Effective Date: (06-24-2014)

GO TO GLENCORELEGAL.COM FOR UPDATES AND ADDENDUMS

GLENCORE PRIVACY POLICY:

Glencore is the leading provider of business and consumer information products, database marketing services, data processing services and sales and marketing solutions, including, but not limited to email marketing and social media marketing.  Content is the essential ingredient in every marketing program, and Glencore has the most comprehensive and cleanest data in the industry, and is the only company to own a proprietary database of U.S. consumers U.S. businesses, including International feeds and data for consumers and businesses outside the United States. The Glencore database powers the directory services of the top Internet traffic-generating sites. Our customers use Glencore’s products and services to find new customers, grow their sales, and for other direct telemarketing, customer analysis and credit reference purposes.

Glencore recognizes the privacy interests of the businesses and consumers on which it collects information and has implemented the most comprehensive and formal data protection policies which balance privacy expectations with the legitimate business need of our customers.

As a global leader in helping clients manage and disseminate consumer information, Glencore has understood the importance of fair information practices and consumer privacy. Glencore helps clients improve relationships with consumers by making individual recognition possible across the entire enterprise spectrum, including over the Internet, over the phone, through email, and in retail outlets. The growth of e-commerce and remote transactions means a company’s ability to know its audience also involves honoring individual preferences regarding privacy and security. Today, marketers are required by good corporate citizenship practices, and in some cases by legislation, to put procedures in place that enable individuals to control how, when and for what reasons companies communicate with them. Glencore’s proprietary intelligence tools and advanced encryption methods ensure security.

These procedures also enable individuals to control how companies share data about them with others. With customer data often stored in different systems across a company and with potentially different spellings of names and addresses, it is difficult for most companies to establish or honor their commitments to consumers about how data about them will be used. Glencore is at the forefront of consolidating and managing the world’s largest databases.

Glencore provides the critical services, products and technology that companies need to honor customer preferences and maintain good customer relationships. Glencore and its associates, subsidiaries, and partners worldwide pledge to conduct our business according to the following:

Security:
Glencore uses encrypted security systems and procedures to safeguard and protect the information, ensuring the data is accessed only by authorized individuals for legitimate business needs. Glencore will not transmit or sell the compiled information to third parties without obtaining a written or electronic agreement that defines the rights and responsibilities with respect to the data. Furthermore, Glencore will review our customers use of the data to ensure sensitive data is being handled in accordance with required protections, and that this information is not used for deceptive, misleading, distasteful, or suspicious purposes. Our data will not be made available to any unauthorized person(s) and or businesses.

Notice:
Glencore recognizes that individuals should be informed as to how information about them is used and should have choices about the dissemination of that information.

Compliance:
Glencore is an active member of local trade associations in the countries where we conduct business and conforms to all self-regulatory guidelines of these associations. Glencore also actively monitors local laws in order to be compliant with any regulatory requirement. Glencore complies with all applicable federal and state laws concerning data privacy, as well as best practices and procedures and guidelines established by industry groups of which the company is a contributing member, including the Direct Marketing Association (DMA) and others.  Glencore maintains agreements with its customers containing strict controls on the data as required by the applicable laws and industry standards. The company also encourages its customers that are not members of the DMA or other applicable industry groups to comply with the standards and guidelines established by those groups.

Accuracy:
Glencore maintains the strictest quality control procedures to ensure our information is as accurate as possible. Our clean data process and HyClean method is licensed to Global Government agencies throughout the world, including every country in the Western Hemisphere except Cuba.

Consumer and Business Value:
Glencore offers services and information products that create and build value — including lower prices, greater access, better security, timeliness and diversity – for consumers and businesses around the world.

Ethics:
Glencore pledges to conduct our relationships with clients and other information providers in an ethical and professional manner. We have been instrumental in developing and shaping how laws are written here in the U.S. and globally to always protect the information we are able to gather.

Awareness:
Glencore is committed to educating our clients, our associates and the industry about the issues, guidelines and laws surrounding individual consumer privacy issues.

Consumer and Business Value:
Glencore offers services and information products that create and build value — including lower prices, greater access, better security, timeliness and diversity – for consumers and businesses around the world.

Privacy Scope:
Glencore respects the right of individuals to privacy. Our privacy policy functions to explain how we collect, use and safeguard personal data, as well as the choices individuals can make about the way their personal data is collected and used. Glencore provides data products and services, containing personal data, to our clients. When we do so, we pledge to follow practices described in this privacy policy in relation to such personal data.

“Glencore” is defined as the Glencore, “personal data” as data that identifies living individuals, “business prospect” as a business in contact with but does not have an established relationship with Glencore (or representative of a business) and the term “business client” as a business with which Glencore does have an established relationship (or representative of a business).

Information Collection and Hygiene:
Glencore collects personal data, such as name, addresses, emails, telephone numbers, transactional data, lifestyle and demographic data both online and offline through questionnaires, promotions, our partners, public sources, commercially available databases and our websites. Personal data may be kept in its identifiable form, or in an aggregated meta form (so that individuals cannot be identified), for the purposes listed below.

We may collect personal data online from individuals via our questionnaire websites and from prospects and clients to help us efficiently perform various business transactions. Personal data may be sought when requesting information from Glencore, registering for a free trial or demonstration of certain products and services, signing up or subscribe to products and services, or participating in a special offer, contest, or lottery. We may also use cookies to identify repeat visitors, and to collect statistical data that enable us to make our sites more user-friendly and secure the information Glencore gathers.

Information Disclosures and Uses:

Glencore, the Glencore group of companies, and our partners and business clients (where permitted by Glencore and its subsidiaries) may use this personal data:

·         to undertake research and analysis,

·         to market their products and services,

·         for product development and testing,

·         for identity validation and fraud reduction,

·         support client relationship,

·         for work planning, management and strategic decision making, and

·         for data hygiene, data integration, update and validation of files.

All personal data that Glencore collects are used in accordance with the Data Protection Act 1998. When personal data is collected from people who voluntarily complete our questionnaires, the personal data are also used in accordance with the use and disclosure statements on the questionnaires.

Personal data used in Glencore’s data products and services may be passed to and used by members of the Glencore group of companies worldwide, after obtaining appropriate permissions where applicable and allowed. We will only pass personal data outside this group to our contracted suppliers that process personal data on our behalf and to our clients and their subcontractors or subsidiaries. When we do so, we ensure that appropriate contractual safeguards are put in place and that appropriate encryption. These parties may be located in the United States or abroad. Glencore may also disclose personal data as required by law and to comply with legal process.

Data Subjects’ Rights:
Individuals may access or correct their personal data, or withdraw their consent at any time by contacting us or by refusing technologies such as cookies. This must be done by the individual themselves and we may require proof of the individual requesting access for identification and other personal details authenticating verification.

Contact Us:
Individuals wishing to inquire about our policies, to access or correct their personal data, or withdraw consent should contact Glencore by faxing to 267.618.9460.

Other Important Information:

Compliance:
Glencore has notified its processing activities with the Information Commissioner We have implemented measures designed to ensure compliance with the Data Protection Act 1998, the Telecommunications Act 2003 and other applicable legislation as amended from time to time.

Cookies:
At all sites owned by Glencore where technologies such as “cookies” are used, web-browsers can be set to notify individuals when a cookie is received. This will give individuals the chance to choose whether to accept it or not.

Cookies and other data collection technologies:
We use cookies and other data collection technologies on our site to:

·help you navigate our website

·facilitate the sign up and login process for our services

·personalize your experience

·analyze which pages our site visitors visit

·provide website feature such as social sharing widgets and videos

·measure advertising and promotional effectiveness

·accesses which areas of our site you visit to remarket to you after you leave our site

Glencore uses cookies with our online behavioral advertising notice and choice programs opt-out tools to assist with your opt-out choices and to help us measure usage. Our opt-out tool prevents the use of your browsing behavior by companies that may provide interest-based advertising to you by setting their opt-out cookie in your browser.  If you clear your browser cookies, this will remove all cookies including the opt-out cookies set by the companies. You will need to re-access the opt-out tool to reset your preferences. Our cookie only knows your last set of preferences and does not reflect the current state of cookies on your browser.

We work with a third party to track your activities on our web site to improve our marketing efforts and provide you advertising based on your visit.

Please note that some cookies may be placed by a third party service provider who performs some of these functions for us.

Information Automatically Collected By Our Site:
As is true of most Websites, we gather Web server log file information automatically such as your IP address, browser type, referring/exit pages, and operating system. We use this information to administer our website, understand how visitors navigate through our Site and to enhance your experience while using our Site.

Other Web Sites:
Glencore’s web site may contain links to other web sites which are outside our control and are not covered by this privacy policy. If individuals access other sites using these links, the operators of these sites may collect personal data for their own use from individuals in accordance with their own privacy policy, which may differ from ours. Be sure to educate yourself of any other company’s privacy policy.

Transfer of Data Assets:
As Glencore develops its business, there may be a change of control of Glencore or divisions, subsidiaries, affiliates or portions of Glencore. In this situation, personal data is typically considered a transferable asset. Also, in the event that Glencore or a part of its divisions, affiliates or subsidiaries are purchased, personal data will be one of the transferred assets.

Changes To Our Privacy Policy:
Glencore reserves the right to update and revise this privacy policy from time to time to take into account legislative and other developments. Any changes we may make to our privacy policy will be posted on this page and contain an “effective date” reflecting when the last changes occurred. Additional changes and updates will be made available to you at glencorelegal.com.

Privacy Statement Regarding Customer and Online User Information:
The Privacy Statement Regarding Customer and Online User Information applies to Glencore and its worldwide corporate affiliates (we or our), but not to those Glencore corporate affiliates that have published their own privacy and security statements. This privacy statement also does not apply to the websites of our business partners or to any other third parties, even if their websites are linked to our website. We recommend you review the privacy statements of the other parties with whom you interact.

This privacy statement governs personal information we collect from our customers and online from our website users (you), through Glencore products, services, software, websites, contacts or our relationship with you.

For the purposes of this privacy statement, corporate affiliates means any entity or joint venture that is wholly or partially owned or controlled by Glencore Business partners means any subcontractor, vendor or other entity with whom we have an ongoing business relationship to provide products, services or information. Personal information means information that identifies you, such as your name, telephone number and email address.

Information We Collect:
We may ask you to provide personal information when you:

• Use our website;

• Request quotes, services, support or information;

• Place orders for products or services;

• Apply for credit card or financing;

• Participate in surveys, sweepstakes or other promotional activities;

• Subscribe to newsletters, promotional emails or other materials;

• Apply for a job, submit your resume/CV or create a candidate profile; or

• Contact us

Information we may request includes your email address, name, home address and telephone number. If you make a purchase, we may ask for your credit card number and billing information. We may also ask for your Social Security number and other data to process your credit or financing request. Job applicants may be requested to provide information such as educational background, employment experience and job interest. We may also collect demographic information, such as your business or company information, age, gender, interests, preferences and favorites. Forms that you may fill in will indicate whether information requested is mandatory or voluntary.

We may collect information about your visits to our websites, including the pages you view, the links and ads you click, search terms you enter, and other actions you take in connection with the Glencore websites and services. We may also collect certain information from the browser you used to come to our website, such as your Internet Protocol (IP) address, browser type and language, access times, the Uniform Resource Locator (URL) of the website that referred you to our website and to which URL you browse away from our site if you click on a link on our site.

In order to offer you a more consistent and personalized experience in your interactions with Glencore, information collected through one source may be combined with information obtained through other Glencore resources. We may also supplement the information we collect with information obtained from other parties.

Some Glencore services may be co-branded and offered in conjunction with another company. If you register for or use such services, both Glencore and the other company may receive information collected in conjunction with the co-branded services, and may use the information according to each companys privacy statement and other agreements with you.

How We Use Personal Information:

·Deliver the services and support, or carry out, the transactions you have requested;

·Send communications to you, such as product safety information, your transactions status (for example, order confirmations), information about products and services available from Glencore and its corporate affiliates, promotional offers and surveys;

·Customize, analyze and improve our products, services (including the content and advertisements on our website), technologies, communications and relationship with you;

·Enforce our conditions of sale, website terms and/or separate contracts (if applicable) with you;

·Prevent fraud and other prohibited or illegal activities;

·Protect the security or integrity of the website, our business, or our products or services; or

·Otherwise, as disclosed to you at the point of collection.

Personal information collected may be stored and processed in the United States or any other country in which Glencore or its corporate affiliates, subsidiaries or agents maintain facilities, and by using Glencore products and services (including our website), you consent to any such transfer of information outside of your country.