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  TnT Expense Management Privacy Policy  
 


TnT Expense Management ("TnT") is committed to maintaining its client's personal and proprietary information ("Client Information"). To further TnT’s commitment, TnT abides by the Safe Harbor Principles developed by the U.S. Department of Commerce and the European Commission and the Frequently Asked Questions (FAQs) issued by the Department of Commerce on July 21, 2000. The Safe Harbor Privacy Policy sets forth the principles for protecting client and vendor information, whether received via physical delivery, websites, data feeds, emails, file transfers, or wireless ordering portals. The Safe Harbor Privacy Policy incorporates the principles of Notice, Choice, Onward Transfer, Security, Data Integrity, Access, and Enforcement and is registered with the U.S. Department of Commerce’s Safe Harbor Program.

TnT implemented various administrative, technical, and physical safeguards, designed to ensure the security and confidentiality of customer data, to protect against anticipated threats and hazards to the security or integrity of such information, and to protect against unauthorized access to such information. Such measures include, but are not limited to encryption, physical access security and other appropriate technologies.

NOTICE

Client Information

All Client Information possessed by TnT has been provided by its clients or vendors and is used for the specific purposes of performing the contracted services. At times TnT may provide a strategic partner with Client Information necessary to perform the contracted services, nonetheless TnT requires all third parties to agree that they will protect Client Information to the degree that they would protect their own confidential information.

Use of IP Addresses

For security purposes, TnT captures IP addresses of users who access its website. With respect to personal information, TnT only captures information voluntarily disclosed by the user. E-mail addresses are also captured as validation that the user is entitled to access and use certain information. TnT uses this information to track the users visiting the website to ensure security for its clients.

If you have any questions concerning the security of your information or how it is used please contact TnT’s Privacy Officer via privacyoffer@tntem.com. This Privacy Policy will be available via http://www.tntem.com as of March 18, 2008.

CHOICE

TnT does not share Client Information with a third party unless required by law or authorized by the respective client. For this reason, there is no need to offer clients the choice to opt out. TnT’s clients are the gatekeepers to their information, thus they determine to what extent their information is utilized.

ONWARD TRANSFER

TnT does not disclose Client Information to a third party unless required by law or requested by the client. In the instances that Client Information is disclosed, TnT requires all third parties to agree that they will protect Client Information to the degree that they would protect their own confidential information.

SECURITY

TnT does take security seriously and has implemented ongoing measures to prevent Client Information from being lost, misused, altered, destroyed, accessed without authorization, or inappropriately disclosed. To prevent unauthorized access, to maintain data accuracy, and to ensure the correct use of information, TnT has implemented appropriate physical, electronic, and managerial procedures to safeguard and secure Client Information. TnT is “Statement of Auditing Standard, Number 70 (SAS 70) Type II” certified. To become SAS 70 certified, TnT contracted an independent third party to test and verify its security measures related to storing, processing, and maintaining Client Information.

DATA INTEGRITY

TnT will only use and process Client Information for the purposes it was collected or for the purposes authorized by the client. TnT will take reasonable steps to ensure that any Client Information received is used for its intended use and is accurate, complete, and current.

ACCESS

The Client Information that TnT collects is sensitive, which makes security and accuracy extremely important. To ensure that Client Information is gathered and processed correctly and accurately, TnT performs audit trails to track the changes made by the client. If clients do find an issue with the accuracy of the Client Information, they are to contact TnT, who can process the updates within two business days. All requested changes will be made within 48 hours. Further, there are processes in place to ensure TnT enters and records the correct information. To verify that the updated Client Information is correct and accurate, clients may access their Client Information in a read-only format from the web reports. When clients view their Client Information they are required to have a valid username and password; each viewing is electronically monitored and recorded.

In addition, all employees are required to read and sign a copy of TnT's Information Technology Security Policy. Requiring each employee to acknowledge these security policies emphasizes the importance of security for Client Information. Only those employees who need Client Information to perform their duties are authorized to access such information.


ENFORCEMENT

If a client has any questions of how its information is used or disclosed or if it would like to initiate a dispute with TnT regarding its compliance with its Privacy Policy, the client may contact TnT’s Privacy Officer via privacyoffer@tntem.com. All issues or disputes will be addressed within two business days of TnT obtaining receipt of such correspondence. TnT is committed to remedying any issue or dispute arising out of TnT’s failure to comply with its Privacy Policy. Therefore, if client is unsatisfied with TnT’s resolution, client may file a dispute pursuant to the policies of American Arbitration Association.

VERIFICATION

TnT certifies that it is compliant with the principles provided by the Safe Harbor Program and that it adheres to the Safe Harbor principles described in its Privacy Policy. TnT will monitor its own compliance as to its Privacy Policy. For more information about the Safe Harbor Program, please visit http://www.export.gov/safeharbor.

CHANGES TO THIS PRIVACY POLICY

TnT reserves the right to update this Privacy Policy at anytime. If in such case TnT implements a change, the change will be reflected in Policy. If the change is material, TnT will notify the client by posting a notice prior to its implementation. TnT encourages its clients to periodically review this Privacy Policy to be informed of how TnT protects its Client Information.