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Our Commitment to Privacy

HR Anew’s Privacy Policy was developed as an extension of our commitment to combine quality products and services with integrity in dealing with our customers. Your privacy is very important to HR Anew. It is our goal to make your experience on our websites as enjoyable and rewarding as possible and we desire you to use the extensive resources, information, and tools located within our web pages with complete confidence.

HR Anew’s Privacy Policy is designed to assist you in understanding how we collect, use and safeguard the personal information you provide to us and to assist you in making informed decisions when using our site, our services, and our products. This policy was created to demonstrate our firm commitment to privacy and security. It describes how HR Anew collects information from all end users of our Internet services and products, what we do with the information we collect, and the choices you have related to the collection and use of such information.

What Information Do We Collect?

When you visit our site you may provide us with two types of information: personal information you actively choose to disclose (“Active Information”) and use information collected, in a way not visible to you, and on an aggregate anonymous basis as you and others browse our site (“Passive Information”).

No Use of Our Site by Persons Under Age 18

HR Anew is committed to protecting children’s privacy. It is our policy to comply with the Children’s Online Privacy Protection Act of 1998 and all other applicable laws. No person under age eighteen (18) should access or disclose information on this web site.

If you are using this web site you must be eighteen (18) years of age or older. If you are under this age, you are not permitted to access this web site for any reason due to the age restrictions for use of this web site. No information obtained by this website falls within the Child Online Privacy Act (COPA) and is not monitored as doing so. You may learn more about protecting children’s privacy online by visiting www.ftc.gov/kidsprivacy.

Active Information You Choose to Provide

You may be asked to provide personal information when you purchase or sign up to receive our services, products, or communications including type of internet access you have, your name, address, telephone number, and billing information (such as a credit card number). We use this information to manage your account with us (e.g., for billing purposes only). This information is not shared with third parties, unless there are special circumstances and we specifically state otherwise.

There may be instances when HR Anew has a resource affiliation with another company to provide a product or service. We may provide the resource partner with certain information such as the name and address of persons who purchased a product or subscribed for a service. The sole purpose of providing this information is to assess the results of the promotion. This information may not be used by our resource partner for any other purpose than described above.

Some of our web pages will allow you to purchase products and services or register to receive information such as complimentary training resources, assessment tools, special alerts, newsletters, catalogs, and service updates. You may be asked to provide contact information such as your email address, name, address, telephone number, and credit/debit card information. We will use this information only for the purpose described herein. We do not share this information with outside parties except to the extent necessary to fulfill your request.

HR Anew does not share personal information regarding visitors and users of our web sites with third parties.

Voluntary Surveys

We may occasionally conduct a voluntary visitor or customer survey. Your participation in a survey helps us to better understand your business needs and helps us improve our service and product offerings. Your survey responses will remain strictly confidential and will be combined with other survey responses and used in the aggregate. This aggregated, non personal information may be shared with third parties.

We may disclose anonymous information about user habits, characteristics and user patterns, based on aggregate user statistics to advertisers on our site. The parties who perform services for us (credit card processors, merchant bank, our Internet Service Provider) may also have access to your information in performing such services. Should we buy or sell assets of our company, another company may need to review our company’s assets, including your information, to make business decisions as to whether to acquire such assets.

Security

We use secure socket layer (SSL) encryption to protect the transmission of the information you submit to us when you use our secure online forms. The information you provide to us is stored securely.

We take special care to protect against the loss, misuse, and alteration of the information under our control. While we make every effort to ensure the integrity and security of our network and systems, we cannot guarantee that our security methods will prevent third parties (e.g., such as hackers) from illegally obtaining this information.

We secure your personal information submitted by you by using reasonable efforts to prevent unauthorized access or disclosure, or accidental loss or destruction of Active Information and Passive Information. Your postings on this site and other communications you may have with us via email or snail mail may not be secure unless we advise you that security measures are in place prior to your sending information. Therefore, if you choose to communicate with us through these means, you are assuming the risk of doing so and we request that you do not send or post sensitive information through these means.

Passive Information Collected

Cookies are a feature of web browser (Internet Explorer, Netscape Navigator, etc.) software that allows web servers to recognize the computer used to access a site. They are small pieces of data that are stored by a user’s web browser on one site to simplify subsequent interactions with that site by the same user or to use the information to streamline the user’s transaction on related web pages. This makes it easier for a user to move from site to site and to complete transactions over the Internet. Cookies should make your online experience easier and more personalized.

Our site utilizes cookies to collect, store, and sometimes track information about how our site is used for statistical purposes, to improve the services and products we provide, and to manage our technology networks. Passive Information gathered may include the date and time of visits, the site pages viewed, time spent at our site, the sites visited just before and just after our site. If you do not wish to transmit “cookie” information about yourself, you may turn off the cookie function in your web browser; please consult the “Help” section of your browser to correctly do so. Cookies do not enable third parties to access any of your personal information.

Our site’s servers also automatically identify your computer by its Internet Protocol address which is a unique string of numbers that is assigned to your computer by your Internet Service Provider. Your IP address may be used to address problems with our server or administer our site or to gather broad demographic information about our users.

We use Passive Information to gather information about our users and to enhance and design our site to make it easier, faster and friendlier to use. Additionally, cookies help us know information about how many people visit our site, when they visit and how they use our service. Passive Information may result in your viewing of particular advertising based on your user habits for your viewing on our site and a shopping experience customized to you in content, services and goods.

Broadly speaking, persons we employ directly, or as contractors or agents at our direction, use Active Information for purposes of administering our business activities, providing customer services such as support, and making available other products or services we think may be of interest to our customers. We may use the Active Information or Passive Information you provide to us to contact you about changes to our site, new services, features or products we offer, or other information we think you shall find valuable. If at any time you do not wish to receive such information, you may “opt-out” of doing so by sending an email to us at unsubscribe@hranew.com.

Your Information In Relation to Others We Link To

You may be able to access other websites through our site. When you do so you are doing so subject to their policies regarding privacy and data collection and you should read those sites’ privacy policies to make sure you agree to them before using such sites. When you choose to shop at such sites, you should read their privacy policies to make sure you agree to them before making purchases.

Sharing Information with the Government or As Otherwise Required by Law

HR Anew may be required by subpoena, law or government agency to disclose both Active and Passive Information you have provided to us. We retain our sole privilege to provide such information if we believe it is reasonable to do so. This includes providing information to credit agencies, merchant database agencies, law enforcement, collection agencies, or to satisfy laws such as the Child Online Privacy Act, Electronics Communications Privacy Act, regulations or governmental or legal requests for such information.

Changes and Updates to our Privacy Policy

Your use of our web site means that you accept the policy and the practices set forth herein. We reserve the right to make changes or modify our policy and practices by posting the new version with a new effective date. Your continued use indicates your agreement to the changes posted.

If you have questions about our Privacy Policy or the practices we have described herein, contact us through the information provided on our web site.

Last updated: March 12, 2006