordingly, we follow the Safe Harbor Principles published by the U.S. Department of Commerce (the “Principles”) with respect to all such data. If there is any conflict between the policies in this privacy policy and the Principles, the Principles shall govern. This privacy policy outlines our general policy and practices for implementing the Principles, including the types of information we gather, how we use it and the notice and choice affected individuals have regarding our use of and their ability to correct that information. This privacy policy applies to all personal information received by the Company whether in electronic, paper or verbal format.

Definitions

“Personal Information” means information that (1) is transferred from the EU to the United States; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and (4) can be linked to that individual. “Sensitive Personal Information” means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual’s health.

The Safe Harbor Principles as Applied at GBS

Notice

If you are a customer, prospect, business partner, agent, or employee of GBS, we may collect and retain your Personal Information, or transfer your Personal Information between GBS affiliates and agents in the EU and the US. Such Personal Information will only be collected, saved and/or transferred for the purpose of contacting you and conducting business together for our mutual benefit. We will transfer such Personal Information only to GBS affiliates and/or agents who are directly involved in the conduct of that mutual business, and only to the extent necessary to conduct such mutual business. Sensitive Personal Information will not be transferred between the EU and the US except with the express written permission of the individual.

Choice

Safe Harbor provides that the Company shall offer individuals the opportunity to choose (opt out) whether their Personal Information is (1) to be disclosed to a third party or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. For Sensitive Personal Information, it provides that the Company will give individuals the opportunity to affirmatively or explicitly (opt in) consent to the disclosure of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. GBS supports and subscribes to these protections, but in any event GBS will not disclose or transfer your Personal Information to any other party for any purpose other than that for which it was collected, except as may be required by a legal authority upon due legal process.

Onward Transfers

GBS will ensure that any third party to which Personal Information may be disclosed 1) has need of the Personal Information for the purpose for which that information was collected, and 2) subscribes to the Principles, or is subject to law providing the same level of privacy protection as is required by the Principles and agrees in writing to provide an adequate level of privacy protection.

Data Security

GBS will take reasonable steps to protect the Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. GBS has put in place appropriate physical, electronic and managerial procedures to safeguard and secure the Personal Information from loss, misuse, unauthorized access or disclosure, alteration or destruction. Company cannot guarantee the security of Personal Information on or transmitted via the Internet.

Data Integrity

GBS will only process Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, GBS will take reasonable steps to ensure that Personal Information is accurate, complete, current and reliable for its intended use.

GBS Apps

Information about the use of mobile applications.

Access

GBS will allow an individual access to their Personal Information and allow the individual to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated.

Enforcement

GBS uses a self-assessment approach to assure compliance with this privacy policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Principles. We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Information in accordance with the Principles.

If a complaint or dispute cannot be resolved through our internal process, it may be submitted to the EU Data Protection Authorities. GBS will cooperate with them to resolve any such dispute.

Amendments

This privacy policy may be amended from time to time consistent with the requirements of the Safe Harbor. We will post any revised policy on this website.

Contact Information

If you have questions, comments or complaints regarding the Company’s Safe Harbor Policy or data collection and processing practices, you can also contact us.

GROUP Business Software Corporation
2295 Towne Lake Parkway
Suite 116-290
Woodstock, GA 30189

Phone: 404-891-1711
Fax: 404-720-1335