Safe Harbor Policy

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Kaizen Life Group 

Safe Harbor Policy 

Kaizen Life Group (We) respect your privacy and are committed to protecting it through our compliance with this safe harbor policy. This policy describes the privacy principles we follow with respect to transfers of personal data from the European Economic Area (EEA) [and from Switzerland] to the United States. It sets out our practices for collecting, using, maintaining, protecting and disclosing that personal data.

1. SAFE HARBOR PRIVACY STATEMENT 

1.1 We will process personal data that is transferred to us from the EEA in accordance with the safe harbor principles agreed between the United States Department of Commerce and the European Commission (Safe Harbor Principles). These principles enable US companies to satisfy the EU requirement set out in the EU Data Protection Directive that personal data transferred from the EEA to the United States be adequately protected.

1.2 Kaizen Life Group’s safe harbor certification can be found at www.team-kaizen.com/safe_harbor_certification. Additional information about the safe harbor program and the Safe Harbor Principles is available at http://www.export.gov/safeharbor.

2. CHANGES TO OUR SAFE HARBOR POLICY 

2.1 It is our policy to post any changes we make to our safe harbor policy on this website. If we make material changes to how we treat the personal data that falls within the scope of our safe harbor policy, we will notify you by e-mail to the primary e-mail address specified in your account and/or through a notice on Kaizen Life Group’s website home page.

2.2 The date the safe harbor policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date, active and deliverable e-mail address for you, and for periodically visiting our website and this safe harbor policy to check for any changes. 2

3. DEFINITIONS 

3.1 Data Protection Directive: EU Directive 95/46/EC on the protection of individuals with regard to the processing of personal data and on the free movement of such data.

3.2 Agent: any third-party data processor that processes personal data provided by Kaizen Life Group on its behalf and under its instructions.

3.3 Personal Data: any information or set of information that identifies or could be used to identify (together with other information) a living individual. Personal data does not include information that is anonymised or aggregated.

3.4 Sensitive Personal Data: any Personal Data that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, information that concerns health or sex life, and information about criminal or administrative proceedings and sanctions.

4. NOTICE 

4.1 If we collect Personal Data directly from individuals in the EU, we will inform them about the purposes for which we intend to process that Personal Data, the types of non-agent third parties, if any, to which we will disclose that Personal Data, and the choices and means, if any, that we offer individuals for limiting the use and disclosure of their Personal Data.

4.2 We will provide notice to individuals in clear and conspicuous language when individuals are first asked to provide Personal Data to us, or as soon as practicable thereafter. In any event, we will provide notice before we use the Personal Data for a purpose other than that for which it was originally collected.

4.3 If we receive Personal Data from our subsidiaries, affiliates or other entities in the EEA, we will use that information in accordance with the notices those entities provided to the individuals to whom that Personal Data relates and the choices made by those individuals.

5. CHOICE 

5.1 We will provide individuals with the opportunity to opt out of any disclosure of their Personal Data to any non-agent third party or the use of that data for a purpose other than the purpose for which 3

it was originally collected or subsequently authorised by the individual.

5.2 We will not disclose Sensitive Personal Data to a non-agent third party or use Sensitive Personal Data for a purpose other than the purpose for which it was originally collected or subsequently authorised by the individual unless we have received the individual’s affirmative and explicit consent (opt-in).

5.3 We will provide individuals with reasonable methods to exercise their choices.

6. ONWARD TRANSFER OF PERSONAL DATA 

6.1 We will obtain assurances from our Agents that they will safeguard Personal Data in accordance with this safe harbor policy.

6.2 Appropriate assurances include:

(a) a contract between us and the Agent that requires the Agent to provide at least the same level of protection as is required by the Safe Harbor Principles;

(b) the Agent being subject to the Data Protection Directive;

(c) the Agent being established in a country that is subject to a finding of adequacy by the European Commission under Article 25(6) of Data Protection Directive; or

(d) safe harbor certification of the Agent.

7. SECURITY 

7.1 We will take reasonable precautions to protect Personal Data we create, maintain, use or disseminate from loss, misuse, unauthorised access, disclosure, alteration and destruction.

7.2 We will take special care to ensure the security of Sensitive Personal Data.

8. DATA INTEGRITY 

8.1 We will use Personal Data only for the purpose for which it was first collected or subsequently authorised by the individual or for other compatible purposes.

8.2 We will take reasonable steps to ensure that Personal Data is relevant to its intended use, accurate, complete and current. 4

9. ACCESS AND CORRECTION 

9.1 Upon request, we will provide individuals with reasonable access to the Personal Data that we hold about them except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where the rights of persons other than the individual would be violated.

9.2 We will take reasonable steps to permit individuals to correct, amend or delete Personal Data related to them that is inaccurate or incomplete.

10. ENFORCEMENT 

10.1 We will conduct compliance audits of its relevant privacy practices to verify compliance with this safe harbor policy.

10.2 Any Kaizen Life Group employee that we determine has acted in violation of this safe harbor policy will be subject to disciplinary action up to and including termination of employment.

11. DISPUTE RESOLUTION 

11.1 Any questions or concerns regarding our use or disclosure of Personal Data should be addressed to Kaizen Life Group at the address given below.

11.2 We will investigate and attempt to resolve any complaints and disputes regarding the use and disclosure of Personal Data in accordance with the provisions of this safe harbor policy.

11.3 For complaints that cannot be resolved between Kaizen Life Group and the complainant, we have agreed to participate in the following dispute resolution procedures in the investigation and resolution of complaints to resolve disputes in accordance with the Safe Harbor Principles:

(a) You agree to give us an opportunity to resolve any disputes or claims relating in any way to the Website, any dealings with our customer service agents, any services or products provided, any representations made by us, or our Privacy Policy us at info@team-kaizen.com. If we are not able to resolve your Claims within 60 days, you may seek relief through arbitration or in small claims court, as set forth below.

(b) At the Company’s sole discretion, it may require You to submit any disputes arising from the use of these Terms of 5

Use or the Website, including disputes arising from or concerning their interpretation, violation, invalidity, non-performance, or termination, to final and binding arbitration under the Rules of Arbitration of the American Arbitration Association applying Nevada law.

(c) Any and all Claims will be resolved by binding arbitration, rather than in court, except you may assert Claims on an individual basis in small claims court if they qualify. This includes any Claims you assert against us, our subsidiaries, travel suppliers or any companies offering products or services through us (which are beneficiaries of this arbitration agreement). This also includes any Claims that arose before you accepted these Terms of Use, regardless of whether prior versions of the Terms of Use required arbitration.

(d) Arbitrations do not involve a judge nor jury, and court review of an arbitration award is limited. However, an arbitrator can award on an individual basis the same damages and relief as a court (including statutory damages, attorneys’ fees and costs), and must follow and enforce these Terms of Use as a court would.

(e) The American Arbitration Association (AAA) will conduct all arbitrations under its rules, including the AAA Consumer Rules. Payment of all filing, administration and arbitrator fees will be governed by the AAA’s rules, except as provided in this section. If your total Claims seek less than $10,000, we will reimburse you for filing fees you pay to the AAA and will pay arbitrator’s fees. You may choose to have an arbitration conducted by telephone, based on written submissions, or in person in the state where you live or at another mutually agreed location.

(f) To begin an arbitration proceeding, you must send a letter requesting arbitration and describing your Claims to “Kaizen Legal: Arbitration Claim Manager,” at Kaizen Life Group, LLC, 7250 S. Durango Dr., Ste 130-256, Las Vegas, NV 89113. If we request arbitration against you, we will give you notice at the email address or street address you have provided. The AAA’s rules and filing instructions are available at www.adr.org or by calling 1-800-778-7879.

(g) Any and all proceedings to resolve Claims will be conducted only on an individual basis and not in a class, consolidated or representative action. If for any reason a Claim proceeds in court rather than in arbitration, we each waive any right to a jury trial. The Federal Arbitration Act and federal 6

arbitration law apply to this agreement. An arbitration decision may be confirmed by any court with competent jurisdiction.

12. CONTACT INFORMATION 

Questions or comments regarding this safe harbor policy should be submitted to Kaizen Life Group by mail or e-mail as follows:

Kaizen Life Group, LLC,

7250 S. Durango Drive

Suite 130-256,

Las Vegas, Nevada 89113

info@team-kaizen.com

13. EFFECTIVE DATE 

This safe harbor policy was last updated on 20 May 2016.

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