Your Privacy Is Important to Vigilant Futures

In the course of serving you as an individual or as someone associated with a corporate or institutional client, Vigilant Futures may obtain personal information about you. Obtaining this information is important to our ability to deliver the highest level of attention to you, but we also recognize that you expect us to treat this information appropriately. This policy describes the types of personal information we may collect about you, the purposes for which we use the information, the circumstances in which we may share the information and the steps that we take to safeguard the information to protect your privacy. As used throughout this policy, the term “Vigilant Futures” refers to Vigilant Futures LLC and its affiliates worldwide.

The Sources of Information
The personal information we collect about you comes primarily from the account applications or other forms and materials you submit to Vigilant Futures during the course of your relationship with us.

Also, information may be collected about you indirectly from monitoring or other means (e.g. recording of telephone calls and monitoring e-mails). In these circumstances, the information is not accessed on a continuous or routine basis, but it may be used for compliance or security purposes.

The Information We Have about You

If you deal with Vigilant Futures in your individual capacity, the typical information we collect about you would include:

• Your name, address and other contact details;
• Your age, occupation and previous work experience;
• Your educational background, professional/business references;
• A personal identifier such as, depending on your country of residence, your Social Security Number, National Insurance Number, Tax File Number, etc.

Of course, you are not required to supply any of the personal information that we may request. However, failure to do so may result in our being unable to process your application or extend employment opportunities to you. While we make every effort to ensure that all information we hold about you is accurate, complete and up to date, you can help us considerably in this regard by promptly notifying us if there are any changes to your personal information.

Our Use of Your Personal Information

We may use your personal information to:

• Administer, operate, facilitate and manage our employee candidate database. This may include sharing such information internally;
• Contact you or, if applicable, your designated representative(s) by post, telephone, electronic mail, facsimile, etc.;
• Facilitate our internal business operations and hiring processes.

If your relationship with Vigilant Futures ends, Vigilant Futures will continue to treat your personal information; to the extent we retain it, as described in this policy.

Disclosures of Your Personal Information within Vigilant Futures

In order to provide efficient and reliable employment opportunities to you, more than one entity within Vigilant Futures may be given, or given access to, your personal information. For example, one Vigilant Futures entity might share your information with another in order to facilitate the maintenance of your file. When so sharing your personal information, we adhere to applicable legal standards regarding the protection of personal information. Additional information on how your personal information is protected while within Vigilant Futures is provided below, under Information Security: How We Protect Your Privacy.

Disclosures of Your Personal Information to Third Parties

Vigilant Futures does not disclose your personal information to third parties.

You should know that Vigilant Futures will not sell your personal information.

Information Security: How We Protect Your Privacy

Vigilant Futures is committed to protecting the privacy and confidentiality of your personal information. We limit access to your personal information to authorized Vigilant Futures employees or agents. We also maintain physical, electronic and procedural safeguards to protect the information against loss, misuse, damage or modification and unauthorized access or disclosure. Some of the other central features of our information security program are:

• The use of specialized technology such as firewalls;
• Testing of the security and operability of products and services before they are introduced to the Internet, as well as ongoing scanning for publicly known vulnerabilities in the technology;
• Internal and external reviews of our Internet sites and services;
• Monitoring of our systems infrastructure to detect weaknesses and potential intrusions;
• Implementing controls to identify, authenticate and authorize access to various systems or sites;
• Protecting information during transmission through various means including, where appropriate, encryption; and
• Providing Vigilant Futures personnel with relevant training and continually updating our security practices in light of new risks and developments in technology.

Privacy and the Internet

The following additional information will be of interest to you if you access Vigilant Futures, or one of their associated businesses web sites:

• The private Vigilant Futures Web sites are built upon a secure infrastructure with multiple layers of protection, including measures ranging from proper physical security of our machines to system intrusion detection capabilities. Within such private sites, Vigilant Futures uses industry standard encryption technologies to protect your information from external compromise.
• Security is a cooperative effort between Vigilant Futures and the users of the Vigilant Futures Web sites. Please remember that your password and PIN are personal to you and should not be made available to any other person. Also, you should discontinue their use and notify us if you have any reason to suspect that someone else may be using them.
• "Cookies" are small text files consisting of information stored by your Web browser. This information is used for administrative purposes and to improve your experience with our Web sites. For example, this information helps authenticate you (i.e. verify that you are who you say you are), an essential component of site security. Cookies also make it easier for you to navigate a Vigilant Futures Web site by, among other things, "remembering" your identity so that you do not have to input your password multiple times as you move between pages or services. You can set your Web browser to inform you when cookies are set, or to prevent cookies from being set. However, if you decline to use cookies, you may experience reduced functionality, and declining to use authentication related cookies will prevent you from using the Web site altogether.
• "Clickstream" or similar data (e.g. information regarding which of our Web pages you access, the frequency of such access and your product and service preferences) may be collected and shared internally within Vigilant Futures

Other Privacy Policies or Statements; Changes to Policy

This policy provides a general statement of the ways in which Vigilant Futures protects your personal information. You may, however, in connection with specific products or services offered by Vigilant Futures, be provided with privacy policies or statements that supplement this policy. This policy may be changed from time to time to reflect changes in our practices concerning the collection and use of personal information. The revised policy will be effective immediately upon posting to our Web site. This version of the Policy is effective April 1, 2008.