Safe Harbor Data Privacy Statement

 
The A.C. Coy Company ("A.C. Coy") is a professional services firm providing
Information Technology consulting services to private and publicly traded
businesses. Protecting your privacy is important to A.C. Coy. A.C. Coy ("the
firm," "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. A.C. Coy ("the firm," "we," "us," or "our") adhere to the U.S.-
Switzerland Safe Harbor Framework as set forth by the U.S. Department of
Commerce. Accordingly, we follow the Safe Harbor Principles published by the
U.S. Department of Commerce ("Principles") with respect to all such data. If
there is any conflict between the policies in this statement and the Principles, the
Principles will govern. This statement outlines our general policy and practices
for implementing the Principles, including the types of information we gather, how
we use it, and the choices affected individuals have regarding our use of, and
their ability to correct, that information.
This statement applies to all personal information we handle (except as noted
below), including on-line, off-line, and manually processed data. For purposes of
this statement, "personal information" means information that: is transferred from
the EU to the United States; is recorded in any form; is about, or pertains to, a
specific individual; and can be linked to that individual.
It does not include information that pertains to a specific individual, but from
which that individual could not reasonably be identified.

Principles Protecting Individuals' Privacy

Notice and Choice
To the extent permitted by the Safe Harbor Agreement, we reserve the right to
process personal information in the course of providing professional services to
our clients without the knowledge of individuals involved. Where we collect
personal information directly from individuals in the E.U., we inform them about
the types of personal information we collect from them, the purposes for which
we collect and use it, and the types of non-agent third parties to which we
disclose that information. We also inform those individuals about the choices and
means, if any, we offer individuals for limiting the use or disclosure of their
information.

Disclosures and Transfers
A.C. Coy will not disclose an individual's personal information to third parties,
except when one or more of the following conditions is true:
• We have the individual's permission to make the disclosure;
• The disclosure is required by law or professional standards;
-The disclosure is reasonably related to the sale or disposition of all or part of
our business;
• The information in question is publicly available;
• The disclosure is reasonably necessary for the establishment or defense of
legal claims; or
• The disclosure is to another A.C. Coy entity or to persons or entities providing
services on our or the individual's behalf (each a "transferee"), consistent with
the purpose for which the information was obtained, if the transferee, with
respect to the information in question:
• is subject to law providing an adequate level of privacy protection;
• has agreed in writing to provide an adequate level of privacy protection; or
subscribes to the Principles.

Permitted transfers of information, either to third parties or within A.C. Coy,
include the transfer of data from one jurisdiction to another, including transfers to
and from the United States of America. Because privacy laws vary from one
jurisdiction to another, personal information may be transferred to a jurisdiction
where the laws provide less or different protection than the jurisdiction in which
the information originated.


Data Security
A.C. Coy takes your security seriously and takes reasonable steps to protect
your information. To prevent unauthorized access or disclosure, maintain data
accuracy, and ensure the appropriate use and confidentiality of information,
either for its own purposes or on behalf of our clients, A.C. Coy has put in place
appropriate physical, electronic, and managerial procedures to safeguard and
secure the information we process. However, we cannot guarantee the security
of information on or transmitted via the Internet.

Data Integrity
We process personal information only in ways compatible with the purpose for
which it was collected or subsequently authorized by the individual. To the extent
necessary for such purposes, we take reasonable steps to make sure that
personal information is accurate, complete, current, and otherwise reliable with
regard to its intended use.

Access and Correction
If an individual becomes aware that information we maintain about that individual
is inaccurate, or if an individual would like to update or review his or her
information, the individual may contact us using the contact information below.
We will take reasonable steps to permit individuals to correct, amend, or delete
information that is demonstrated to be inaccurate. The individual will need to
provide sufficient identifying information, such as name, address, birth date, and
social security number. We may request additional identifying information as a
security precaution. In addition, we may limit or deny access to personal
information where providing such access would be unreasonably burdensome or

expensive in the circumstances, or as otherwise permitted by the Safe Harbor
Agreement. In some circumstances, we may charge a reasonable fee, where
warranted, for access to personal information.

Enforcement and Dispute Resolution
A.C. Coy utilizes the self-assessment approach to assure its compliance with our
privacy statement. A.C. Coy periodically verifies that the policy is accurate,
comprehensive for the information intended to be covered, prominently
displayed, completely implemented, and in conformity with the Principles. We
encourage interested persons to raise any concerns with us using the contact
information below. We will investigate and attempt to resolve complaints and
disputes regarding use and disclosure of personal information in accordance with
the principles contained in this policy.
With respect to any complaints relating to this policy that cannot be resolved
through our internal processes, we have agreed to participate in the dispute
resolution procedures of the panel established by the EU data protection
authorities to resolve disputes pursuant to the Safe Harbor Principles. In the
event that we or such authorities determine that we did not comply with this
policy, we will take appropriate steps to address any adverse effects and to
promote future compliance.
Any person who we determine is in violation of our privacy policies will be subject
to disciplinary process.

Privacy Statement Changes
This privacy statement may be changed from time to time, consistent with the
requirements of the Safe Harbor. We will post any revised policy on this Web
site, or a similar Web site that replaces this Web site.

Information Subject to Other Policies
We are committed to following the Principles for all personal information within
the scope of the Safe Harbor Agreement. However, certain information is subject
to policies of the firm that may differ in some respects from the general policies
set forth in this statement.
Information relating to present or former A.C. Coy personnel is subject to our
policies concerning personnel data privacy, which are available to present A.C.
Coy personnel on A.C. Coy's intranet and former A.C. Coy personnel upon
request.

Information obtained from or relating to clients or former clients is further subject
to the terms of any privacy notice to the client, any engagement letter or letters
with the client, and applicable laws and professional standards.

How to Contact Us
Questions, comments or complaints about A.C. Coy's Safe Harbor Data Privacy
Statement or data collection and processing practices can be e-mailed to
jfalascino@accoy.com, or mailed to J. Falascino, A.C. Coy 395 Valley Brook Road
McMurray, PA 15317.   In the event that a complaint is not satisfactorily addressed
by A.C.Coy  within a reasonable time frame, you may contact the
Federal Trade Commission at www.ftc.gov/ftc/complaint.htm, or via phone at
202-382-4357.

EFFECTIVE November 16, 2010