Privacy Policy

The following statement describes the privacy practices for TEDS Inc. (“TEDS”). This statement is
divided into four sections: (1) this introduction, (2) TEDS.com’s Online Privacy Policy, which addresses
the privacy practices applicable to usage of the TEDS.com website, (3) TEDS Inc. ASP Privacy Policy,
which addresses the privacy practices applicable to information processed by TEDS in its role as an
Application Services Provider (“ASP”) and (4) TEDS, Inc. General Privacy Provisions, which apply to
both the TEDS.com website and TEDS role as an ASP.
TEDS respects individual privacy and strives to collect and use personal information in a manner
consistent with the laws of the countries in which it does business. TEDS abides by the Safe Harbor
Principles developed by the U.S. Department of Commerce and the European Commission. More
information about the U.S. Department of Commerce’s Safe Harbor program can be found at www.export.gov/safeharbor.

TEDS, Inc. Online Privacy Policy
This Online Privacy Policy covers use of the site www.TEDS.com. All information disclosed by visitors
is subject to this Privacy Policy. With respect to data received through its websites, TEDS.com will
comply with the following:

Types and Uses of Information

TEDS.com gathers personal information from site visitors from time to time in order to better understand your needs and how we can improve and enhance our products and services; and we may use that information to contact you and send offers and other information to you. This may include contact information such as name, email address, telephone number, and company name, and perhaps other data.
TEDS.com also may monitor customer traffic patterns and site usage to help refine and improve the
design and layout of the website as well as the user experience. As a result, TEDS.com automatically
tracks certain information about site visitors. This information includes the users’ browser type, URLs
visited and visitors’ IP addresses. TEDS.com uses this information to, among other things; identify broad demographic trends that may be used to provide information tailored to users’ interests.
Any personal information given to us through our website is used exclusively by TEDS.com unless
otherwise noted on the site. We do not now and do not intend to sell or rent personal data about you to
third parties. By using the Site, you consent to our collection and use of your information as described in this privacy policy. If we change our privacy policies and procedures, we will post the revised policies on the Site to keep you aware of what information we collect, how we use it and under what circumstances we may disclose it. We encourage you to review this section each time you visit the Site to check for any updates or changes. Any changes shall be effective when posted to the Site.

Cookies
TEDS.com may use both per-session and persistent cookies to enhance the user experience while visiting the TEDS.com website. Cookies are small bits of data stored locally by a browser that saves information and helps the hosting website identify the user upon subsequent visits. Cookies are uniquely assigned to the users’ computer and may only be read by a web server located within the domain that originally issued the cookie. Cookies generally assist users by performing certain functions such as saving passwords and personal preferences regarding the sites.
Persistent cookies are stored for a set length of time determined by the web server when it passes the cookie on to the browser. Persistent cookies are used to store information between visits to a site.
Per-session cookies are used to store information only within a session. These cookies are cached only while a user is visiting the web server that issues the per-session cookie. Per-session cookies are deleted from the cache when the user closes the session.
Users may have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but users can typically modify browser settings to decline all cookies. Alternatively, users may modify browser settings to provide notification each time a cookie is tendered, permitting the user to accept or decline cookies on an individual basis. If a user chooses to decline cookies, however, it may hinder performance and negatively impact the user experience on TEDS.com’s website.

Disclosure to TEDS, Inc. partners
TEDS.com does not provide detailed information about individual site visits, nor the information users provide, to outside companies without users’ permission. TEDS may share aggregated information about the use of this site to companies with which TEDS has business relationships. TEDS provides this data so that partners can better understand how people use their content and the TEDS.com site, with the goal of providing the best possible web experience.

TEDS, Inc. ASP Privacy Policy
TEDS is an Application Service Provider (“ASP”). As an ASP, TEDS offers its customers a totally
integrated Talent Management software package consisting of; Learning, Competencies, Performance, Workforce, Recruiting, Staffing, Succession and Compensation Management. TEDS serves as a data center for the customers who use TEDS’ products. Customers of TEDS hosted Talent Management solutions fill the role of data controller. TEDS maintains only that information which its customers have asked it to house. This ASP Privacy Policy does not reflect the privacy practices of TEDS customers, and TEDS is not responsible for its customers’ privacy policies or practices. TEDS does not review, comment upon or monitor its customers’ compliance with their respective privacy policies, nor does TEDS review its customer instructions to determine whether they are in compliance with or conflict with the terms of a customer's published privacy policy.
This ASP Privacy Policy applies only to the transfer of personally identifiable information (“Personal
Information”) received by TEDS in any format through its hosted solutions, whether supplied directly by
TEDS customers or by employees or users of the hosted solutions anywhere in the world, including
transfers from the European Union to the United States. With respect to data received through its hosted solutions, TEDS will comply with the following:

Notice/Use of Personal Information
TEDS supports a hosted system, where it collects Personal Information including but not limited to
customers’ organizational data (salary and compensation figures and structures, job descriptions, job codes, reporting relationships), employee data (specific identifying information such as name,
email/physical address, current base salary, performance ratings, gender, ethnicity and other
demographical information). TEDS operates as a data processor for its customers. TEDS maintains only the Personal Information which its customers have asked TEDS to process. It is the responsibility of the customer to ensure that the data the customer collects and later gives to TEDS can be legally collected and disclosed in the country of origin. The TEDS customer is responsible for giving its employees and users the appropriate level of notification that Personal Information is being collected and maintained.
The TEDS customer also is responsible for ensuring the security of any method used by the customer to provide Personal Information to TEDS if through means other than the hosted solution.

TEDS, Inc. General Privacy Provisions
These General Privacy Provisions apply to both TEDS.com’s website and its hosted solutions
applications. All information disclosed by site visitors, customers and other individuals or organizations is subject to these provisions. With respect to data received through TEDS.com’s website and its hosted solutions, TEDS will comply with the following:

Data Integrity and Access to Data
TEDS will take reasonable steps to ensure that Personal Information is accurate, complete and current to its intended use. TEDS will only use Personal Information in ways that are compatible for the purposes for which it was collected or subsequently authorized by the user.
TEDS provides users with reasonable access to Personal Information that they provide to us as well as the ability to review and correct such information. In addition, to protect users’ privacy and security, TEDS takes reasonable steps to verify user identity before granting access to Personal Information. TEDS may limit or deny access to Personal Information where providing such access would be unreasonably burdensome or expensive in the circumstances.

Security
To prevent unauthorized access or disclosure, to maintain data accuracy, to allow only the appropriate exercise of users’ Personal Information while also protecting the confidentiality, integrity and availability of users’ Personal Information, TEDS employs a variety of industry standard security technologies. Security is provided on the data, application and hosting level. The security infrastructure includes a physically secure data center, proven firewall protection, intrusion detection/prevention measures, SSL encryption of all data in transit, role based authorization and additional proprietary security measures.
Communication to TEDS’ servers from a client computer is achieved through an SSL connection. This ensures data, including Personal Information, is encrypted when transferred over the Internet. TEDS provides further user-based security configured specifically for the individual client’s needs. For example, as a Learning on Demand Administrator, the client will be able to specify levels of user security, including: domain-limited access (access only from the client’s proxy server), password configuration (length, letters, numbers, etc.) and automatic password expiration.
TEDS limits access to users’ Personal Information and data to those persons who have a specific business purpose for maintaining and processing such information. TEDS’ employees who have access to users’ Personal Information will be made aware of their responsibilities to protect the confidentiality, integrity and availabilit of that information and have been provided training and instruction on how to do so. This information is covered in our employee signed confidentiality agreement.

Enforcement
TEDS has a Privacy Officer who is responsible for TEDS compliance with and enforcement of this
Policy. TEDS Privacy Officer is available to any of its employees, customers, vendors, business partners or others who may have questions concerning this Policy or data security policies. TEDS Privacy Officer may be contacted by email at privacy@teds.com or by mail at TEDS, Inc. PO Box 700, Atkins Virginia 24311. If users have questions or concerns regarding this policy, they should contact TEDS Privacy Officer before filing any formal complaints with the Better Business Bureau or any other applicable organizations.

Safe Harbor

TEDS adheres to the Safe Harbor privacy framework developed by the U.S. Department of Commerce in consultation with the European Commission’s Directive on Data Protection on the transfer of Personal Information from European Union member countries to the United States. The Safe Harbor privacy principles are notice, choice, onward transfer, access, security, data integrity and enforcement. More information about the U.S. Department of Commerce’s Safe Harbor program can be found at www.export.gov/safeharbor.

Notification of Privacy Policy Changes/Choice

TEDS reserves the right to change, modify, add, or remove portions of this Policy at any time. All
changes will be posted on this page to inform our users what information we collect, how we use it, and under what circumstances, if any, we may disclose it.

Legal Disclaimer

TEDS may disclose Personal Information when required by law or in the good faith belief that such
action is necessary in order to conform to the edicts of the law, comply with legal mandates, enforce the terms of use of TEDS.com’s website, enforce agreement between TEDS and its customers or to protect the rights, property, or personal safety of TEDS, its users and the public.

Contacting TEDS.com

If you have any questions about this privacy policy, the practices of this site, or your dealings with this site, please send correspondence to the following address.

Privacy Policy
TEDS, Inc.
PO Box 700
Atkins, VA 24311
support@teds.com
Update effective June 5, 2006

The TEDS, Inc. Customer Privacy Policy is subject to change at any time. We encourage you to review the privacy policy regularly for any changes.

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