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Spheerix Studios respects individual privacy and values the confidence of its customers, employees, vendors, consumers, business partners and others. Spheerix Studios strives to collect, use and disclose Personal information in a manner consistent with the laws of the countries in which it does business, and has a tradition of upholding the highest ethical standards in its business practices. Spheerix Studios abides by the Safe Harbor Principles developed by the U.S. Department of Commerce and the European Commission and the Frequently Asked Questions (FAQs) issued by the Department of Commerce on July 21, 2000. This Safe Harbor Privacy Policy (the "Policy") sets forth the privacy principles that Spheerix Studios follows with respect to transfers of Personal information anywhere in the world, including transfers from the European Economic Area (EEA) (which includes the twenty-five member states of the European Union (EU) plus Iceland, Liechtenstein and Norway) to the United States.

I. INFORMATION SECURITY IS KEY

Spheerix Studios staff assists in ensuring compliance with this Policy and data security issues. Spheerix Studios educates its employees concerning compliance with this Policy and has self-assessment procedures in place to assure compliance. Spheerix Studio’s relevant contact information is provided online via the contact page.

II. SCOPE

This Policy applies to all Personal information received by Spheerix Studios in any format including electronic, paper or verbal. Spheerix Studios collects and processes Personal information concerning current and former employees and their respective family members, as well as applicants for employment through its Internet websites, its intranet site, electronic mail and manually. Spheerix Studios is the sole owner of information it collects from current and former employees, applicants for employment, customers, vendors, and others. Spheerix Studios will not sell or share this information with third parties in ways different from what is disclosed in this Privacy Policy. On a global basis, Spheerix Studios will, and will cause its affiliates to, establish and maintain business procedures that are consistent with this Policy.

Personal information collected by Spheerix Studios from employees and applicants for employment is maintained at its offices in Norman, OK in the United States as well as the satellite office of the employee or applicant. Spheerix Studios collects Personal information for, among other things, legitimate human resource business reasons such as payroll administration; filling employment positions; administration and operations of its benefit programs; meeting governmental reporting requirements; security, health and safety management; performance management; company network access; and authentication. Spheerix Studios does not request or gather information regarding political opinions, religion, philosophy, or sexual preference. To the extent, Spheerix Studios maintains information on an individual's medical health or ethnicity (as legally required); Spheerix Studios will protect, secure, and use that information in a manner consistent with this Policy and applicable law.

Personal information collected by Spheerix Studios from prospective customers, consumers, vendors, business partners and others may be maintained at its office in Norman, OK or at other Spheerix Studios facilities. Spheerix Studios collects Personal information for, among other things, legitimate business reasons such as customer service; product, warranty and claims administration; meeting governmental reporting and records requirements; maintenance of accurate accounts payable and receivable records; internal marketing research; safety and performance management; financial and sales data; and contact information. All Personal information collected by Spheerix Studios will be used for legitimate business purposes consistent with this Policy.

III. DEFINITIONS

For purposes of this Policy, the following definitions shall apply:

"Agent" means any third party that uses Personal information provided by Spheerix Studios to perform tasks on behalf of or at the instruction of Club Spheerix, LLC.

"Spheerix Studios" means Club Spheerix, LLC, its predecessors, successors, subsidiaries, divisions, and groups.

"Personal information" means any information or set of information that identifies or could be used by or on behalf of Spheerix Studios to identify an individual. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public Personal information.

"Sensitive Personal information" means Personal information that reveals race, ethnic origin, trade union membership, or that concerns health. In addition, Spheerix Studios will treat as sensitive Personal information any information received from a third party where that third party treats and identifies the information as sensitive.

IV. PRIVACY PRINCIPLES

The privacy principles in this Policy are based on the seven Safe Harbor Principles.

(1) NOTICE: Where Spheerix Studios collects Personal information directly from individuals, it will inform them about the purposes for which it collects and uses Personal information about them, the types of non-agent third parties to which Spheerix Studios discloses that information, and the choices and means, if any, Spheerix Studios offers individuals for limiting the use and disclosure of their Personal information.Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal information to Spheerix Studios, or as soon as practicable thereafter, and in any event before Spheerix Studios uses the information for a purpose other than that for which it was originally collected.Spheerix Studios may disclose Personal information if required to do so by law or to protect and defend the rights or property of Spheerix Studios.

(2) CHOICE: Spheerix Studios will offer individuals the opportunity to choose (opt-out) whether their Personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

For sensitive Personal information, Spheerix Studios will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

Spheerix Studios will provide individuals with reasonable mechanisms to exercise their choices should requisite circumstances arise.

(3) DATA INTEGRITY: Spheerix Studios will use Personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Spheerix Studios will take reasonable steps to ensure that Personal information is relevant to its intended use, accurate, complete, and current.

(4) TRANSFERS TO AGENTS: Spheerix Studios will obtain assurances from its Agents that they will safeguard Personal information consistently with this Policy. Examples of appropriate assurances that may be provided by Agents include: a contract obligating the Agent to provide at least the same level of protection as is required by the relevant Safe Harbor Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), Safe Harbor certification by the Agent, or being subject to another European Commission adequacy finding (e.g., companies located in Switzerland). Where Spheerix Studios has knowledge that an Agent is using or disclosing Personal information in a manner contrary to this Policy, Spheerix Studios will take reasonable steps to prevent or stop the use or disclosure. Spheerix Studios holds it Agents accountable for maintaining the trust our employees and customers place in the company.

(5) ACCESS AND CORRECTION: Upon request, Spheerix Studios will grant individuals reasonable access to Personal information that it holds about them. In addition, Spheerix Studios will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. Any employees that desire to review or update their Personal information can do so by contacting their local Human Resources Representative.

(6) SECURITY: Spheerix Studios will take reasonable precautions to protect Personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. Spheerix Studios protects data in many ways. Physical security is designed to prevent unauthorized access to database equipment and hard copies of sensitive Personal information. Electronic security measures continuously monitor access to our servers and provide protection from hacking or other unauthorized access from remote locations. This protection includes the use of firewalls, restricted access, and encryption technology. Spheerix Studios limits access to Personal information and data to those persons in Spheerix Studios's organization, or as agents of Spheerix Studios, that have a specific business purpose for maintaining and processing such Personal information and data. Individuals who have been granted access to Personal information are aware of their responsibilities to protect the security, confidentiality, and integrity of that information and have been provided training and instruction on how to do so.

(7) ENFORCEMENT: Spheerix Studios will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy and the US Department of Commerce Safe Harbor Principles. Any employee that Spheerix Studios determines is in violation of this Policy will be subject to disciplinary action up to and including termination of employment.

V. DISPUTE RESOLUTION

Any questions or concerns regarding the use or disclosure of Personal information should be directed to Club Spheerix, LLC via the contact page online. Spheerix Studios will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal information in accordance with the principles contained in this Policy. For complaints that cannot be resolved between Spheerix Studios and the complainant, Spheerix Studios has agreed to participate in the dispute resolution procedures of a panel established by Spheerix Studios resolution representatives to resolve disputes.

VI. INTERNET PRIVACY

Spheerix Studios sees the Internet, intranets and the use of other technologies as valuable tools for communicating and interacting with consumers, employees, vendors, business partners, and others. Spheerix Studios recognizes the importance of maintaining the privacy of Personal information collected through websites that it operates. Spheerix Studios's sole purpose for operating its websites is to provide information concerning products and services to the public. In general, visitors can reach Spheerix Studios on the Web without revealing any Personal information. Visitors on the Web may elect to voluntarily provide Personal information via Spheerix Studios websites but are not required to do so. Spheerix Studios collects information from visitors to the websites who voluntarily provide Personal information by filling out and submitting online questionnaires concerning feedback on the website, requesting information on products or services, or seeking employment. The Personal information voluntarily provided by website users is contact information limited to the user's name, home and/or business address, phone numbers and email address. Spheerix Studios collects this information so it may answer questions and forward requested information. Spheerix Studios does not sell or share this information with non-agent third parties.

Spheerix Studios may also collect anonymous information concerning website users through the use of "cookies" in order to provide better customer service. "Cookies" are small files that websites place on users' computers to identify the user and enhance the website experience. None of this information is reviewed at an individual level. Visitors may set their browsers to provide notice before they receive a cookie, giving the opportunity to decide whether to accept the cookie. Visitors can also set their browsers to turn off cookies. If visitors do so, however, some areas of Spheerix Studios websites may not function properly.

Few, if any, of Spheerix Studios's websites are directed toward children. Nevertheless, Spheerix Studios is committed to complying with applicable laws and requirements, such as the United States' Children's Online Privacy Protection Act ("COPPA").

All inquiries should include the individual's name, address, and other relevant contact information (phone number, email address). Spheerix Studios will use all reasonable efforts to honor such requests as quickly as possible.

Spheerix Studios websites may contain links to other "non-Spheerix Studios" websites. Spheerix Studios assumes no responsibility for the content or the privacy policies and practices on those websites. Spheerix Studios encourages all users to read the privacy statements of those sites; their privacy practices may differ from those of Spheerix Studios.

VII. CHANGES TO THIS PRIVACY POLICY

The practices described in this Policy are current Personal data protection policies as of October 25, 2006. Spheerix Studios reserves the right to modify or amend this Policy at any time consistent with the necessary requirement.