Notice of Privacy Policy – Effective January 30, 2012

Introduction
Platinum HR Management (“PHRM”) respects your privacy. We have created this privacy policy (“Privacy Policy”) to demonstrate our firm commitment to online privacy. This “Notice of Privacy Policy” discloses the information gathering and dissemination practices for certain of PHRM’s Web Sites, which include platinumhrm.com and our password-protected Internet service platforms (collectively referred to as the “PHRM Web Sites”), which are available primarily to us, our clients, our employees and their families. Except as noted above, this Privacy Policy applies to all information that you provide to PHRM and that PHRM maintains electronically, whether you provide the information through the PHRM Web Sites or through other means. Additionally, this Privacy Policy applies to any personal information obtained from your use (and, if applicable, your family’s use) of the PHRM Web Sites. This Privacy Policy does not apply to any information that you may provide to third parties; for example, other sites linked to the PHRM Web Sites. You should contact such third parties directly to determine their respective privacy policies. As used herein, the terms “PHRM,” “we,” “our” and “its” when referring to Platinum HR Management and its related companies are used only for convenience and are not intended to be an accurate description of ownership, operation or corporate/legal relationships.

What information does PHRM collect?

If you are an employee or client of PHRM, we collect and maintain a variety of personal information about you and, if applicable, your company and employees. This information may be collected through the PHRM Web Sites or through paper forms submitted by you. For employees, the information we maintain includes, among other things:

·                 your name, phone number and address (street and e-mail)

·                 age, marital status and occupation

·                 information about your job history and employment status

·                 information about your salary and benefits, including health benefits, your time off, your retirement plans, your Social Security or taxpayer identification number

·                 your recruiting and training history

·                 information about your family members such as their names, addresses and Social Security numbers

We may make some or all of this information available for your or your worksite employer’s use on the PHRM Web Sites. For clients, examples of this information include:

·                 your location

·                 your number of worksite employees

·                 the gross payroll of worksite employees assigned to your location

·                 your SIC codes

·                 information about insurance and other benefit plans

Depending on the use that you make of the PHRM Web Sites, we may also collect your Internet Protocol (IP) address (which is the unique address of your computer), information about your interests and preferences, and, if you decide to send us your resume, information included in your resume. From time to time, we may conduct surveys or offer contests or other promotional events, and gather additional personal information from you in connection with those events. PHRM may store and analyze log files from user sessions.

What is this information used for?

We use your personal information in the course of your employment or client relationship with PHRM.  Among other things, we use this information to provide you with the services available on the PHRM Web Sites. For example, we may allow you to edit and update personal information online and allow you to download forms that have been pre-populated with your personal information. We also use your information for other things, which may include but is not limited to the following:

·                 Use of IP Address

IP addresses are numbers that are automatically assigned to your computer, and if associated with other individually identifiable information, could be considered personal information. We use your IP address to help diagnose problems with our server and to administer and improve the PHRM Web Sites. Your IP address is also used to help identify you and to gather broad demographic information, some of which we aggregate and then share with our strategic alliances or potential strategic alliance companies. We also use your IP address to keep track of the information you have seen on our sites.

·                 Use of Cookies

Cookies are a standard technology used by commercial Web services to store small pieces of information on your hard drive by sending a small string of text to your browser. They make your use of the PHRM Web Sites more pleasing and efficient by, for example, “personalizing” your user interface or identifying which parts of a site you have previously visited. They also enable us to pre-populate, or automatically fill out, forms and schedules. They enable us to tailor the information you receive and to assist third-party organizations with whom we have strategic alliances by identifying you as an PHRM client, employee or user of the PHRM Web Sites. Most Web browsers automatically accept cookies, unless you have configured yours not to accept them. In order for us to provide you with services on PHRM Web Sites, your browser must accept cookies, as they are essential for site administration and security. PHRM does not use cookies either to collect individually identifiable information or to collect non-individually identifiable information using a cookie that is combined with a personal identifier.

·                 Other General Information

If you send us your resume, we use that information to assist you with job placement. PHRM may also collect the name of the domain from which you access the Internet (e.g., aol.com); the date and time you access the PHRM Web Sites, the Internet address of any Web site from which you link directly to the PHRM Web Sites as well as collecting and storing other information in a user’s log file. A user’s log file tells PHRM where a user comes from when entering the PHRM Web Sites, which part of the PHRM Web Sites the user visits as well as where the user goes when leaving the PHRM Web Sites; and how much time the user spends in the PHRM Web Sites. In addition, PHRM may collect e-mail addresses and other personal information from persons who are not current employees or clients of PHRM.

·                 Rewarding Use of the PHRM Web Sites

PHRM may use information it collects in order to reward or provide incentives to employees, client companies or other users of the PHRM Web Sites for visiting the PHRM Web Sites, using services provided on the PHRM Web Sites, or for visiting the Web sites of PHRM’s strategic alliances or affiliates.

With whom is this information shared?

PHRM shares personal information only as described below:

·                 Your Worksite Employer

If you are an employee, most of your personal information is also available to your individual worksite employer. However, PHRM does not provide information regarding your physical and/or mental health to any third party for any purposes, unless compelled by a governmental or legal authority.

·                 Governmental Authorities, Compliance with Law and Protection of PHRM and Others
We provide information to governmental authorities when required to do so by law (for example, we report information regarding your compensation and withholding to the U.S. Internal Revenue Service and state taxing authorities). PHRM will also provide personally identifiable information to third parties if compelled to do so by an appropriately empowered governmental or legal authority, or, as necessary, to protect PHRM’s rights or the rights of third parties.

·                 Benefit Plan Providers

PHRM will also provide personally identifiable information to its third-party benefit providers in conjunction with the administration of its benefit plans.

·                 Medical Emergencies

If necessary to respond to an apparent medical emergency, PHRM may disclose selected employee information.

·                 Business Transfers

As PHRM continues to develop its businesses, it may sell various aspects of its business. If PHRM sells a portion of its business, it will transfer personal information associated with that business as part of such a sale. Also, in the unlikely event that PHRM or substantially all of its assets are acquired, personal information regarding employees and clients will be one of the transferred assets.

What access do you have to information you provide?

You have access to much of your personal information through PHRM Web Sites, where you can view and update most of the personal information we maintain.

Security measures

PHRM makes access to your personally identifiable information subject to certain security measures, including technological controls such as “firewalls,” in accordance with industry standards. When the use of the PHRM Web Sites involve the transmission of confidential information about you or PHRM, we use Secure Socket Layer (SSL) technology to establish a secure connection between your PC and our server. SSL allows the transmission of encrypted information from your PC to our server and back again and is the industry standard for Internet platform security. No data transmission over the Internet can be guaranteed to be 100% secure, so while PHRM strives to protect your personal information, we cannot ensure or warrant the security of any information that you transmit to PHRM.

Disclaimer of responsibility for privacy policy and content at linked sites

The PHRM Web Sites may provide you with links to other Web sites. We are not responsible for those sites and cannot control the use of information that you submit once you reach those sites, nor can we control the content of what is offered on those sites or on links from those sites. You should contact such third-party Web sites directly to determine their privacy policies.

Use of information from third parties

We may use information about you provided to us by third parties (such as credit reporting agencies or strategic alliances) in order to offer you their services and products, to improve our own services or to evaluate your eligibility for our services.

This is not a children’s Web site

PHRM does not knowingly solicit data from children, and we do not knowingly market to children.

Applicable only to U.S. residents

The PHRM Web Sites are designed for and intended only for the use of clients located in the United States and employees who are U.S. citizens or are residents of the United States If you are a client that is located outside of the United States, you are not authorized to access any of the PHRM Web Sites.

Changes in these policies and practices

PHRM reserves the right to change its privacy policies and practices periodically, without providing individual notice, by updating this Privacy Policy notice. This Privacy Policy was last updated on January 23, 2012. You agree that it is your responsibility to monitor such updates. Your continued use of any of the PHRM Web Sites after such revisions have been made or your failure to object in writing to any notice of such change will constitute your full acceptance of such revised Privacy Policy.

California Residents – Your Privacy Rights

California Civil Code Section 1798.83 permits California residents who provide personal information in obtaining products or services for personal, family or household use to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for their direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to the address provided at the end of this Privacy Policy. Please be aware that not all information sharing is covered by the Section 1798.83 requirements, and only information on covered sharing for California customers will be included in our response.

More information

If you have any questions about this Privacy Policy, please contact us: Platinum HR Management, 4512 Farragut Road, Brooklyn, NY 11203.   Telephone: 718.859.1600; Email address: info@platinumhrm.com

In accordance with California Civil Code § 1786.20, please contact Zlaty Klein at 323.954.0054, zklein@platinumhrm.com and/or 5455 Wilshire Blvd, Suite 702, Los Angeles, CA 90036 for assistance regarding our privacy practices or policies in the event of a compromise of your information.