Overview
ACN Opportunity, LLC and ACN Communications Services, Inc. (collectively “ACN”) are committed to protecting the privacy of our customer information. This document will provide information about ACN's policy relating to the collection, use and disclosure of personal information and of our customer's right to limit such collection, use or disclosure. All personal information relating to our customers is maintained in strict confidence by ACN and is not sold to third parties. For your protection, we utilize a Secure Socket Layer (SSL) on all pages that require you to complete personal information. Our privacy policies and procedures are subject to change.

Identifying Purposes
ACN collects personal information for a variety of purposes related to your request for services from ACN. Personal information is used to verify, process and administer your product and service requests, assess credit-worthiness, maintain our commercial relationship with you, and analyze, understand and respond to your service needs. ACN also analyzes and uses customer information to improve the products that we offer to our customers. We analyze personal information in order to identify the products and services offered by our affiliates or ourselves or by companies that we believe may be of interest to you, and to offer you those products and services.

Personal information is also used in order to communicate with you for billing and provisioning purposes. ACN does not sell, rent or lease personal information to third parties. From time to time ACN may outsource certain account processing, or other customer service functions to a third party. In such cases, personal information will be provided to such third parties. However, ACN releases personal information only where that information will be maintained in confidence.

From time to time ACN is also required report to regulatory bodies or to present a summary of all our customer information, including your personal information, in statistical or analytical form to governmental authorities and industry organizations. When information is provided in statistical or analytical form, information that might specifically identify you will not be disclosed.

Cardholder Data
To receive payment for services prior to initially providing service, or at the time payment is due for an existing service, ACN often requires customers to conduct transactions with a credit or debit card. In order to facilitate future or recurring payments, fees, or other charges for services, ACN may require a customer to provide a credit or debit card to be stored for such future uses. Each customer's credit or debit card has a primary account number (“PAN”), cardholder name, expiration date and/or service code (collectively, “Cardholder Data”). ACN maintains a Payment Card Industry Data Security Standard (“PCI DSS”) compliance program, as well as other credit card controls that are consistent with PCI DSS.

Although ACN applies current industry standards in order to protect Cardholder Data, including PCI DSS, no method of processing, transmission, or storage of Cardholder Data is 100% secure. Therefore, ACN cannot guarantee that its safeguards will prevent every unauthorized attempt to access, obtain, use or disclose Cardholder Data. In the event a customer suspects a security issue regarding Cardholder Data, the customer should immediately contact ACN's Privacy Officer at the address listed at the end of this document.

Collection and Use
ACN will collect and use customer identifiable information for billing purposes, to provide and change service, to anticipate and resolve problems with your service, or to create and inform you of products and services that better meet your needs. This means that ACN may use your customer identifiable information, in conjunction with information available from other sources, to market new services to you that we think will be of interest to you, but we will not disclose your customer identifiable information to third parties who want to market products to you.

Security
ACN has implemented and will update technological and security features to safeguard the privacy of your customer identifiable information from unauthorized access or improper use.

E-mail Contents
The company will not read or disclose to third parties private e-mail communications that are transmitted using ACN services, except as required to operate the service or as otherwise authorized by law. ACN will never request sensitive personal information through email. Do not respond to e-mails requesting credit information, account numbers, passwords or PINs. Call the company to verify the legitimacy of the e-mail.

Disclosure
ACN may also use customer identifiable information to investigate and help prevent potentially unlawful activity or if required by subpoena, search warrant, or other legal process.

Account Information
ACN honors requests from customers to review all customer identifiable information maintained in reasonably retrievable form, and will correct any such information which may be inaccurate. Customers may verify that appropriate corrections have been made.

Children
ACN complies with all Federal laws and regulations, including the Children's Online Privacy Protection Act, which requires the consent of a parent or guardian for the collection of personally identifiable information from children under 13.

Safe Harbor
ACN complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. ACN has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view ACN's certification, please visit http://www.export.gov/safeharbor/. ACN adheres to these Safe Harbor Principles, as outlined below.

Notice and Choice: When ACN collects personal information from customers in the EU or Switzerland, ACN will inform them about the types of personal information it collects from them, the purposes for which ACN collects and uses it, and the types of third parties to the information may be disclosed. ACN will inform the customers about the choices and means that ACN uses of limiting the use or disclosure of such information.

Data Integrity: ACN seeks to ensure that any personal information held about EU and Swiss individuals is accurate, complete, current and otherwise reliable in relation to the purposes for which the information was obtained. ACN collects personal information that is adequate, relevant and not excessive for the purposes for which it is to be processed. EU and Swiss individuals have a responsibility to assist ACN in maintaining accurate, complete and current personal information about them.

Transfers To Third Parties: ACN will only transfer personal information about EU and Swiss individuals to third-parties where the third-party (a) has provided satisfactory assurances to ACN that it will protect the information consistently with this Statement; or (b) is located in the EU, Switzerland, or a country considered "adequate" for privacy by the EU Commission or Switzerland, as applicable; or (c) the third-party has also certified to the applicable Safe Harbor, and is accordingly independently responsible for complying with the Safe Harbor requirements.

Access and Correction: Upon written request to ACN, ACN will provide EU and Swiss individuals with reasonable access to their personal information. Except as may be subject to legal limitation, ACN will make reasonable steps to allow EU and Swiss individuals to review their information for the purposes of correcting their information.

Enforcement: ACN uses the self-assessment approach to maintain compliance with its Privacy Policy. ACN periodically verifies that its policy is accurate, comprehensive for the information covered, displayed appropriately, implemented and in conformity with Safe Harbor Principles. ACN also encourages individuals covered by this Statement to raise any concerns about our processing of their personal information by contacting the ACN Privacy Officer at the address below or the ACN Legal Department. ACN will seek to resolve any concerns. In the event a dispute arises that the parties cannot resolve, the parties may resolve it through arbitration with the American Arbitration Association program developed to assist in the compliance with Safe Harbor. The arbitration shall be held in Concord, North Carolina before a panel of three arbitrators, each side choosing one and then the two choosing the third. All claims hereunder must be brought within two years of the date of which the facts or circumstances giving rise to the claim are alleged to have happened. Laws of the state of New York will apply to the resolution of the dispute unless otherwise agreed in writing.

Limitations: Adherence to this Privacy Policy may be limited to the extent required to meet a legal, governmental, national security or public interest obligation.

Should you have any questions with respect to the ACN Privacy Policy (Safe Harbor) or if you do not consent to, or would like to limit, the manner in which information about you is collected, used or disclosed, please contact the ACN Privacy Officer in writing at ACN Inc., 1000 Progress Place, Concord, N.C. 28025-2449.