Organization Information:

Affinion Data Services, Inc. (formerly known as Cendant Data Services, Inc.)
40 Oakview Drive
Trumbull, Connecticut 06611
Phone: 203 956-1000
Fax: 203 956-8789
http://www.affiniongroup.com/
Contact Information:

Contact Office: Affinion Group, Inc.
Contact Name: Brian Fisher, Senior Vice President
Phone: 203 956-1000 Fax: 203 956-8789 Email: bfisher@affiniongroup.com

Corporate Officer Information:

Corporate Officer: Brian Fisher, Senior Vice President
Phone: 203 956-1000 Fax: 203 956-8789 Email: bfisher@affiniongroup.com

Safe Harbor Information:

Signed up to safe harbor 04/30/2001 04:58:18 PM
Next certification 04/30/2010
EU/EEA Countries From Which Personal Information Is Received: Austria, Belgium, Denmark, Finland, France, Germany, Greece, Ireland, Italy, Luxembourg, Netherlands, Norway, Portugal, Spain, Sweden, United Kingdom, Cyprus, Malta, Slovakia, Estonia, Latvia, Slovenia, Lithuania, Hungary, Poland, Czech Republic
Industry Sector: Computer Services - (CSV)
Personal Information Received From the EU:
Affinion Data Services, Inc. acts as a Data Processor and processes data in accordance with instructions from the Data Controller. Affinion Data Services, Inc. only supports business offerings of its European affiliates and/or former affiliates purely as a processor. In doing so, it acts at the specific direction of the European affiliates and/or former affiliates. Written instructions are provided by such affiliates and/or former affiliates outlining the authority granted to Affinion Data Services, Inc. as the Data Processor.

The data transferred is on-line data. The data transferred to Affinion Data Services, Inc. includes customer data housed in the databases of the clients of its European affiliates and/or former affiliates. The data will also be processed by Affinion Data Services, Inc. in the following way: off-line backups for recovery purposes which are stored on-site and archived off-site. The manual processing is limited to use of the data in problem solving and movement of databases for normal operational upgrades, recoveries and other actions to assure integrity, security and operability of the servers as needed by its clients, affiliates, and/or former affiliates. This is the necessary technical and database support required to assure continuous operation of the servers. Manual handling is on a need-to-know basis by authorized operations staff, technical support persons, database administrators, network administrators, and security administrators and is only accessed for problem solving, backups and normal computer operations movement of data.

Privacy Policy Effective: Effective April, 2001; Revised March 2006
Location: Affinion Group, Inc. address above
Regulated by: Federal Trade Commission
Privacy Programs:
Affinion Data Services, Inc., has instituted a self-regulatory program for ensuring verification and adherence to the safe harbor principles. This may consist of regular information security reviews including privacy information reviews, physical security reviews, disaster recovery planning, testing and reviews, internal and external audits of security of Affinion Data Services, Inc., reviews performed by Affinion International Limited (the main client of Affinion Data Services, Inc.) and onsite and survey reviews by Affinion International Limited's clients. This also consists of periodic certification/vulnerability assessments, which includes periodic renewal and check pointing to assure maintenance of certification. Vulnerability reviews by Affinion Group or its designated third parties are also performed periodically. In addition, Affinion Data Services, Inc. maintains Cybertrust/TruSecure enterprise-level certifications of the Trumbull, CT and Westerville, OH Data centers. The Cybertust certification processes provide for (among other things) a quarterly scan of our internet perimeter and annual re-certification validation and assessment of the Data Centers.
Verification: In-house and third party
Dispute Resolution: Affinion Data Services, Inc. commits to cooperation with the EU Data Protection authorities.
Personal Data Covered: On-Line Data
Human Resource Data Covered: No

Do you agree to cooperate and comply with the European Data Protection Authorities? Yes

Certification Status: Current
Compliance Status:

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