Privacy Policy

Privacy Statement - May 2008

This online privacy policy describes the information SodexoPass USA, Inc. ("Sodexo") collects through the services available on our web site, www.esteempass.com (the "Site") and the EsteemPass Card Program, and how we use that Information. Our policy also describes the choices you can make about how we collect and use your information.

What type of information does Sodexo collect about me? Sodexo may collect personal information. Personal information means information about an identifiable individual and may include identifying information, such as name, address, e-mail address; or financial information, such as credit card number.

In addition to the personal information you actively provide us, we may also collect web site use information which includes Information about your Internet service provider, browser type, domain name, IP address, the web site that referred you to us, the web pages you request, the date and time of those requests, and entry and exit points. Our collection of web site use information may involve the use of cookies and pixel tags.

Sodexo may also collect aggregated data, which is data from which the identity of an individual cannot be determined. Since it is not personal information, Sodexo may use aggregated data in any way that it considers appropriate.

How does Sodexo use personal information?

Sodexo may use personal information in order to:

• Process and manage your purchase of products and services, including the purchase and use of your EsteemPass Card;
• Communicate with you about your order or purchases, or your EsteemPass Card account;
• Respond to your customer service inquiries;
• Communicate with you about our brands, products, events or other promotional purposes, including co-branded offers, if you have opted to receive such communications;
• Communicate, to the extent required, with and manage our relationship with Sodexo's consultants, strategic partners, agents, distributors, suppliers, contractors and other third parties in order to provide services or products you have requested;
• Meet any applicable legal and regulatory requirement.

Is my personal information shared with third parties?

We will give you the option to receive marketing and promotional information from retailers or other companies involved in the EsteemPass Card Program, but only if you tell us that you would like to receive these sorts of materials in your communication preferences.

Our website may also share information with companies that provide support services to us (such as credit card processors, mailing houses or web hosts) or that help us market our products and services (such as email vendors). These companies may need information about you in order to perform their functions in accordance with the preferences you indicate. These companies may only use your information in accordance with the preferences you select and are not authorized to use the information we share with them for any other purpose.

We may disclose specific information upon governmental request, in response to a court order, when required by law, to enforce our corporate policies, or to protect our or others' rights, property, or safety. We do not provide information to these agencies or companies for marketing or commercial purposes.

In the event of a sale of some or all of our business, Sodexo may disclose personal information to those involved in a transfer of all or part of the assets or business.

Unless permitted by law, no personal information is collected, without first obtaining your consent for the collection, use and sharing of that information. By providing personal information to Sodexo, you agree and consent that we may collect, use and share your personal information in accordance with this privacy policy.

In most cases, and subject to legal and contractual restrictions, an individual is free to refuse or withdraw his or her consent at any time upon reasonable, advance notice. It should be noted that in some circumstances, certain Sodexo products and services can only be offered if a person provides personal information to Sodexo. If you choose not to provide us with any required personal Information, we may not be able to offer the products or services requested.

How can I change what promotional communications I receive?

We may use your e-mail address and other contact information provided to us through the Site or the EsteemPass Card Program to send you promotional materials from us and, as an additional opt-in, from third parties. If you do not want to receive such promotional information, you can remove yourself from any of these e-mail lists at any time by following the instructions included with each e-mail.

Please also note that even if you opt out of receiving promotional emails from us, we may still use your information to communicate with you for other purposes, such as orders/purchases, your EsteemPass Card account, customer service responses and other communications we consider necessary in order to service your account.

How do I remove or modify my personal information?

To remove or modify your personal information, please log in to the Site and modify your personal information in the profile area of your account.

Why does Sodexo collect web site use information?

During your visit to this Site, we will collect certain web site use information for a number of purposes, namely to:

• Make your access to services and products more convenient and efficient;
• Establish Site activity trends;
• Monitor Site performance; and
• Improve Site design and functionality.

Our collection of web site use information may involve the use of cookies. A cookie is a small removable data file that is stored by your web browser on your computer. Cookies allow you to place an order on our website and allow us to enhance and personalize your online surfing and shopping experience. We use cookies to remember the items in your cart, recognize you when you return to our website and analyze visitor behavior.

You can choose to have your computer warn you each time a cookie is being sent or you can choose to turn off all cookies. You do this through your browser (like Netscape Navigator or Internet Explorer) settings. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookie settings. If you turn cookies off, you won't have access to many features that make your site experience more efficient and some of our services will not function properly.

We also use pixel tags – tiny graphic images – to help us analyze your online behavior, but we do not tie that behavior to any personal information.

How is my personal information secured?

Sodexo strives to maintain appropriate physical, procedural and technical security with respect to its offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of personal information.

We encrypt the pipe through which personal information, such as credit card numbers, is sent, using Secure Socket Layer (SSL) technology to ensure that your information is safe as It Is sent over the Internet to our server.

Information from children

www.esteempass.com is a general audience site that is not designed nor intended to collect personal information from children under the age of 13. Sodexo does not knowingly collect personal information from anyone under the age of 13, and does not use such information if it discovers that it is has been provided. To respect the privacy of children and to comply with the Children's Online Privacy Protection Act, children under the age of 13 should not provide any personal information on this Site. We ask that parents supervise their children while online.

What about links to other sites?

Please be aware that we may provide links to third-party web sites as a service to our guests, and that we are not responsible for the content or information collection practices of those pages. Please note that these web sites' privacy policies may differ from this privacy policy. We encourage you to review and understand their privacy practices before providing them with information.

Privacy policy changes

If we decide to change our privacy policy, we will post a new statement on our Site and change the date at the top of the policy. Therefore, we encourage you to check the date of our privacy policy whenever you visit this Site for any updates or changes.

Questions and Feedback

You may provide any questions, comments, or concerns about this privacy policy by e-mailing us at support.sodexopass.usa@sodexo.com.