ALACRA PRIVACY POLICY

Our Commitment to Privacy

Alacra, Inc. ("ALACRA") is committed to protecting your privacy. This policy sets forth the privacy and data protection policy of ALACRA and describes, among other things, how ALACRA collects, uses, handles and discloses personal information.

ALACRA has elected to adhere to the Safe Harbor Privacy Principles and the Frequently Asked Questions (collectively, the "Safe Harbor Principles") established by the United States Department of Commerce in consultation with the European Commission with respect to certain personal information that it receives in the United States from or about European Union ("EU") residents. Information about ALACRA's adherence to the Safe Harbor Principles can be found in the section set forth below entitled "Safe Harbor Participation".

The Information We Collect and Receive

ALACRA Sites ALACRA operates various world wide websites, including, but not limited to, www.alacra.com, www.alacrastore.com, pulse.alacra.com, www.researchrecap.com, www.alacrawiki.com and www.alacrablog.com (the "Site(s)"), which enable individuals to access, purchase and/or download business information and data. When you browse or access an ALACRA Site, ALACRA may collect the following types of information: Information you provide directly, including personal information, when you register or make an online order; inquire about ALACRA products or business development opportunities; request ALACRA sales, support or other services; subscribe to an ALACRA service; elect to receive e-mail, information or other alerts from ALACRA; or send us e-mail messages. For example, as a result of these actions, you might supply us with such information as your name, address, company name, e-mail address, telephone number, credit card information and anything else you choose to include in an e-mail message to our customer service department. Passively collected information, including through the use of "cookies" described below, such as IP addresses, web browser and operating system information, date and time of visits, and the web pages your Internet browser visits when browsing an ALACRA Site; and Aggregate, non personally-identifiable information, such as the number of hits per week or per web page.

The ALACRA Sites are general audience web sites and are not directed to children. It is our intention to adhere to the Children's Online Privacy Protection Act, and ALACRA does not knowingly collect personally identifiable information about children under the age of thirteen (13).

ALACRA Services ALACRA also provides professional services to business clients (the "Services"). Some of these services occasionally require that ALACRA, pursuant to a contract with such business clients, process such clients' data for the purpose of fulfilling the contracted services. The client data processed by ALACRA may include personally identifiable information about a client's customers or other individuals. This information is collected, supplied and/or controlled by ALACRA's business clients, not by ALACRA. ALACRA's business clients, and not ALACRA, are responsible for providing or maintaining the accuracy or completeness of the data or information provided to ALACRA as part of the contract to provide professional Services.

Cookies "Cookies" are small text files that store information about your interactions with a particular website, either temporarily (known as a "temporary" or "session" cookie, and deleted once you close your browser window) or more permanently on the hard drive of your computer (known as a "permanent" or "persistent cookie"). Cookies can make it easier to use a website by allowing servers to access certain information quickly. The Sites may use both session/temporary cookies and persistent/permanent cookies to store information that allows us to offer you better customer service and to navigate through a Site with ease. To make a Site easier to use, we combine information collected via cookies with personally identifiable information. Note that if you configure your browser to reject cookies, you might not be able to access important functions or areas of a Site or enjoy certain conveniences at a Site.

The Way We Use Information

ALACRA Sites ALACRA uses personal information collected online in the following ways: For information you provide online, either directly through our Sites or through e-mail messages, relating to the purchase, download or ordering of products, or requests for support or services, we use the information to engage in and process transactions with you, respond to your inquiries and requests, and provide customer service activities. For information you provide online, including actions or clicks from hyperlinks, we use the information to notify you of relevant new products, to notify you of promotional activities, and to analyze and notify you of products most appropriate for you by customizing future communications and web pages in accordance with communication preferences you have established with ALACRA. For some information you provide online, we use the information for in-house research to improve our understanding of customer needs and product development, build marketing profiles, and aid strategic development. All results of such research and analysis will by anonymized or aggregated and will not reveal any personal information or other personal facts about individual users. For some registration, e-mail and use data you provide, we may direct you to particular web pages, customize the web pages you see, or otherwise increase the relevance of the information you receive. For information about web pages visited, page hits per week, and the like, we use this information internally to improve the design of our web pages. For information submitted using the online job application process, we may use and disseminate this information internally as necessary to consider your application and to contact you regarding our decision.

ALACRA Services Where ALACRA receives data and information, including personal information of individuals, in furtherance of the Services it provides to its business clients, ALACRA processes such data and information solely in accordance with the applicable contract and solely on behalf, and for the benefit, of that business client. ALACRA does not in any manner access or use any information or data, including personal information of individuals, it processes pursuant to such contracts with its business clients as part of its own business.

When We Share Customer Information
ALACRA will not rent, sell or otherwise disclose personal information with other people or companies, except under the following circumstances:

• We may share your personal information for business purposes only on a need-to-know basis and only with: (i) our own employees; (ii) business partners; (iii) ALACRA subcontractors, consultants, and third-party service provider companies that have agreed to safeguard such information in a like manner to the way that ALACRA safeguards such information and that have signed confidentiality agreements with ALACRA; and (iv) other entities authorized to have access to such information under applicable laws or regulations. ALACRA does not share non-public individually identifiable information with third-party marketers;
• We may disclose your personal information in response to judicial or other legal process (including the issuance of a valid subpoena), to protect our rights or property, or to enforce our terms of use and legal notices, as required or permitted by law. We shall have no duty to notify you of such compliance with the law; and
• We may disclose or transfer your personal information in the event ALACRA is acquired by or merges with another company. In this event, ALACRA shall provide notice of any materially different privacy policy, if any, by posting such policy on our Site.

We will not use or share information in ways unrelated to those described above without first notifying you and offering you a choice as to whether or not we may use your data in this different manner.

Our Commitment to Data Security
ALACRA takes reasonable and appropriate measures to maintain the confidentiality and integrity, and prevent the unauthorized use or disclosure, of an individual's personal information. This includes maintaining a system of appropriate administrative, physical and technical safeguards to secure such information.

Links to Unaffiliated Third Party Websites
The Sites may contain links to unaffiliated third party websites. If you link to or otherwise visit any other websites managed by third parties, please review the privacy policies posted at those sites. ALACRA has no control over those websites and is not responsible or liable for the policies and practices followed by third parties.

How You Can Access or Correct Your Information
If you have created an online profile with ALACRA through one of our Sites, you can update or correct your profile or contact information by accessing your account or by contacting ALACRA.

You can also request access to your personal information that we collect online and maintain, and update or correct that information, through e-mailing privacy@alacra.com with the subject line heading of "Privacy Policy Request." To protect your privacy and security, we will take reasonable steps to verify your identity before granting access or making corrections. We may keep information in an off-line form, for archival purposes or as otherwise required by law. Please note that if your information is removed from our databases, you may no longer be able to access certain areas of our Sites. Individuals may request to be removed from an ALACRA e-mail list by following the "unsubscribe" instructions on e-mails from ALACRA or by sending a request to privacy@alacra.com.

Your California Privacy Rights
Beginning January 1, 2005 under California's "Shine the Light" law, California residents who provide personal information in obtaining products or services for personal, family or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g., requests made in 2005 will receive information regarding 2004 sharing activities).

To obtain this information on behalf of ALACRA, please send an e-mail message to privacy@alacra.com with "Request for California Privacy Information" on the subject line and in the body of your message. We will provide the requested information to you at your e-mail address in response, where applicable.

Policy Changes
ALACRA may update this Privacy Policy from time to time, and we reserve the right to change this Privacy Policy without advance notice. Any modifications are effective when they are posted on our Site. The date of the newest version will be posted below. Please check back frequently, especially before you submit any personal information through a Site to see if the Privacy Policy has changed. By using an ALACRA Site, you are indicating that you understand and accept the terms of the Privacy Policy posted at the time of your use.

Contact Information
If you have any questions about ALACRA's privacy policy or information ALACRA may have stored about you, please contact our Chief Privacy Officer, by sending an e-mail message to privacy@alacra.com with the subject line heading of "Privacy Policy Request." Alternatively, you can contact our Chief Privacy Officer at:

Alacra, Inc.
100 Broadway, Suite 1101
New York, New York 10005
United States
Attn: Chief Privacy Officer

Effective Date of Privacy Policy: April 24, 2009.

SAFE HARBOR PARTICIPATION STATEMENT

ALACRA adheres to the Safe Harbor Privacy Principles and the Frequently Asked Questions (collectively, the "Safe Harbor Principles") established by the United States Department of Commerce in consultation with the European Commission. Compliance with the Safe Harbor Principles ensures that personal information shared with ALACRA from the European Union is provided "adequate" protection. Confirmation of ALACRA's "self-certification" and of its adherence to the Safe Harbor Principles can be found at: http://www.export.gov/safeharbor/.

As detailed above, ALACRA operates various world wide websites (the "Site(s)"), which enable individuals to access, purchase and/or download business information and data. When an individual user browses or accesses an ALACRA Site, ALACRA may collect personal information. ALACRA also provides professional services to business clients (the "Services"). For those business clients who engage ALACRA to provide Services, ALACRA may be required, as part of its contractual obligation, to process personal information, including personally-identifiable information, provided to ALACRA by such business clients. In such cases, ALACRA acts merely as a data processor.

The Safe Harbor is based on the following seven Principles:

1.	Notice.
	ALACRA collects, processes, and discloses personal information in the ordinary course of its business.
	(a) ALACRA Sites: When you browse or access an ALACRA Site, ALACRA may collect personal information. Generally, however, you have the choice of whether to provide personal information to ALACRA. If you do, you are prompted only for certain basic or necessary information, such as your name, company name (if applicable(, address, e-mail address, telephone number and credit card information (also if applicable). You will not need to disclose and ALACRA does not collect or use any "sensitive" personal information, such as your social security number, medical or health condition, age, racial or ethnic origin, sex, religion, or political affiliation. ALACRA may also collect information that you choose to include in an e-mail message to our customer service department, your IP address, web browser and operating system information, date and time of visits, the web pages your Internet browser visits when browsing an ALACRA Site, and the number of hits per week or per web page. ALACRA may use the information you provide us for the following purposes: (i) fulfillment and tracking of orders; (ii) providing services and support; (iii) tracking of payments and otherwise ensuring payment; (iv) assessing performance and making assessments about future purchases; (v) performing direct marketing activities; (vi) improving our Sites; and (vii) otherwise communicating information regarding ALACRA products or services (where permitted by law). For information submitted using the online job application process, ALACRA may use and disseminate this information internally as necessary to consider your application and to contact you regarding our decision. ALACRA also may disclose personal information as necessary in connection with the sale or transfer of all or part of its business, where required by law, where ALACRA believes that such disclosures are appropriate in connection with a law enforcement request or otherwise permitted by the Safe Harbor Principles, or in order to investigate, prevent or take action regarding illegal activities or suspected fraud or enforce or apply ALACRA agreements. (b) ALACRA Services: In certain situations, ALACRA may obtain incidental access to information, including personal information, about its business clients' customers and other individuals in connection with professional Services ALACRA provides to business clients. These business clients act as the data controller for such information, including information collected in the EU and subsequently transferred to ALACRA in the United States. ALACRA acts as a data processor on behalf and for the sole benefit of a particular business client and processes such data and information solely in accordance with the applicable contract with that business client. ALACRA does not in any manner access or use any information or data, including personally-identifiable information of individuals, it processes pursuant to such contracts with its business clients as part of its own business. Further, as a data processor for its clients, ALACRA does not inform individuals about the purposes for which their personal information is collected and used by such business clients, but rather relies on its business clients to provide any required notices.
2.	Choice.
(a) ALACRA Sites: When you visit an ALACRA Site, you always have a choice as to whether you wish to provide your personal information to ALACRA. By choosing not to provide your personal information, you can "opt out" of having any such information (i) disclosed by ALACRA to a non-agent third party; or (ii) used by ALACRA for a purpose other than the purpose for which it was originally collected or subsequently authorized by you. Please note, however, that if you choose not to provide certain personal information to ALACRA, you may be prevented from making a purchase or taking advantage of other features and benefits of an ALACRA Site. Also, should ALACRA directly collect Sensitive Personal Information (as defined in the Safe Harbor Principles) from individuals through one of its Sites, to the extent applicable and required by the Safe Harbor Principles, ALACRA will offer individuals the choice to opt-in to having their sensitive personal information (i) disclosed to a non-agent third party; or (ii) used for a purpose other than the purpose for which it was originally collected. (b) ALACRA Services: When ALACRA acts as a data processor for its business clients, ALACRA does not offer individuals a choice regarding the purposes for which their personal information is collected and used by such business clients. ALACRA relies on its business clients to provide and comply with any required options.
3.	Onward Transfer.
	ALACRA may disclose and/or personal information to its employees, business partners, subcontractors, consultants, and third-party service providers. ALACRA shall obtain reasonable assurances from its employees, business partners, subcontractors, consultants, and third-party service providers that they will treat and safeguard any personal information shared with them in a manner consistent with this Statement.
4.	Security.
	Security is extremely important to ALACRA. Accordingly, ALACRA takes reasonable security precautions to protect personal information it collects and processes from loss, misuse and unauthorized access, disclosure, alteration and destruction. ALACRA safeguards information according to established security standards and periodically assesses new technology for improved methods of protecting information.
5.	Data Integrity.
	With regard to the ALACRA Sites, ALACRA takes reasonable measures to verify that personal information it collects is relevant for its intended use, reliable for its intended use, accurate, complete and current. As a data processor for business clients, ALACRA does not typically collect, access or use the personal information provided by its business clients, and ALACRA relies on its business clients to ensure that personal information is relevant for the purposes for which it is used, reliable for its intended use, accurate, complete and current.
6.	Access.
	ALACRA provides individuals from whom it directly collects information through an ALACRA Site the opportunity to access, review and correct their own personal information, and otherwise provides such individuals access to personal information in accordance with the Safe Harbor Principles. Any personal information contained in the Services provided by ALACRA to its business clients as a data processor is under the ownership and control of the particular business client contracting the Service. ALACRA is not authorized to access or change any such personal information, and the burden and expense for ALACRA to identify individuals and provide access for them to correct, amend or delete information would be disproportionate to the risks to the individuals' privacy, and would possibly violate ALACRA's contractual obligations to its business clients.
7.	Enforcement.
	ALACRA will monitor and conduct periodic assessments to verify its adherence to this Statement. ALACRA will investigate suspected infractions and will take all appropriate action. If you have any questions, concerns or complaints regarding ALACRA's collection or processing of personal information pursuant to this Safe Harbor Statement, please contact our Chief Privacy Officer, by sending an e-mail message to privacy@Alacra.com. Alternatively, you can contact our Chief Privacy Officer at: Alacra, Inc. 100 Broadway, Suite 1101 New York, New York 10005 United States Attn: Chief Privacy Officer
	Additional information may be obtained on the U.S. Department of Commerce website at http://www.export.gov/safeharbor/.
	ALACRA will conduct a reasonable investigation of, and will attempt to resolve any complaints in accordance with the principles set forth in this Statement. For complaints that cannot be resolved between ALACRA and complainant, ALACRA agrees to cooperate with the European Union Data Protection Authorities, participate in the dispute resolution procedures of the panel established by the European Data Protection Authorities to resolve disputes pursuant to the Safe Harbor Principles, and comply with advice from such Authorities that ALACRA needs to take specific action to comply with the Safe Harbor Principles. ALACRA also agrees to accept the jurisdiction of the U.S. Federal Trade Commission under Section 5 of the Federal Trade Commission Act.
	ALACRA reserves the right to change this Safe Harbor Statement at any time with or without notice in accordance with the Safe Harbor Principles. Any modified Statement will be posted on ALACRA's Sites for public viewing.

Effective date of this Safe Harbor Statement: April 24, 2009