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DDB Worldwide Communications Group Inc.
US-EU/Swiss Safe Harbor Privacy Policy

DDB Worldwide Communications Group Inc. (“DDB”) respects privacy and operates within the Safe Harbor Principles published by the US Department of Commerce and described at http://www.export.gov/safeharbor/. All capitalized terms used in this Privacy Policy have the meanings expressed in the EU directive EC/95/46 dated 24th October 1995 or at http://www.export.gov/safeharbor/. If there is any conflict between this Privacy Policy and the Safe Harbor Principles, the Principles will govern.

DDB receives data in a variety of ways to evaluate employee performance. The data collected will be human resource data and may include such information as name, date of birth, job title, date of hire, compensation, benefits package, and employee performance evaluations. The data may be collected on-line, off-line or through manual processes. This Privacy Policy applies to all Personal Data collected, whether electronic, paper or verbal format, in the EU and Switzerland. Individuals should review this Privacy Policy and not provide Personal Data to DDB unless they agree to these principles.

DDB will provide individuals Notice of the purposes and uses of the information collected and the choices for limiting its use and disclosure, including the types of third parties to which the Personal Data may be transferred. This Notice will be provided at either the initial point the Personal Data is collected or before it is used for a different purpose from which it was collected or before it is transferred to a third party.

Individuals will be given a Choice to opt-out if their Personal Data is to be disclosed to a third party or used for a purpose different from which it was originally collected.

DDB will ensure Security and Data Integrity for the Personal Data collected. DDB will protect Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction. DDB will take reasonable steps to ensure that Personal Data is reliable for its intended use, accurate, complete, and current.

Individuals may have reasonable Access to their Personal Data to correct, amend or delete information that is inaccurate. DDB may require an individual to provide acceptable proof of identity prior to granting reasonable Access. Requests for Access should be directed to safe.harbor@ddb.com.

In order to enforce these principles, DDB employs Verification through Self-Assessment, such as ensuring implementation of this Privacy Policy and appropriate employee training. DDB will initiate investigation of complaints from people who feel the privacy of their Personal Data has been violated. If initial resolution of the complaint is not satisfactory, DDB is committed to cooperating with the EU Data Protection Authority mechanism. Complaints regarding Personal Data should be directed to safe.harbor@ddb.com.

DDB is subject to FTC Action for non-compliance with the Safe Harbor principles. Such Remedy and Sanctions include potential administrative action and/or civil penalties.