NeuCo - The Optimization Standard
  

Privacy Statement

General Information
NEUCO respects the privacy of our customers, business partners and employees. We recognize the need for appropriate protections and management of your personal information that you provide to us. NEUCO has therefore established this Privacy Statement to assist you to understand what information we collect and how that information is used. This Privacy Statement applies to NEUCO Corporation including its Divisions and Subsidiaries.

Safe Harbor Compliance
NEUCO's privacy practices are in compliance with the U.S. and E.U. Safe Harbor principles. Information about the U.S. Department of Commerce Safe Harbor certification can be found at www.export.gov/safeharbor.

What personal information does NEUCO collect?
Personal Information is information that can be used to identify or contact a specific individual, such as a name, address, telephone number or email address. NEUCO may collect certain personal information from customers, business partners, employees and candidates for employment. NEUCO does not collect personal information when you visit NEUCO's web sites unless you choose to provide such personal information.

On NEUCO web sites you can order products or services, register products, request information, subscribe to marketing or support materials, register to a secure extranet site to obtain access to product information, support, services and training, or apply for jobs at NEUCO. The types of personal information you provide to us on these pages may include name, address, phone number, e-mail address, user IDs and passwords, billing and transaction information, credit card or other financial information, contact preferences, educational and employment background, job interest data and benefit choices.

NEUCO also collects personal information of its employees (human resources data) in connection with administration of its Human Resources programs and functions. These programs and functions include compensation and benefit programs, performance appraisals, training, business travel, expense and tuition reimbursement, identification cards, access to NEUCO facilities and computer networks, employee profiles, internal employee directories, Human Resource recordkeeping, and other employment related purposes. NEUCO employees can go on-line to access their personal profile, job related data, compensation and benefit information, to make benefit elections and transactions and to make changes to their personal information.

How does NEUCO use personal information?
NEUCO will use personal information to provide customers and business partners with information and services and to help us better understand your needs and interests. Specifically, we use your information to help you complete a transaction or order, to communicate with you, to deliver products/services to you, to bill you for products/services you purchased, and to provide ongoing service and support. Occasionally we may use your information to contact you to complete surveys that we use for marketing and quality assurance purposes. Personal information collected online may be combined with information you provide to NEUCO through other sources such as trade shows or seminars.

NEUCO may share your personal information with third parties in responding to your requests for products or services or product evaluations. Also, we may on occasion allow selected partners to send you special offers in blind mailings. Generally, you will be given the opportunity to opt out of having your personal information shared with these third parties. However, if you request information on any of our products/services, NEUCO may provide your information to third party distributors and resellers who may subsequently contact you directly to purchase such products/services. In these instances, you will not have the opportunity to opt out of having your information shared with these third party distributors and resellers.

Some of NEUCO’s websites make on-line newsgroups available to our users. Any information that is disclosed in these newsgroups becomes public information and you should exercise caution when deciding to disclose your personal information. NEUCO may, from time to time, send email regarding our products and services to users who have posted to our newsgroups. Each participant's opinion expressed in a newsgroup is his or her own and should not be considered as reflecting the opinion of NEUCO.

To the extent that NEUCO uses personal information to email you about our product and services, NEUCO's email practices are in compliance with the U.S. and E.U. SPAM laws. Information about the U.S. and E.U. SPAM laws can be found at http://www.spamlaws.com/.

NEUCO uses personal information to consider candidates for employment opportunities within NEUCO. NEUCO uses personal information about its employees in connection with the administration of its Human Resources programs and functions and for purpose of communicating with its employees.

Except as provided in this Statement, NEUCO does not use your personal information for a purpose other than the stated purpose for which such information is collected.

Personal information given to NEUCO may be transferred across state and country borders for data consolidation, storage and simplified information management.

With whom does NEUCO share personal information?
NEUCO contracts with third party service providers and suppliers to deliver complete products, services and customer solutions. NEUCO may share personal information with its service providers and suppliers for the sole purpose and only to the extent needed to support the customers’ business needs. Service providers and suppliers are required to keep confidential the personal information received from NEUCO and may not use it for any purpose other than as originally intended.

Human Resources data may be shared with third party vendors for the exclusive purpose of enabling the vendor to provide service and/or support to NEUCO in connection with these Human Resource programs and functions. Personal data is not shared with third parties for non-employment related purposes.

Third parties receiving personal information are expected to apply the same level of privacy protection as contained in this Privacy Statement.

Except as provided above, NEUCO will not share personal information with any other third parties without your permission, unless required by, or in connection with, law enforcement action, subpoena or other litigation, or applicable law.

NEUCO will not sell, trade or lease your personal information to others.

Choice and Consent
NEUCO does not require that you provide NEUCO with personal information. The decision to provide personal information is voluntary. If you do not wish to provide the personal information requested, however, you may not be able to proceed with the activity or receive the benefit for which the personal information is being requested.

Except as expressly stated otherwise in this Privacy Statement, you may opt out of having NEUCO share personal information with third parties as described in this Privacy Statement by notifying NEUCO in writing of your desire to do so.

Sensitive Information
Sensitive information is defined as personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or information specifying the sex life of the individual.

Except as provided below, NEUCO does not request or receive sensitive information from visitors to our web sites. NEUCO may receive sensitive information such as medical or health conditions, or race and ethnic data regarding its employees in connection with the administration of its health and welfare benefit plans, or as part of government mandated recordkeeping requirements. Such information will not be shared with third parties without the employee’s affirmative approval as required by applicable law. In addition, sensitive information will not be used for a purpose other than its original purpose without the employee’s approval. Further, NEUCO will treat as sensitive any information received from a third party where the third party treats and identifies the information as sensitive.

Access to and accuracy of your information
NEUCO strives to keep your personal information accurate. We have implemented technology, management processes and policies to maintain data accuracy. We will provide you with access to your information, including making reasonable effort to provide you with online access and the opportunity to change your information. To protect your privacy and security, we will also take reasonable steps to verify your identity, such as a password and user ID, before granting access to your data.

NEUCO will not process personal information in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by the individual, as required by applicable law.

Security of Personal Information
NEUCO is committed to taking reasonable efforts to secure the personal data you choose to provide us. To protect the privacy of any personal information you may have provided, NEUCO employs industry-standard controls including physical access controls, Internet firewalls, intrusion detection, and network monitoring. In addition, access to sensitive data as defined in this Statement is limited to those individuals and agents having a need to know.

Other Information/Logging and Cookies
NEUCO collects and/or logs Internet Protocol addresses, Internet domain names, the web browser and operating system used to access the NEUCO web site, the files visited, the time spent in each file, and the time and date of each visit.

NEUCO also uses cookies on some of its web sites. Cookies are identifiers that can be sent from a web site via your browser to be placed on your computers hard drive. Thereafter when you visit a web site, a message is sent back to the web server by the browser accessing the web site. You may elect not to accept cookies by changing the designated settings on your web browser. However, not utilizing cookies may prevent you from using certain functions and features of web sites. The information collected from the use of cookies is used and analyzed to improve NEUCO's web sites.

You can set your browser to notify you when you are sent a cookie, giving you the chance to decide whether or not to accept it. The information we collect and analyze is used to improve our service to you and personalize your web-browsing experience.

Links to Non-NEUCO Web Sites and Third Parties
The NEUCO web sites may provide links to third-party web sites for your convenience and information. If you access those links, you will leave the NEUCO web site. NEUCO does not control those sites or their privacy practices, which may differ from NEUCO’s. We do not endorse or make any representations about third party web sites. The personal data you choose to give to unrelated third parties is not covered by the NEUCO Privacy Statement. We encourage you to review the privacy policy of any company before submitting your personal information. Some third party companies may choose to share their personal data with NEUCO; that sharing is governed by that third party company's privacy policy.

Verification
NEUCO will engage in periodic self-assessment to verify that it continues to be in compliance with this Privacy Statement.

Contact Information
If you have any questions regarding the Privacy Statement or believe that the privacy of your personal information has not been respected, you may submit a complaint in writing to the attention of NEUCO’s Office of the General Counsel, 176 South Street, Hopkinton, MA 01748.

Dispute Resolution
If an employee living in an E.U. member country has a complaint regarding the transfer of human resources data to the U.S., NEUCO agrees to cooperate with the appropriate European data protection authority for handling such complaints. NEUCO agrees to handle all other disputes involving the transfer of personal data from the EU to the U.S. in accordance with the JAMS dispute resolution procedures.

Except as provided above, dispute resolution for all other individuals shall be in accordance with applicable law.

Changes to this Statement
NEUCO will review and update this Statement periodically.