De Novo Legal Privacy Policy

De Novo Legal, LLC respects the privacy of our offline/online visitors and clients. It is our policy to maintain the confidentiality and privacy of any personal data voluntarily submitted to us in writing, submitted electronically via our website, or submitted to us by our clients in connection with employment background screening, credential verification, investigations and other services. All data shall be collected, stored and used in compliance with applicable law.

De Novo Legal, LLC provides electronic discovery and document review services using web-based software for storage, review and production of electronic documents. In the course of providing this service, De Novo Legal, LLC adheres to strict confidentiality standards and privacy policies related to the use of information obtained from its clients, including personal information collected directly from clients or otherwise provided to De Novo Legal, LLC to enable the delivery of its services.

This Privacy and Security Statement (“Privacy Statement”) demonstrates our commitment to customer privacy. Because we receive important information about our clients, we have established this Privacy Statement to communicate our information storage and dissemination practices. We reserve the right to change our Privacy Statement at any time.

Scope

This Safe Harbor Privacy Policy applies to information pertaining to an identifiable individual residing in the European Union or other data that De Novo Legal, LLC acquires pursuant to its performance of services for its clients (“EU Personal Data"). This Policy does not apply to: (a) data collected and used by De Novo Legal, LLC which is not EU Personal Data; (b) the subsidiaries of De Novo Legal, LLC which do not receive EU Personal Data or; (c) data collected on any other De Novo Legal, LLC subsidiary website not related to EU Personal Data. The De Novo Legal, LLC Online Privacy Policy is located on www.denovolegal.com.

Provisions of our Safe Harbor Privacy Policy

De Novo Legal, LLC has joined the U.S. Department of Commerce's "Safe Harbor" program with respect to the EU Personal Data and utilizes such information in strict accordance with the Safe Harbor principles. The Safe Harbor principles and our Safe Harbor certification can be found at www.export.gov/safeharbor.

De Novo Legal, LLC is committed to protecting the privacy of personal data that is gathered and maintained on behalf of employers and clients requesting client data. We certify that, in relation to EU Personal Data, we adhere to the seven "Safe Harbor Principles" of the United States Department of Commerce as outlined in the European Commission's Directive on Data Protection. Our adherence to the seven Safe Harbor Principles is demonstrated below:

Notice

De Novo Legal, LLC performs services related to corporate litigation and investigative services as requested by our clients. All services are performed in accordance with applicable local and national laws. More information regarding the nature and scope of client data inquiries is available by contacting De Novo Legal, LLC in writing or by e-mail at the addresses listed on www.denovolegal.com or by writing to the contact listed below.

Choice

De Novo Legal, LLC affords individuals the opportunity to choose whether their personal information will be disclosed to a third party or will be used for a purpose incompatible with the purpose for which it was originally collected or subsequently authorized by the individual. Therefore, client data may be disseminated under these circumstances unless the client explicitly “opts-out.” Where a client chooses to “opt-out,” the data is not necessarily erased or deleted. Various laws require that the data be maintained on file for a specified period of time for client protection purposes. A client can “opt-out” by contacting De Novo Legal, LLC in writing or by e-mail at the addresses listed on www.denovolegal.com or by writing to the contact listed below. With respect to sensitive information, however, an individual must “opt-in” to the disclosure of the information to a third party or to the use of this information for a purpose other than its original purpose or that purpose authorized subsequently by the individual. In other words, unless a client chooses to provide explicit consent, a disclosure of sensitive information to a third party or for an unauthorized purpose will not be made.

Onward Transfer (Transfers to Third Parties)

With respect to the transfer of client data to third parties, the principles of “Notice” and “Choice” apply. Accordingly, client data is only provided to an employer or its agent for purposes described in the “Notice” section, and will not be disseminated to a third party where a client has “opted-out” or, in the case of sensitive information, failed to “opt-in.” De Novo Legal, LLC will disclose client data to employers or their agents who certify that they subscribe to the Safe Harbor Principles or are subject to the FCRA, the Data Protection Directive or applicable regulations governing client data. In the alternative, De Novo Legal, LLC will also disclose client data to employers or their agents who enter into a written agreement with De Novo Legal, LLC, in which the third party agrees to comply with the FCRA, certifies that they have a permissible purpose to use such data, and provides at least the same level of privacy protection as is required by the seven Safe Harbor Principles (in the instance where EU Personal Data is requested).

Security

De Novo Legal, LLC takes all reasonable procedures to protect personal and identifiable information from loss, misuse, unauthorized access, disclosure, alteration and destruction. All of our users' information, not just the sensitive information mentioned above, is kept strictly confidential in our offices and is stored on our servers in a secure, encrypted manner. Only employees who need the information to perform a specific job are granted access to personally identifiable information. Strong password protection protocols are used on all computers. Furthermore, all employees are kept up-to-date on our security and privacy practices. Finally, the servers that are used to store personally identifiable information are kept in a secure environment, with appropriate security measures. If you have any questions about the security of our service, you can send a letter to the contact listed below.

Data Integrity

De Novo Legal, LLC takes reasonable steps to ensure that data collected is accurate, complete, current, and reliable for its intended use. We only collect data that is strictly necessary for the purposes listed under the section entitled “Notice,” including (but not limited to) information that is necessary to identify the client.

Access

A client may request, in writing, access to all data collected and maintained about him or her. De Novo Legal, LLC affords the client a reasonable opportunity to correct, amend, or delete information that is inaccurate or incomplete, except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy, or where the rights of persons other than the individual would be violated. De Novo Legal, LLC reserves the right to engage in reasonable efforts to confirm the identity of the individual requesting the data to ensure the information is provided only to the subject of the data. De Novo Legal, LLC makes every effort to ensure that the data we collect and store is as accurate as possible. We cannot guarantee, however, that third party data sources are committed to making the same efforts, and therefore, we deny any responsibility for the accuracy of the data provided. To request information relating to his or her personal data, a client may contact De Novo Legal, LLC in writing or by e-mail at the addresses listed on www.denovolegal.com or by writing to the contact listed below. In addition, the client will be asked to provide sufficient evidence of his or her identity so we may ensure that information is being released to the correct individual. If, for a good reason, we are unable to provide the client with access to his or her data or to correct data, we will let him or her know.

Enforcement

De Novo Legal, LLC will verify adherence to the EU Safe Harbor Policy via in-house verification and internal policies and procedures implemented by the management of our company.

Dispute Resolution

In order to comply with the European Union’s Safe Harbor Principles, De Novo Legal, LLC commits to the resolution of complaints about your privacy and our collection or use of your personal information. We have committed to resolve any complaints by European Union citizens relating to this policy, which cannot be resolved directly with our company, through BBB EU Safe Harbor, a dispute resolution procedure administered by the Council of Better Business Bureaus, Inc.

If you have any questions regarding this policy, please contact:

Michael McDonald

De Novo Legal, LLC

666 Third Avenue, 7th Floor

New York, NY 10017

212-905-7500

michael.mcdonald@denovolegal.com

If you do not receive acknowledgment of your complaint or your complaint is not satisfactorily addressed by De Novo Legal, LLC, you should then contact:

Council of Better Business Bureaus, Inc.

BBB EU Safe Harbor

4200 Wilson Boulevard, Suite 800

Arlington, VA 22203

Phone: 703-276-0100

Web: www. us.bbb.org

Email: eusafeharbor@council.bbb.org

Contact Information You may send any question regarding our Safe Harbor Privacy Policy to the following address and contact person:

Michael McDonald

De Novo Legal, LLC

666 Third Avenue, 7th Floor

New York, NY 10017

212-905-7500

michael.mcdonald@denovolegal.com