Last updated: September 2006

Silverpop Systems Inc. (hereinafter the "Silverpop") respects individual privacy and values the confidence of their customers, employees, consumers, business partners and others. Silverpop strives to collect, use and disclose personal information in a manner consistent with the laws of the countries in which they do business, and pride themselves on upholding the highest ethical standards in their business practices. This Safe Harbor Privacy Policy (the "Policy") sets forth the privacy principles that Silverpop follows with respect to personal information transferred from the European Union (EU) to the United States.

Safe Harbor
The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions (the "Safe Harbor Principles") to enable U.S. Companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EU to the United States. Consistent with its commitment to protect personal privacy, Silverpop adheres to the Safe Harbor Principles.

Scope
This Safe Harbor Privacy Policy (the "Policy") applies to all personal information received by Silverpop in the United States from the European Economic Area, in any format including electronic, paper or verbal.

Definitions
For purposes of this Policy, the following definitions shall apply:

"Silverpop" means Silverpop Systems Inc. a Georgia based Company in the USA.

"Personal information" means any information or set of information that identifies or is used by or on behalf of Silverpop to identify an individual. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.

"Sensitive" means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns an individual's health. In addition, Silverpop will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.

Notice: Silverpop enters into email marketing agreements with its clients in the EU which may include the processing of information relating to their clients' customers. In these agreements, the EU client agrees and recognizes that it is the 'data controller' for the purposes of data protection legislation. This means that our EU clients are responsible for complying with the data protection legislation in the relevant Member State national law before it sends its customer data to Silverpop for processing. Any data processed by Silverpop is only disclosed to third parties at the request and direction of its European client as the data controller, or when required by law. Any information that our EU clients identify as sensitive will be treated as such.

Silverpop has a Compliance Manager who is responsible for the internal supervision of Silverpop privacy policies. Silverpop also has a team of technicians to handle data security. Silverpop continuously educates its employees about compliance with the Safe Harbor Principles and has self-assessment procedures in place to ensure its compliance. The Direct Marketing Association serves as Silverpop's third-party dispute resolution provider. Silverpop participates in the EU Safe Harbor Privacy Framework as set forth by the United States Department of Commerce.

Security: Silverpop will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

Enforcement: Silverpop will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that Silverpop determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.

Dispute Resolution: Silverpop participates in the Direct Marketing Association (DMA) Safe Harbor dispute resolution process. If you feel that this company is not abiding by its posted privacy policy or is not in compliance with the Safe Harbor principals, you should first contact Silverpop's Compliance Manager by email at privacy@silverpop.com. If you do not receive acknowledgment of your inquiry or your inquiry has not been satisfactorily addressed, you should then contact the Direct Marketing Association (DMA) Safe Harbor Dispute Resolution Program. The Direct Marketing Association (DMA) will act as a liaison to Silverpop to resolve your concerns.

You can contact the Direct Marketing Association (DMA) Safe Harbor Dispute Resolution Program at:

Safe Harbor Line
Direct Marketing Association
1615 L Street, NW, Suite 1100
Washington, DC 20036
Safeharbor@the-dma.org

Contact Information
Questions or comments regarding this Policy should be submitted to the following person by mail as follows:

Silverpop Systems Inc.
Privacy Department
200 Galleria Parkway, Suite 750
Atlanta, Georgia 30339
Telephone: 678-247-5000
E-mail Address: privacy@silverpop.com

Changes To This Safe Harbor Privacy Policy
This Policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. A notice will be posted on Silverpop's web page: www.silverpop.com.

Effective Date: September 1st, 2006