ASPEN iFAMILY^TM TERMS OF USE AND PRIVACY STATEMENT

These terms of use ("Terms of Use") apply to the online real estate information management services (the "Services") branded under the Aspen iFamily™ suite of services and all other property services related to Aspen Grove Solutions Services, with the exception of Aspen iListing™, the use of which is governed by separate agreement.. Aspen iFamily™ includes Aspen iAgent®, Aspen iProperty®, Aspen iVendor®, Aspen iListing™, Aspen iClient® Aspen iLearn™. Other property related services include any Aspen Grove Solutions online service used directly by Aspen Grove Solutions clients or by 3^rd Parties given access through Aspen Grove Solutions clients, for the management, listing, processing, disposition or service provision around, Real Estate Owned Properties, Broker Price Opinions, Property Appraisals, General Property Management, Vendor Services related to Property Management including but not limited to, Property Management, Property Disposition, Closing Services, Title Services, Repair and Preservation, Attorney Services. The Services provided are owned by Aspen Grove Solutions,(hereafter Aspen) a Delaware corporation and any of its successors, assigns and affiliates ("Aspen"). The Services' features and capabilities may vary depending on the particular Service(s) to which you subscribe. As used in the Terms of Use and Privacy Statement, the terms "you", "your", "yourself" and "user" all refer to the person or entity using the Services in any way.

1. Permitted Uses and Restrictions on Use

Subject to these terms and conditions of the Terms of Use and the Privacy Policy, Aspen makes the Services available to you via the World Wide Web. You may not use the Services until you have read and accepted all of the Terms of Use and the Privacy Policy by checking the "I accept" checkbox. By doing so, you further agree to the Acceptable Use Policy which is incorporated herein by reference and made a part of the Terms of Use and is stated at the end of the Terms of Use. In the event that you do not agree with any provision of the Terms of Use or Privacy Policy, do not access, use, copy, modify, or view any part of the Services. In order to use the Services, you must, at your own expense, obtain access to the World Wide Web, either directly or through devices that access web-based content. In addition, you are solely responsible for obtaining all equipment necessary to make such connection to the World Wide Web, including a computer and modem or other access device.

2. Registration and Content

In consideration of your use of the Services, you agree to: (a) provide true, accurate, current and complete information about yourself as prompted by the Services' registration form(s) ("Registration Data") and (b) maintain and promptly update the Registration Data to keep it true, accurate, current and complete. If you provide any information that Aspen has reasonable grounds to suspect is untrue, inaccurate, not current or incomplete, Aspen may suspend or terminate your account and refuse any and all current or future use of the Services (or any portion thereof). By using the Services and submitting data, files, software, text (including but not limited to names of files, databases and directories), software, music, sound, photographs, video or any other material (collectively, the "Content") to Aspen iFamily^TM suite of services and Aspen in connection with the Services, you represent and warrant that: (i) you are the owner of such Content, and (ii) the use of Content by Aspen will not infringe or misappropriate the intellectual property rights or otherwise violate the rights of any third party. The Content may include, but not be limited to, property addresses and characteristics, property photographs, property videos, sale price information, dates and names of parties including buyers, sellers, landlords, tenants, agents, agencies and vendors. By submitting Content and Personal Information (as defined in the Privacy Policy) to Aspen iFamily^TM suite of services and Aspen via the Services, you hereby grant to Aspen iFamily^TM suite of services and Aspen a worldwide, non-exclusive, royalty-free, sub-licensable and transferable license to use, reproduce and prepare derivative works of such Content and Personal Information for any lawful purpose and to display, distribute, give away or sell such Content and Personal Information to any party or parties not prohibited by law in any media format and through any media channels.

3. Access, Passwords and Security

You may designate and provide and assign account access and passwords to as many users as are permitted by the Service(s) for which you have registered. You shall be solely responsible for the confidentiality and use of your access number(s), password(s), and account number(s). You shall be solely responsible for all electronic communications, including account registration and other account holder information and other data including any Content ("Electronic Communications") entered through or under your access number(s), password(s) or account number(s). Aspen will assume that any Electronic Communications it receives under your access number(s), password(s) or account numbers(s) will have been sent by you. You agree to immediately notify Aspen if you become aware of any loss or theft or unauthorized use of any of your access number(s), password(s) and/or account number(s).

4. Member Conduct

By submitting Content to Aspen, you warrant that: (i) you are the owner of such Content, and (ii) the use of such Content by Aspen will not infringe or misappropriate the intellectual property rights of or otherwise violate the rights of any third party. You agree to not use the Services to:

interfere with or disrupt the Services, servers, networks or any combination thereof connected to the Services;
violate any applicable law or regulation, including, but not limited to, regulations promulgated by the U.S. Securities and Exchange Commission and any rules of any securities exchange; and
incite or provide instructional information about illegal activities.

5. General Practices Regarding Use, Storage and Services Access

You acknowledge that Aspen may establish from time to time general practices and limits concerning use of the Services, including without limitation, establishing the maximum amount of storage space you have on the Services at any time, as well as limiting the number of times (and the maximum duration for which) you may access the Services in a given period of time. You agree that Aspen has no responsibility or liability for the deletion or failure to store any messages and other communications or other Content maintained or transmitted to or from the Services. As a condition of use for the Services, you agree that, in the event that your access to the Services is interrupted as a result of a malfunction, technical error or general disrepair, a Services technician shall be permitted to access your information as necessary to resolve the problem. You acknowledge that Aspen reserves the right to change these general practices and limits at any time, in its sole discretion.

6. HIPAA

You acknowledge and agree that the Services and Content are not "HIPAA-ready" or "HIPAA-compliant" and will not assist with or ensure compliance with HIPAA, and that you are solely responsible for using the Services and Content in a manner consistent with all applicable federal and state privacy laws relating to medical or health information.

7. Modifications to the Services and Terms of Use

7.1 Modifications to the Services. Aspen expressly reserves the right at any time and from time to time to modify or discontinue, temporarily or permanently, the Services (or any part thereof). You agree that Aspen shall not be liable to you or to any third party for any modification, suspension or discontinuance of the Services or loss of access to the Content. Aspen may specify from time to time the version(s) of related products required in order to use the Services (e.g. supported browser versions).

7.2 Modifications to the Terms of Use. You agree that Aspen may modify the Terms of Use if necessary to comply with any other agreements that Aspen is currently bound by or will be bound by in the future, and/or with applicable law, as well as to adjust to changing business circumstances. Your continued use of the Services shall constitute your acceptance of the Terms of Use with the new modifications. If you do not agree to any of such changes, you should immediately cease all access and use of the Services. You agree that such termination of your use of the Services will be your sole and exclusive remedy if you do not wish to abide by any changes to the Terms of Use.

8. Charges/Credits/Termination

You agree to pay the then-current fees associated with the Service(s) you choose. You will be notified of all applicable Service fees incurred by you within a reasonable time after subscribing to a Service or Services. If you are an end-user, you may be charged a fee by Aspen and by your client. Aspen may be asked by the client to collect the fees on their behalf or they may collect the fee directly, or you may not incur a fee. You authorize Aspen to debit your credit card for any payments owed related to your use and subscription to the Services or to issue you an invoice for related services that is payable on receipt. Aspen reserves the right to modify its fees at any time.

Where Service fees apply, all fees will be billed to you at the time of purchase or near the end of each calendar month for all fees that were incurred during the calendar month and the bill will be immediately due and payable by you. If you decide to terminate access to the Services, such termination shall be effective at the end of the last day of the calendar month that we receive your termination notice. If Aspen terminates your access to the Services pursuant to these Terms of Use, such termination shall be effective immediately. The calendar month that the Services is terminated for any reason is the "Termination Month". During or after any Termination Month, in lieu of the normal billing procedure, Aspen reserves the right and may elect to automatically charge your credit or debit card on or after the effective date of the Service termination for all incurred and unpaid fees. You shall be responsible for all fees incurred by you up to the effective date of the termination. This obligation survives any expiration or termination of the Terms of Use. There shall be no refunds or credits to users of the Services except as expressly provided in this Section unless Aspen elects to issue a refund or credit to users of the Services on a case by case basis in its sole and absolute discretion. Where your bills are not paid on time, or if you actions result in a charge back Aspen reserve the right to charge you interest and or a charge back fee.

9. Termination and Indemnity

You acknowledge and agree that Aspen may suspend or terminate your account and/or deny you access to, use of, or submission of Content for, all or part of the Services, without prior notice, if you engage in any conduct that Aspen believes, in its sole discretion: (a) violates any term or provision of the Terms of Use, (b) violates the rights of Aspen or third parties, (c) or is otherwise inappropriate for continued access and use of the Services. In addition, Aspen reserves the right to terminate inactive membership accounts. You agree that upon termination of the Services, either by you or Aspen, Aspen may delete all Content and information related to your account and may bar your access to your account and the Services including, but not limited to, access to any of your Content entered into or used in connection with the Services. Further, you agree that Aspen shall not be liable to you or any third-party for any termination of your access to the Services. You agree to defend, indemnify and hold Aspen harmless from and against any and all claims, losses, liability costs and expenses (including but not limited to attorneys' fees and expenses) arising from: (i) any inaccuracy or falsity related to the Content or the Personal Information (as defined in the Privacy Policy) and, (ii) your violation of the Terms of Use, state or federal laws or regulations, or any third party's rights, including but not limited to infringement of any trademark, patent, copyright or other intellectual property right, violation of any proprietary right or invasion of any privacy rights. This obligation shall survive the termination of Services and the termination or expiration of these Terms of Use, whichever applicable.

10. Links

The Services may provide links to other World Wide Web sites or resources. You acknowledge and agree that Aspen is not responsible for the availability of such external sites or resources, and does not endorse and is not responsible or liable for any content, advertising, products, or other materials on or available from such sites or resources. You further acknowledge and agree that Aspen shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, goods or services available on or through any such site or resource.

11. Aspen and Third Party Proprietary Rights

You acknowledge and agree that the Services contains proprietary and confidential information that is protected by applicable intellectual property and other laws. You further acknowledge and agree that content contained in sponsor advertisements or information that may have been presented to you through the Services or advertisers is protected by copyrights, trademarks, service marks, patents or other proprietary rights and laws.

12. No Resale, Etc. of the Services

You agree not to copy, sell, resell, rent or license (including offering the Services to third parties on an applications service provider or time-sharing basis), lease, loan, give, redistribute, or create a derivative work of any portion of the Services, use of the Services, or access to the Services. You agree not to access the Services by any means other than through the interface that is provided by Aspen for use in accessing the Services. You may not use, copy, modify or transfer the Services, in whole or in part, except as expressly provided in these Terms and Conditions. You agree to not make any attempt to decompile, disassemble or reverse engineer the Services or otherwise discover or derive the source code or underlying processes, ideas, structure, organization or algorithms of the Services.

13. Disclaimer of Representations and Warranties

YOU EXPRESSLY UNDERSTAND AND AGREE THAT:

YOUR USE OF THE SERVICE IS AT YOUR SOLE RISK. THE SERVICE AND ANY CONTENT OR ADD-ON FEATURES THROUGH THE SERVICE ARE PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS. ASPEN AND ITS SUPPLIERS EXPRESSLY DISCLAIM ALL REPRESENTATIONS AND WARRANTIES OF ANY KIND, WHETHER EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE AND NON-INFRINGEMENT.

ASPEN AND ITS SUPPLIERS MAKE NO REPRESENTATION OR WARRANTY THAT THE SERVICE AND ANY CONTENT OR ADD-ON FEATURES THROUGH THE SERVICE (i) WILL MEET YOUR REQUIREMENTS OR RESULT IN REVENUES OR PROFITS, (ii) WILL BE UNINTERRUPTED, TIMELY, SECURE, OR ERROR-FREE, (iii) WILL PROVIDE RESULTS THAT ARE ACCURATE OR RELIABLE, AND (iv) WILL MEET YOUR QUALITY EXPECTATIONS OF ANY PRODUCTS, SERVICES, INFORMATION, OR OTHER MATERIAL PURCHASED OR OBTAINED BY YOU THROUGH THE SERVICES. ASPEN EXPRESSLY DISCLAIMS ANY REPRESENTATIONS OR WARRANTIES THAT ANY LAWS OR REGULATIONS DESCRIBED IN THE SERVICE HAVE BEEN DESCRIBED ACCURATELY OR COMPLETELY AND THAT YOUR USE OF THE SERVICES WILL SATISFY ANY STATUTORY OR REGULATORY OBLIGATIONS, OR WILL ASSIST WITH, GUARANTEE OR OTHERWISE ENSURE COMPLIANCE WITH ANY APPLICABLE LAWS OR REGULATIONS, INCLUDING BUT NOT LIMITED TO STATE PROFESSIONAL LICENSING LAWS, THE HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ACT OF 1996 ("HIPAA"), THE GRAMM-LEACH-BLILEY ACT OF 1999, THE SARBANES-OXLEY ACT OF 2002, OR OTHER FEDERAL OR STATE STATUTES OR REGULATIONS. YOU ARE SOLELY RESPONSIBLE FOR ENSURING THAT YOUR USE OF THIS SERVICES OR CONTENT IS IN ACCORDANCE WITH APPLICABLE LAW.

ANY CONTENT OR MATERIAL TRANSFERRED FROM, DOWNLOADED OR OTHERWISE OBTAINED THROUGH THE USE OF THE SERVICES OR ADD-ON FEATURES THROUGH THE SERVICES ARE DONE AT YOUR OWN DISCRETION AND RISK AND YOU WILL BE SOLELY RESPONSIBLE FOR ANY DAMAGE TO YOUR COMPUTER SYSTEM OR LOSS OF DATA AND/OR CONTENT THAT RESULTS FROM THE TRANSFER OR DOWNLOAD OF ANY SUCH MATERIAL.

NO ADVICE OR INFORMATION, WHETHER ORAL OR WRITTEN, OBTAINED BY YOU FROM ASPEN OR THROUGH OR FROM THE SERVICES OR ADD-ON FEATURES THROUGH THE SERVICES SHALL CREATE ANY REPRESENTATION OR WARRANTY NOT EXPRESSLY STATED IN THE TERMS OF USE.

14. Limitation of Liability

(a) YOU EXPRESSLY UNDERSTAND AND AGREE THAT ASPEN AND ITS SUPPLIERS SHALL NOT BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL OR EXEMPLARY DAMAGES, INCLUDING BUT NOT LIMITED TO, DAMAGES FOR LOSS OF PROFITS, GOODWILL, USE, CONTENT OR OTHER INTANGIBLE LOSSES (EVEN IF ASPEN HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES), RESULTING FROM: (i) THE USE OR THE INABILITY TO USE THE SERVICES, CONTENT AND/OR ANY INFORMATION; (ii) THE COST OF PROCUREMENT OF SUBSTITUTE GOODS AND SERVICE RESULTING FROM ANY GOODS, CONTENT, INFORMATION OR SERVICE PURCHASED OR OBTAINED OR MESSAGES RECEIVED OR TRANSACTIONS ENTERED INTO THROUGH OR FROM THE SERVICES; (iii) UNAUTHORIZED ACCESS TO OR ALTERATION OF YOUR TRANSMISSIONS OR CONTENT; (iv) STATEMENTS OR CONDUCT OF ANY THIRD PARTY ON THE SERVICES; OR (v) ANY OTHER MATTER RELATING TO THE SERVICES;

(b) YOU ALSO AGREE THAT ASPEN WILL NOT BE LIABLE FOR ANY (i) INTERRUPTION OF BUSINESS, (ii) ACCESS DELAYS OR ACCESS INTERRUPTIONS TO THIS SITE OR THE WEB SITE(S) YOU ACCESS THROUGH THE SERVICES; (iii) CONTENT NON-DELIVERY, MIS-DELIVERY, ERRORS, OMISSIONS, CORRUPTION, DESTRUCTION OR OTHER MODIFICATION; OR (iv) EVENTS BEYOND ASPEN'S REASONABLE CONTROL; AND

(c) IN NO EVENT SHALL ASPEN'S MAXIMUM AGGREGATE LIABILITY EXCEED THE TOTAL AMOUNT PAID BY YOU TO ASPEN FOR THE SERVICE, BUT IN NO EVENT GREATER THAN FOUR HUNDRED DOLLARS ($400.00). SOME STATES MAY NOT ALLOW THE EXCLUSION OR LIMITATION OF CERTAIN WARRANTYS OR LIABILITY FOR CONSEQUENTIAL OR INCIDENTAL DAMAGES, IN SUCH STATES, ASPEN'S LIABILITY IS LIMITED TO THE EXTENT PERMITTED BY LAW.

15. General Information

The Terms of Use and Privacy Statement constitute the entire agreement between you and Aspen and govern your use of the Services, superseding any prior agreements between you and Aspen (including, but not limited to, any prior versions of the Terms of Use and Privacy Statement) with respect to its subject matter. You also may be subject to additional terms and conditions that may apply when you use affiliate or other Aspen services, third-party content or third-party software. Except as otherwise provided herein, the Terms of Use and Privacy Policy shall be governed by the laws of the State of Maryland without regard to any conflict of law provisions. The Terms of Use and Privacy Policy do not limit any rights that Aspen may have under trade secret, copyright, patent, trademark or other laws. The failure of Aspen to exercise or enforce any right or provision of the Terms of Use and Privacy Statement shall not constitute a waiver of such right or provision. If any provision of the Terms of Use and Privacy Policy is found by a court of competent jurisdiction to be invalid, the parties nevertheless agree that the court should endeavor to give effect to the parties' intentions as reflected in the provision, and the other provisions of the Terms of Use and Privacy Statement remain in full force and effect. You agree that any claim or cause of action arising out of or related to use of the Services or the Terms of Use and Privacy Statement must be filed within one (1) year after such claim or cause of action arose but no later than one (1) year after your use of the Services has terminated for any reason or be forever barred. The section titles in the Terms of Use and Privacy Statement are for convenience only and have no legal or contractual effect. The Terms of Use and Privacy Policy shall inure to the benefit of Aspen and its successors, assigns and affiliates.

16. Non-Discrimination Policy

Aspen does not discriminate on the basis of race, color, sex, religion, national origin, handicap or familial status in the establishment of fees, entrance qualifications or standards for the use of the Services.

17. Government End-User Notice

The Services is a "Commercial Item," as that term is defined at 48 C.F.R § 2.101, consisting of "Commercial Computer Software" and "Commercial Computer Software Documentation," as such terms are used in 48 C.F.R. § 12.212 and 48 C.F.R. § 227.7202, as applicable. Consistent with 48 C.F.R. § 12.212, 227.7202-1 through 227.7202-4, the Commercial Computer Software and Commercial Computer Software Documentation are being licensed to U.S. Government end-users (a) only as Commercial Items and (b) with only those rights as are granted to all other end-users pursuant to the terms and conditions herein.

18. Survival

All representations and warranties contained herein and Sections 1, 2, 5, 8, 9, 10, 12, 13, 14 and 15 in the Terms of Use and all of the Provisions of the Privacy Policy shall survive after your use of the Services has expired or terminated for any reason.

Acceptable Use Policy

1. Responsibility for Content

You understand that all Content, whether publicly posted or privately transmitted, is the sole responsibility of the person from whom such Content originated. This means that you and other third parties, and not Aspen, are solely and entirely responsible for all Content that you upload or otherwise view or transmit via the Services. Aspen does not control the Content uploaded or otherwise transmitted by you or other third parties via the Services and, as such, does not guarantee the accuracy, integrity or quality of such Content.

2. Other Conduct

You agree to not use the Services to: (a) upload or otherwise transmit any Content or domain name that is unlawful, threatening, abusive, harassing, tortuous, defamatory, vulgar, obscene, libelous, invasive of another's privacy, hateful, or racially, ethnically or otherwise objectionable; (b) harm or exploit minors in any way; (c) impersonate any person or entity, including, but not limited to, any Aspen representative, or misrepresent your affiliation with any person or entity; (d) forge headers or otherwise manipulate identifiers in order to disguise the origin of any Content transmitted through the Services; (e) upload or otherwise transmit any Content that you do not have a right to transmit under any law or under contractual relationships (including but not limited to inside information, proprietary and confidential information learned or disclosed as part of employment relationships or under nondisclosure agreements); (f) upload or otherwise transmit any Content or domain name that infringes any patent, trademark, trade secret, copyright or other proprietary rights of any person; (g) upload or otherwise transmit any unsolicited or unauthorized advertising, promotional materials, "junk mail", "spam", "chain letters", "pyramid schemes", or any other form of solicitation, except in those areas of the Services that may be designated for such purpose; (h) upload or otherwise transmit any material that contains software viruses or any other computer code, files or programs designed to interrupt, destroy or limit the functionality of any computer software or hardware or telecommunications equipment; (i) interfere with or disrupt the Services or servers or networks connected to the Services; (j) violate any applicable law or regulation, including, but not limited to, regulations promulgated by the U.S. Securities and Exchange Commission and any rules of any securities exchange, and laws regarding the export of technical data; (k) incite or provide instructional information about illegal activities; or (l) conduct raffles, contests, lotteries or sweepstakes, except in those areas of the Services that may be designated for such purpose.

3. Other

This Acceptable Use Policy is subject to change at any time without notice.

Privacy Statement for Aspen Grove Solutions

This privacy statement applies to the online services (the "Services") branded under the Aspen iFamily™ suite of services, all other property solution services and other online services provided by Aspen Grove Solutions. The Services provided are owned by Aspen Grove Solutions (hereafter Aspen) a Delaware corporation and any of its successors, assigns and affiliates ("Aspen").

Aspen is committed to protecting your privacy. This "Privacy Statement" explains data collection and use practices of the Aspen iListing™ , Aspen iClient® , Aspen iVendor® , Aspen iProperty®, Aspen iAgent®, Aspen iLearn^TM or other Aspen Grove sites (the "Site"). By accessing the Site or using the Services, you are consenting to the information collection and use practices described in this Privacy statement.

The Services' features and capabilities may vary depending on the particular Service(s) to which you subscribe. The terms "you", "your", "yourself" and "user" all refer to the person or entity using the Services in any way.

Aspen is a property management solution company with operations in various countries around the world and provides property management solutions to its corporate clients. Aspen processes the personal data belonging to its corporate clients on behalf of those clients. In order to fulfill this function Aspen receives the personal data of individuals from its corporate clients.

Storing of Personal Information

Aspen stores and processes personal information on behalf of our corporate clients.Our corporate clients are the data controllers for this data and are responsible for ensuring that it is collected and processed in accordance with their own privacy policy and any applicable laws and regulations.Aspen act as data processors for our corporate clients and are obliged to ensure we meet, or exceed, the data protection and privacy requirements of our corporate clients

In the course of serving its customers, Aspen acquires, stores and transmits customer information that may contain personal information. Personal information - such as the customer's name, address, telephone number, electronic mail address, skills and qualifications, photographic, insurance policy details, and credit card data - is provided to Aspen by its customers in order to establish and provision service.

Some of our websites enable visitors to provide personal information for the purpose of submitting requests for information or other queries.Such information may include the IP address of your computer, your name, your email address, location and/or phone number. By providing Aspen with this information, you consent to your information being collected, used, disclosed and stored by us in accordance with this Privacy Statement. Any such information is not provided to third parties and will be used by Aspen solely for the purpose you gave it to us. Please note that such personal data may be anonymised to enable Aspen perform statistical, troubleshooting or performance monitoring.

Use of Your Personal Information

Personal information stored and processed by Aspen will only be used for the purposes it was given to us, whether directly by you or by our corporate clients.

Disclosure of Personal Information and Transfers
Aspen does not disclose an individual's personal information to third parties except when:

Aspen has the individual's verified permission to make the disclosure;
the disclosure is required by law or mandatory professional standards;
In response to a valid court order or a search warrant;
the disclosure is reasonably related to the sale or other disposition of all or part of Aspen's business;
the disclosure is reasonably necessary for the establishment of legal claims;
the disclosure is to another division of Aspen, to an affiliate of Aspen, or to persons or entities providing services on Aspen's or the individual's behalf (each a "permitted transferee"), consistent with the purpose for which the information was obtained, if the permitted transferee, with respect to the information in question (a) is subject to law providing at least the same level of privacy protection as required by Aspen; (b) has agreed in writing to provide at least the same level of privacy protection as required by Aspen; or (c) subscribes to the EU Safe Harbor framework as set forth by the US Department of Commerce or equivalent.
Permitted transfers of information include the transfer of data from one jurisdiction to another, including transfers to and from the United States of America.

Security
Aspen protects the confidentiality of its customers' personal contact and account information. To secure the information collected online, prevent unauthorized access, maintain data accuracy and ensure only appropriate use of information that is collected from customers, Aspen has implemented appropriate physical, electronic, and managerial procedures in line with the ISO 27001:2005 Information Security standard. Further, Aspen requires that employees keep customer information confidential.

Aspen cautions its customers and website visitors that no medium of communication, including the Internet, is entirely secure.

Data Integrity

Aspen processes personal information only in ways compatible with the purpose for which it was collected or authorized. To the extent necessary for such purposes, Aspen takes reasonable steps to ensure that data is reliable for its intended use, accurate, complete, and current

Data Access Requests

There are two ways that Aspen shall respond to individuals' requests for copies of their personal data held on Aspen's systems.These are;

Via our corporate clients who are the Data Controller for the personal data in question and who require Aspen to provide that data to them.
Should an individual submit their personal data directly to Aspen, for example via a web form on one of our websites, we will supply copies of such personal data. If you wish to obtain such copies, you can contact us via our contact page. In order to process your request in a timely manner you should provide any personal identifiers that you submitted to us such as name, email address or phone number. Your request will be dealt with as soon as possible and will take not more than 40 days to process. Aspen retain the right to charge a small fee, in accordance with the Irish Data Protection Acts 1988, 2003, for these requests if it so wishes.

Inaccurate Personal Data

If Aspen is holding inaccurate personal data relating to you then you can request us to correct that information.

If your data was submitted to Aspen via one of our corporate clients you must submit your request to correct the data via that corporate client.
If your data was submitted directly to Aspen that request can be sent directly to us either in writing or via e-mail.

Data Retention

It is Aspen's policy to retain personal data for no longer than necessary.For personal data we process on behalf of our corporate clients Aspen will comply with our clients' data retention policies.

For personal data submitted directly to us, Aspen will only retain that data for as long as it is necessary to carry out the purpose for which that personal data was gathered. Once that purpose is complete the personal data will no longer be retained.

All personal data that is no longer required to be retained shall be securely destroyed.

EU and Swiss Safe Harbor framework

Aspen 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. Aspen has certified that it adheres to the Safe Harbor Principles of notice, choice, onward transfer, security, data integrity, access and enforcement. Details of our certification can be found at http://safeharbor.export.gov/companyinfo.aspx?id=16861

Irish Data Protection Notification

Aspen has a registered office in Ireland and as such any personal information stored and processed by Aspen will be treated with the highest standards of security and confidentiality and strictly in accordance with the Data Protection Acts, 1988 & 2003

Enforcement
Aspen is committed to ensuring all customer personal information is handled in a manner consistent with the purpose for which the information was obtained. If a customer has inquiries or complaints about how their personal information is handled, please send an email to privacy@aspengrovesolutions.com . We will provide answers or begin investigations as necessary.

Amendment
Aspen may amend this policy from time to time by posting a revised policy on this website, or a similar website that replaces this website. If Aspen amends the policy, the new policy will apply to personal information previously collected only insofar as the rights of the individuals affected are not reduced. So long as Aspen adheres to the Safe Harbor Principles, we will not amend our policy in a manner inconsistent with the Safe Harbor Principles.

Contact Information

If a customer has inquiries or complaints about how their personal information is handled, please send an email to privacy@aspengrovesolutions.com. We will provide answers or begin investigations as necessary.