1. Purpose

• 1.1

  To formalise the Exela, LLC  ("Exela") approach to securing personally identifiable information and overall privacy. HOV Services respects the privacy of its employees, customers and shareholders and takes its responsibilities regarding the security of information seriously. In accordance with Exela's commitment to exceed expectations for every one of its customers, Exela has placed into effect the following Privacy Policy

  1.2

  This Privacy Policy and Safe Harbor Policy shall apply to all Exela subsidiaries with the exception of the following: Lason India Pvt. Ltd., Vetri Software Pvt. Ltd., Imagenes Digitales, S.A. de C.V., Promotora de Tecnologia, S.A. de C.V., HOV Services (Nanchang), Ltd., Exela Canada Company, HOV Services (Beijing) Ltd., S-Corp Philippines, Inc., Sourcecorp de Mexico S.A. de C.V.

2. Guiding Principles

• 2.1

  As a leading provider of Transaction Processing outsourcing, Exela's customers include over 50% of FORTUNE 100^® companies across key verticals such as financial services, telecommunications, healthcare, insurance, construction, publishing, finance and accounting and government, we have occasion to collect, store and use personal information from a variety of different sources. Exela believes in protecting that information and has established this Privacy Policy as a guiding document for the collection, use and storage of personal information.

• 2.2

  Exela expects employees, independent contractors, vendors and other users of systems and documents that may contain personal information to protect such personal information from unauthorised disclosure or use; and destroy or delete such personal information when no longer required for the purpose intended or by law, whichever is longer.

• 2.3

  Exela expects each employee, independent contractor, vendor or other user of personal information to apply appropriate measures to protect personal information where collected, used or stored in accordance with the applicable and enforceable laws of those countries in which Exela is operating. As global laws and ethical concerns of privacy are constantly evolving, Exela will continue to adopt reasonable policies and information security measures to meet these evolving standards.

3. Policy

• 3.1

  Exela adheres to the U.S.-E.U. Safe Harbor privacy policies of Notice, Choice, Onward Transfer, Security, Data Integrity and Access and Enforcement.

• 3.2

  Collection of Information. Exela collects personally identifiable information when voluntarily submitted by our online and on site visitors. The information provided is used to fulfill specific requests. This information is only used to fulfill the specific request, unless given permission to use it in another manner. In order to provide our full range of services, Source HOV may collect the following types of information:

• 3.2.1

  Personally Identifiable Information (PII). This includes names, postal addresses, email addresses, phone numbers, company information, etc., as provided by Exela' clients and website visitors.

• 3.2.2

  Cookies. When a visitor accesses the Exela website, Exela sends out one or more cookies to the visitor's computer that will identify the visitor's browser. Cookies are small files that are temporarily stored on the visitor's hard drive, enabling the Exela website to recognise the visitor's computer the next time the visitor visits the Exela website. Exela will use cookies exclusively to collect information concerning the use of its website. Cookies contain no personally identifiable data, so the protection of the visitor's privacy is ensured. Depending on the visitor's settings, the Internet browser will automatically accept cookies. However, the visitor may change his/her browser settings at any time and choose to access this website without accepting cookies.

• 3.2.3

  User Communications. When a visitor sends an email or other communication to Exela, Exela may retain those communications in order to process inquires, respond to requests, and improve our overall services.

• 3.2.4

  Affiliated Sites. Exela offers some of its services in connection with other websites. Personal information that a visitor provides to those sites may be sent to Exela in order to deliver the service. Exela processes such information in accordance with this Policy. The affiliated sites may have different privacy practices and policies and Exela  encourages all visitors to read and familiarise themselves with the affiliated company's privacy policies.

• 3.2.4

  Other Sites. This Privacy Policy applies to websites and services that are owned and operated by Exela. Exela does not exercise control over the sites displayed as search results or links from within our various services. Once a visitor has used these links to leave our site, the visitor should note that Exela does not have any control over that other website. Therefore, Exela cannot be responsible for the protection and privacy of any information, which a visitor provides while visiting such sites and such sites are not governed by this privacy statement. These other sites may also place their own cookie or other files on the visitor's computer, collect data or solicit personal information from the visitor.

• 3.3

  Notice and Choice. To the extent permitted by the Safe Harbor Agreement, Exela reserves the right to process personal information in the course of providing professional services to our clients without the knowledge of individuals involved. Where Exela collects personal information directly from individuals in the European Union, Exela will inform them about the types of personal information Exela collects from them, the purposes for which Exela collects and uses such information, and the types of non-agent third parties to which Exela discloses that information. Exela will also inform those individuals about the choices and means, if any, Exela offers individuals for limiting the use or disclosure of their information.

• 3.4

  Disclosure and Transfers. In general, Exela will not disclose any of a visitor's personally identifiable information except when HOV Services has a visitor's permission under special circumstances, such as when Exela believes in good faith that the law requires it or under other circumstances outlined in this Policy. Exela may share information with governmental agencies or other companies assisting Exela.

• 3.4.1

  Exela may share information with governmental agencies or other companies assisting Exela in fraud prevention or investigation. Exela may do so when: (1) permitted or required by law; or, (2) trying to protect against or prevent actual or potential fraud or unauthorised transactions; or, (3) investigating fraud which has already taken place. The information is not provided to these companies for marketing purposes.

• 3.4.2

  Permitted transfers of information, either to third parties or within Exela, include the transfer of data from one jurisdiction to another, including transfers to and from the United States of America. Because privacy laws vary from one jurisdiction to another, personal information may be transferred to a jurisdiction where the laws provide less or different protection than the jurisdiction in which the personal information originated.

• 3.5

  Data Security. Exela takes reasonable steps to protect all personally identifiable information that we handle. To prevent unauthorised access or disclosure, maintain data accuracy, and ensure the appropriate use and confidentiality of personally identifiable information, either for its own purposes or on behalf of our clients, Exela has put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the personal information we possess. However, Exela cannot guarantee the security of personally identifiable information on or transmitted via the Internet.

• 3.6

  Data Integrity. Exela possesses personally identifiable information only in ways compatible with the purpose for which it was collected or subsequently authorised by the individual. To the extent necessary for such purposes, we take reasonable steps to make sure that personal information is accurate, complete, current and otherwise reliable with regard to its intended use.

• 3.7

  Access and Correction. If an individual becomes aware that personally identifiable information Exela maintains about that individual is inaccurate, or if an individual would like to update or review his or her personal information, the individual may contact Exela using the contact information below.

• 3.7.1

  Exela will take reasonable steps to permit individuals to correct, amend, or delete personally identifiable information that is demonstrated to be inaccurate. The individual will need to provide sufficient identifying personal information, such as name, address, birth date, and social security number. Exela may request additional identifying personal information as a security precaution.

• 3.7.2

  Exela may limit or deny access to personally identifiable information where providing such access would be unreasonably burdensome or expensive in the circumstances, or as otherwise permitted by the Safe Harbor Agreement. In some circumstances, Exela may charge a reasonable fee, where warranted, for access to personally identifiable information.

• 3.8

  Enforcement and Dispute Resolution. Exela utilises the self-assessment approach to ensure its compliance with our privacy policy.

• 3.8.1

  Exela periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented, and in conformity with the Safe Harbor Principles.

• 3.8.2

  Exela encourages interested persons to raise any concerns with us using the contact information below. Exela will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Policy.

• 3.8.3

  With respect to any complaints relating to this Policy that cannot be resolved through our internal processes, Exela has agreed to participate in the dispute resolution procedures of the panel established by the European Union Data Protection Authorities to resolve disputes pursuant to the Safe Harbor Principles.

• 3.8.4

  If Exela or the European Union Data Protection Authorities determine that Exela did not comply with this Policy, Exela will take appropriate steps to address any adverse effects and to promote future compliance.

• 3.8.5

  Any person whom Exela determines is in violation of our Privacy Policy will be subject to disciplinary process.

• 3.9

  Sale of Assets, Merger or Acquisition. In the event Exela merges, is acquired by or sells its assets to a third party, Exela may disclose personally identifiable information as is reasonably necessary to affect any such merger, acquisition or sale. Individuals will be afforded the opportunity to opt-out of the Exela offering consistent with our opt-out provisions.

• 3.9.1

  Any such party with whom Exela merges or whom acquires some or all of the assets of Exela may not have the same or similar privacy guidelines as set forth in this Policy and may use personally identifiable information in a manner other than as set forth herein.

• 3.10

  This Policy may be changed from time to time, consistent with the requirements of the Safe Harbor Agreement. Exela will post any revised Policy on its website, or a similar site that replaces that site.

• 3.11

  Certain information is subject to Exela policies that may differ in some respects from the general policies set forth in this statement.

• 3.12

  Information obtained from or relating to clients or former clients is further subject to the terms of any privacy notice to the client, any contract or other agreement with the client, and applicable and enforceable laws.

• 3.13

  Questions and comments regarding this Privacy Policy shall be directed to the Privacy Official of Exela.

• 3.14

  Formal written complaints should be sent to the attention of the Privacy Official at 1305 Stephenson Highway, Troy, Michigan 48083.

• 3.15

  The Privacy Official shall contact all individuals regarding his or her concerns and questions as they may relate to this Privacy Policy.

• 3.16

  Exela will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between Exela and an individual.

• 3.17

  If a complaint is not satisfactorily addressed by Exela within a reasonable time frame, you may contact the Federal Trade Commission at https://www.ftccomplaintassistant.gov/, or via phone at 1.877.382.4317.

• 3.18

  A version of this Privacy Policy shall be available on Exela's public website and at Exela's Corporate headquarters.

4. Definitions

• 4.1

  "Visitor" shall mean any individual or business, which visits the Exela website. This term may have been used synonymously with the term "individual" throughout this Policy.