Notice of Privacy Policy - Effective 01/01/2006

Introduction
StreetSmart Solutions respects your privacy. We make use of any personal information that you provide to us for the purpose of serving you better. We have created this privacy policy (“Privacy Policy”) to demonstrate our firm commitment to online privacy. This “Notice of Privacy Policy” discloses the information gathering and dissemination practices for StreetSmart Solutions’ websites and our password-protected Internet service platforms which are available primarily to us, our clients, our employees and their families. This Privacy Policy applies to all information that you provide to StreetSmart Solutions and that StreetSmart Solutions maintains electronically, whether you provide the information through what is collectively referred to as “StreetSmart Solutions’ websites” or through other means. Additionally, this Privacy Policy applies to any personal information obtained from your use (and, if applicable, your family’s use) of StreetSmart Solutions’ websites. This Privacy Policy does not apply to any information that you may provide to third parties including Professional Employer Organizations that StreetSmart Solutions represents or other sites linked to StreetSmart Solutions' websites. You should contact such third parties directly to determine their respective privacy policies. As used herein, the terms “StreetSmart Solutions,” “we,” “our” and “its” when referring to StreetSmart Solutions, Inc. and its related companies are used only for convenience and are not intended to be an accurate description of ownership, operation or corporate/legal relationships.

What information does StreetSmart Solutions collect? 
If you are an employee or client of StreetSmart Solutions, we collect and maintain a variety of personal information about you and, if applicable, your company and employees. This information may be collected through our website or through paper forms submitted by you. For employees, the information we maintain includes, among other things:

• your name, your phone number and address (street and e-mail)
• age, marital status and occupation
• information about your job history and employment status
• information about your salary and benefits, including health benefits, your time off, your retirement plans, your social security or taxpayer identification number
• your recruiting and training history
• information about your family members such as their names, addresses and social security numbers

We may make some or all of this information available for your or your worksite employer's use on our website. For clients, examples of this information include:

• your location
• your number of worksite employees
• the gross payroll of worksite employees assigned to your location
• your SIC codes
• information about insurance and other benefit plans

Depending on the use that you make of StreetSmart Solutions’ websites, we may also collect your Internet Protocol (IP) Address (which is the unique address of your computer), information about your interests and preferences, and, if you decide to send us your resume, information included in your resume. From time to time, we may conduct surveys or offer contests or other promotional events, and gather additional personal information from you in connection with those events. StreetSmart Solutions may store and analyze log files from user sessions.

What is this information used for?
We use your personal information in the course of your employment or client relationship with StreetSmart Solutions. Among other things, we use this information to provide you with the services available on our website. For example, we allow you to edit and update personal information online and allow you to download forms that have been pre-populated with your personal information. We also use your information for other things which may include, but are not limited to, the following:

• Contacting You.
  StreetSmart Solutions uses your personally identifiable information to communicate with you in the course of your employment or client relationship. We may also contact you to tell you about products and services provided by StreetSmart Solutions' strategic alliances and other third-party organizations. While we must be able to contact you for matters relating to your employment or your client relationship, if you do not wish to receive email communications from StreetSmart Solutions regarding strategic alliance offers or other third-party products and services, you may opt out of receiving such communications by following the procedure set forth in such e-mail. StreetSmart Solutions will continue to contact you for matters relating to your employment or your client relationship.
   
• Use of IP Address.
  IP addresses are numbers that are automatically assigned to your computer, and, if associated with other individually identifiable information, could be considered personal information. We use your IP address to help diagnose problems with our server and to administer and improve StreetSmart Solutions' websites. Your IP address is also used to help identify you and to gather broad demographic information, some of which we aggregate and then share with our strategic alliances or potential strategic alliances companies. We also use your IP address to keep track of the information you have seen on our sites. 
   
• Use of Cookies.
  Cookies are a standard technology used by commercial web services to store small pieces of information on your hard drive by sending a small string of text to your browser. They make your use of StreetSmart Solutions' websites more pleasing and efficient by “personalizing” your user interface, for example, or identifying which parts of a site you have previously visited. They also enable us to pre-populate, or automatically fill out, forms and schedules. They enable us to tailor the information you receive and to assist third party organizations with whom we have strategic alliances by identifying you as an StreetSmart Solutions client, employee or StreetSmart Solutions website user. Most web browsers automatically accept cookies, unless you have configured yours not to accept them. In order for us to provide you with services on our website, your browser must accept cookies, as they are essential for site administration and security. StreetSmart Solutions does not use cookies either to collect individually identifiable information or to collect non-individually identifiable information using a cookie that is combined with a personal identifier. 
   
• Other General Information.
  StreetSmart Solutions may also collect the name of the domain from which you access the Internet (e.g., aol.com); the date and time you access StreetSmart Solutions' websites; and the Internet address of any website from which you link directly to StreetSmart Solutions' websites; as well as collecting and storing other information in a user’s log file. A user’s log file tells StreetSmart Solutions where a user comes from when entering an StreetSmart Solutions website; which part of the StreetSmart Solutions website the user visits as well as where the user goes when leaving the StreetSmart Solutions website; and how much time the user spends in the StreetSmart Solutions websites. In addition, StreetSmart Solutions may collect e-mail addresses and other personal information from persons who are not current employees or clients of StreetSmart Solutions.
   
• Rewarding Use of StreetSmart Solutions websites.
  StreetSmart Solutions may use information it collects in order to reward or provide incentives to employees, client companies or other StreetSmart Solutions website users for visiting StreetSmart Solutions websites; using services provided on the StreetSmart Solutions websites; or for visiting the websites of StreetSmart Solutions’s strategic alliances.

With whom is this information shared?
StreetSmart Solutions shares personal information only as described below:

• Other StreetSmart Solutions Companies and Third-Party Contractors.
  We may share your information among related companies of StreetSmart Solutions, even if the related company is not a party to your client service or employment agreement. In addition, we may from time to time transfer our database of employee information to third-party contractors who analyze such information on behalf of StreetSmart Solutions for the purpose of, among other things, targeting e-mails to employees regarding strategic alliance offers, or who mail marketing materials to employees regarding strategic alliance offers. Additionally, we may from time to time transfer our database of employee information to a third-party contractor who provides employment verification services on behalf of StreetSmart Solutions. Such third-party contractors are contractually bound to hold all such information in confidence and do not share such information with any parties other than StreetSmart Solutions. 
   
• Your Worksite Employer.
  If you are an employee, most of your personal information is also available to your individual worksite employer. However, StreetSmart Solutions does not provide information regarding your physical and/or mental health to any third party for any purposes, unless compelled by a governmental or legal authority.
   
• Governmental Authorities, Compliance with Law and Protection of StreetSmart Solutions and Others.
  We provide information to governmental authorities when required to do so by law (for example, we report information regarding your compensation and withholding to the U.S. Internal Revenue Service and state taxing authorities). StreetSmart Solutions will also provide personally identifiable information to third parties if compelled to do so by an appropriately empowered governmental or legal authority, or, as necessary, to protect StreetSmart Solutions' rights or the rights of third parties. 
   
• Benefit Plan Providers.
  StreetSmart Solutions will also provide personally identifiable information to its third-party benefit providers in conjunction with the administration of its benefit plans.
   
• Medical Emergencies.
  If necessary to respond to an apparent medical emergency, StreetSmart Solutions may disclose selected employee information.
   
• Strategic Alliances.
  StreetSmart Solutions has entered into marketing agreements, strategic alliances and other relationships with third-party organizations that may offer or provide products and services to you, sometimes under discounted or preferential terms. We sometimes agree to give these third parties (including potential parties to strategic alliances) aggregated, non-personally identifiable information about our clients, employees or visitors. If you initiate an inquiry with respect to a third party’s product or service by clicking on the icon or link relating to such product or service on StreetSmart Solutions' websites, we may furnish such third party with certain personal information regarding you for the purpose of, among other things, pre-populating forms or facilitating the exchange of information between you and the third party. If you do not wish to have any of your personal information furnished to such third-parties, do not access any of the third-party products and services included on StreetSmart Solutions’ websites. 
   
• Business Transfers.
  As StreetSmart Solutions continues to develop its businesses, it may sell various aspects of its business. If StreetSmart Solutions sells a portion of its business, it will transfer personal information associated with that business as part of such a sale. Also, in the unlikely event that StreetSmart Solutions or substantially all of its assets are acquired, personal information regarding employees and clients will be one of the transferred assets.

What access do you have to information you provide?
You have access to much of your personal information through our website, where you can view and update most of the personal information we maintain. 

Security measures
StreetSmart Solutions makes access to your personally identifiable information subject to certain security measures, including technological controls such as "firewalls", in accordance with industry standards. When the use of an StreetSmart Solutions website involves the transmission of confidential information about you or StreetSmart Solutions, we use Secure Socket Layer (SSL) technology to establish a secure connection between your PC and our server. SSL allows the transmission of encrypted information from your PC to our server and back again and is the industry standard for Internet platform security. No data transmission over the Internet can be guaranteed to be 100% secure, so while StreetSmart Solutions strives to protect your personal information, we cannot ensure or warrant the security of any information that you transmit to StreetSmart Solutions.

Disclaimer of responsibility for privacy policy and content at linked sites
StreetSmart Solutions’s websites may provide you with links to other websites. We are not responsible for those sites and cannot control the use of information that you submit once you reach those sites, nor can we control the content of what is offered on those sites or on links from those sites. You should contact such third-party websites directly to determine their privacy policies.

Use of information from third parties
We may use information about you provided to us by third parties (such as credit reporting agencies or strategic alliances) in order to offer you their services and products, to improve our own services, or to evaluate your eligibility for our services. 

This is not a children’s website
StreetSmart Solutions does not knowingly solicit data from children, and we do not knowingly market to children.

Applicable only to U.S. residents
StreetSmart Solutions' websites are designed for and intended only for the use of client companies located in the United States and employees who are U.S. citizens or are residents of the United States If you are a client company that is located outside of the United States, you are not authorized to access StreetSmart Solutions' websites. 

StreetSmart Solutions employees and privacy
StreetSmart Solutions trains all StreetSmart Solutions employees about the importance of privacy. It is StreetSmart Solutions' policy to give access to your information only to those employees who require it to carry out the responsibilities of their jobs.

Changes in these policies and practices
StreetSmart Solutions reserves the right to change its privacy policies and practices periodically, without providing individual notice, by updating this Privacy Policy notice. This Privacy Policy was last updated on January 1, 2006. You agree that it is your responsibility to monitor such updates and that your continued use of StreetSmart Solutions' websites after such revisions have been made constitutes your full acceptance of such revised terms and conditions.

More information
If you have any questions about this Privacy Policy, please write to:

StreetSmart Solutions
357 Marshall Avenue, Suite 104
St. Louis, Missouri 63119
Toll-Free  866.966.9887
Local  314.961.8553
Fax  314.961.5545
Email address: mwilliams@stsmrt.com