SAFE HARBOR PRIVACY POLICY FOR CONSUMER DATA - EFFECTIVE DATE May 17, 2016

ProV International, Inc. (“ProV”) 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. ProV has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view ProV’s certification, please visit http://www.export.gov/safeharbor

ProV International, Inc. ("ProV") is committed to upholding the highest ethical standards in its business practices and strives to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business. This Safe Harbor Privacy Policy sets forth the privacy principles that ProV follows with respect to personal consumer information transferred from the European Economic Area (EEA) (which includes the twenty-eight member states of the European Union (EU) plus Iceland, Liechtenstein and Norway) and from Switzerland to the United States.

ProV 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.

The United States Department of Commerce and the European Commission have agreed on a set of data protection principles (the "U.S.-EU Safe Harbor Principles") and frequently asked questions (collectively the “U.S.-EU Safe Harbor Framework”) to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EU to the United States. The EEA also has recognized the U.S. Safe Harbor as providing adequate data protection. The United States Department of Commerce and the Federal Data Protection and Information Commissioner of Switzerland have agreed on a similar set of data protection principles (the "U.S.-Swiss Safe Harbor Principles") and frequently asked questions (collectively the “U.S.-Swiss Safe Harbor Framework) to enable U.S. companies to satisfy the requirement under Swiss law that adequate protection be given to personal information transferred from Switzerland to the United States. Consistent with its commitment to protect personal privacy, ProV adheres to the U.S.-EU and U.S.-Swiss Safe Harbor Principles (hereinafter “Safe Harbor Principles”).

SCOPE

This Safe Harbor Privacy Policy (the "Policy") applies to all personal information received from consumers by ProV in the United States from the European Economic Area and from Switzerland, in any format including electronic, paper or verbal.

DEFINITIONS

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

"Agent" means any third party that collects or uses personal information under the instructions of, and solely for, ProV or to which ProV discloses personal information for use on ProV's behalf.

"ProV" means ProV International, Inc., its successors, subsidiaries, divisions and groups in the United States.

"Personal information" means any information or set of information that identifies or is used by or on behalf of ProV 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, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns health or sex life. In addition, ProV will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.

PRIVACY PRINCIPLES

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

NOTICE: Where ProV collects personal information directly from individuals in the EEA, it will inform them about the purposes for which it collects and uses personal information about them and the choices and means, if any, ProV 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 ProV, or as soon as practicable thereafter, and in any event before ProV uses or discloses the information for a purpose other than that for which it was originally collected or discloses information to a non-agent third party.

Where ProV receives personal information from its subsidiaries, affiliates or other entities in the EEA, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.

CHOICE: For personal information, ProV will offer individuals the opportunity to choose (opt-in) 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, ProV 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.

ProV will provide individuals with reasonable mechanisms to exercise their choices.

DATA INTEGRITY: ProV will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. ProV will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current. We will only collect and store personal information that is relevant to fulfill the purpose of the request and will retain such information no longer than appropriate to fulfill the purpose of the request.

TRANSFERS TO AGENTS: ProV 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. Where ProV has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, ProV will take reasonable steps to prevent or stop the use or disclosure.

ACCESS AND CORRECTION: Upon request, ProV will grant individuals reasonable access to personal information that it holds about them. In addition, ProV will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. These requests can be made by calling the ProV office in the country where they reside and asking for consumer services.

SECURITY: ProV will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

ENFORCEMENT: ProV will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that ProV determines intentionally violates this policy will be subject to disciplinary action up to and including termination of employment.

DISPUTE RESOLUTION: Any questions or concerns regarding the use or disclosure of personal information should be directed to the ProV Office of Ethics and Business Conduct at the address given below. ProV 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 ProV and the complainant, ProV has agreed to participate in the dispute resolution procedures of the American Arbitration Association pursuant to the Safe Harbor Principles.

LIMITATIONS ON APPLICATION OF PRINCIPLES

Adherence by ProV to these Safe Harbor Principles may be limited (a) to the extent required or permitted by law or legal process, such as to respond to or investigate a legal or ethical obligation or request or pursuant to court orders, subpoenas, interrogatories or similar directive carrying the force of law; and (b) to the extent expressly permitted by an applicable law, rule or regulation.

INTERNET PRIVACY

ProV sees the Internet and the use of other technologies as valuable tools for communicating and interacting with consumers. ProV recognizes the importance of maintaining the privacy of information collected online and has created a specific Internet Privacy Policy (the "IPP") governing the treatment of personal information collected through web sites that it operates. With respect to personal information that is transferred from the European Economic Area or Switzerland to the U.S., the IPP is subordinate to this Policy. However, the IPP also reflects additional legal requirements and evolving standards with respect to Internet privacy. ProV’s Internet Privacy Policy can be found at http://www.ProVintl.com/privacy.aspx.

CONTACT INFORMATION

Questions or comments regarding this Policy should be submitted to the ProV Office by mail as follows:

ProV International, Inc.
502 N. Rocky Point Drive. Ste 896
Tampa, FL 33607

CHANGES TO THIS SAFE HARBOR PRIVACY POLICY

This Policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. A notice will be posted on the ProV web page (www.ProVintl.com) for 60 days whenever this Safe Harbor Privacy Policy is changed in a material way.