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FALLON CONSULTANTS, LTD.
CUSTOMER PRIVACY POLICY STATEMENT
Date revised and posted: 01/12/2001

The Fallon Consultants, Ltd. Customer Privacy Policy has been developed as an extension of our commitment to combine the finest quality products and services with the highest level of integrity in dealing with our customers. The Policy guides how we collect, store and use information about customers and prospects, and it will be periodically assessed against new technologies, business practices and our customers' changing needs.

Fallon Consultants, Ltd. may, from time to time, modify this Customer Privacy Policy to reflect legal, technological and other developments. In that event the changes will appear at this location.

Our Policy recognizes two kinds of personal data that deserve varying levels of protection. Personally-Identifiable Information includes, for example, e-mail addresses, billing information, employment status and "click stream" data that tracks user activity on a Web site or online service. A subset of that category, Sensitive Data, deserves additional safeguards. Sensitive Data includes, by way of example, Social Security numbers, personal financial data (such as specific salary, net worth or individual portfolio information), and information about specific medical conditions.

Fallon Consultants, Ltd. is committed to using all reasonable efforts to abide by the following Policy statement:

Collection. Personally-Identifiable Information will only be collected to the extent that Fallon Consultants, Ltd. deems reasonably necessary to serve a legitimate business purpose. Please be aware that if you disclose Personally-Identifiable Information on Website message boards or chat areas, that information may be collected and used by third parties without our knowledge and may result in unsolicited communications from third parties. Such activities are beyond the control of Fallon Consultants, Ltd.

Notification. Customers and prospects will be notified (usually at the point where Personally-Identifiable Information is collected) as to the uses the business unit may make of the Personally-Identifiable Information collected from them.

Choice: Opt Out for External Distribution of Personally-Identifiable Information. Customers and Prospects will be given the opportunity to refuse permission for External Distribution of their name, address or other Personally-Identifiable Information through an Opt Out mechanism. (External Distribution does not include certain limited distributions such as sharing Personally-Identifiable Information with an entity working on behalf of Fallon Consultants, Ltd. to serve our customers; transfer of Personally-Identifiable Information in conjunction with the sale or similar transfer of a business unit; or the disclosure of Personally-Identifiable Information in connection with legal proceedings, investigations of crimes or other wrongdoing. However, sharing Personally-Identifiable Information with an entity working on behalf of Fallon Consultants, Ltd. or transferring Personally-Identifiable Information in conjunction with the sale or similar transfer of a business unit is considered an Onward Transfer and will be handled as described below.)

Security. Appropriate safeguards will be implemented to ensure the security, integrity and privacy of Personally-Identifiable Information about our customers and prospects.

Access: Review and correction. Procedures have been developed through which customers and prospects can, upon request, review and correct the Personally-Identifiable Information that has been collected from them by Fallon Consultants, Ltd. These procedures may not, however, compromise the security, integrity and privacy of either Fallon Consultants' own proprietary databases or databases licensed from third party companies.

Sensitive Data. The collection and use of Sensitive Data carries with it special obligations and responsibilities in order to maintain the data's security, integrity and privacy. Sensitive Data will not be rented or otherwise made available for External Distribution outside Fallon Consultants, Ltd. (although it may be made available through Onward Transfer as described below). Customers and prospects will be given the opportunity to refuse permission for their Sensitive Data to be distributed outside of the business unit that collected the Sensitive Data through use of an Opt Out mechanism for Internal Distribution within Fallon Consultants, Ltd.

Note: Customers of units based in an EU Member State will be asked for explicit consent (Opt In) to the transfer of EU Sensitive Data outside of the EU, including an Internal Distribution or transfer that takes place within a particular business unit of Fallon Consultants, Ltd.

Onward Transfer. Whenever Fallon Consultants, Ltd. permits a third party outside of Fallon Consultants to access Personally-Identifiable Information through either External Distribution or Onward Transfer, commercially appropriate procedures will be followed to help ensure that the Information is used only for authorized purposes and by authorized persons in a manner consistent with the choices customers and prospects have made under this Policy, and that the security, integrity and privacy of the information is maintained. Please note that our Website may contain links to other Websites that have their own privacy policies and practices. While Fallon Consultants, Ltd. will employ commercially appropriate procedures to help ensure that your information is only used for authorized purposes as described above, Fallon Consultants, Ltd. cannot make any guarantees with respect to the actions or policies of such third parties.

Children: Collection and use of information from children under the age of thirteen will be made in compliance with the Children's Online Privacy Act of 1998. Specifically, Fallon Consultants, Ltd. will:

  1. Provide parents or guardians with notice of our information practices;
  2. obtain prior verifiable parental or guardian consent for the collection, use, and/or disclosure of Personally-Identifiable Information from children;
  3. provide a parent or guardian, upon request, with the means to review the Personally-Identifiable Information collected from his or her child;
  4. provide a parent or guardian with the opportunity to prevent the further use of Personally-Identifiable Information that has already been collected, or the future collection of Personally-Identifiable Information, from that child;
  5. limit collection of Personally-Identifiable Information for a child's online participation in a game, prize offer or other activities to Personally-Identifiable Information that is reasonably necessary to participate in the activity; and
  6. establish procedures to protect the confidentiality, security and integrity of the Personally-Identifiable Information collected from children.

Questions and comments? The Fallon Consultants, Ltd. Customer Privacy Policy has been developed out of respect for the privacy preferences and choices of our customers and prospects. We have established procedures to ensure that every reasonable effort is made to address your concerns. Each business unit within Fallon Consultants, Ltd. has designated a Privacy Official to implement our Customer Privacy Policy for its respective customers and prospects. You should find contact information on each of our business unit's Web sites that collect data from you.

The Corporation also has established a standing Privacy Steering Committee consisting of senior corporate executives and managers from our major business segments. This Committee will continue to oversee implementation of and compliance with our Policy and will adapt the Policy to reflect changes in technology and customer expectations. The co-chairs of the Committee are also charged with handling unresolved customer concerns. You can reach them by sending an e-mail message to efallon@fallonconsultants.com.

To ensure that we follow our stated Policy, we also are conducting periodic and random reviews of our Web sites and other products and services. The results of our review are shared with senior management and our Board of Directors. A report of our experience will be available annually.