Catalina Marketing Privacy Policy

Catalina Marketing Corporation is dedicated to providing behavior-based targeted marketing services that improve the businesses of both consumer goods manufacturers and retailers, while simultaneously providing real value to consumers. While Catalina Marketing uses technology to deliver one-to-one marketing programs, we have a sincere regard and concern for protecting the privacy of the information about our clients' consumers.

We will never release identifying customer information that is provided to us by the retailer without written approval from the consumer and the retailer. Likewise, our participating retailer partners will not jeopardize their customers' privacy by selling or releasing information obtained from loyalty card applications and/or collected from purchase behavior without the customer's permission. We remain in compliance with all legislation, domestically and internationally, that deals with the protection of privacy for the consumer.

TO VIEW THE PRIVACY POLICY FOR A SPECIFIC DIVISION CLICK BELOW:

CATALINA MARKETING SERVICES
Catalina Marketing Services provide our clients with a variety of programs that deliver targeted communications and incentives to consumers in-store. These communications and incentives are most often based on consumer purchase behavior, both present and historical. The information we use to define individual consumer purchase behavior is processed only by individual product UPC, by shopping order size or by a retailer-issued loyalty card number. No individual consumer identifying information is used for the collection of consumer purchase behavior.

The information regarding consumer past purchase history relies on access to retailer data based on a retailer-issued loyalty card number or other identifying card number for a particular household. Catalina Marketing does not use information such as names or addresses for the collection of consumer purchase behavior information. While the retailer maintains identifying information about their customers, that information is never sold to any outside businesses. In addition, we urge all of our retail partners to offer their loyalty card customers the option to opt-out of any data collection activities. This option is to be provided to the consumer in clear language and readable type.

CATALINA MARKETING INTERNATIONAL
The programs offered through our international division are very similar to those provided by Catalina Marketing Services. They fall under the same stringent guidelines and standards to protect consumer privacy. All operations in France, Italy, Germany and the United Kingdom and Japan have been examined to ensure that the privacy of our international consumers is protected.

CATALINA HEALTH RESOURCE
Protection of patient privacy is not, and never will be, a matter for debate within CHR. The trust placed in us by patients and pharmacists is our greatest asset, and not something we will ever place in jeopardy. Catalina Health Resource (CHR) programs are compliant with the federal Privacy Rule, implementing the Health Insurance Portability and Accountability Act of 1996 ("HIPAA"). (The Privacy Rule is the primary federal law that protects patient privacy).

We do understand, however, that the powerful data management capabilities which CHR has built can make a person wonder about what information we "see" as we help their pharmacist fill their prescriptions. We hope this page answers those questions.

CHR does not see or take possession of any information that would allow us to personally identify a patient. CHR carries out its programs without having access to that information by using a filtering and encryption process that resides on the pharmacy's "side" of the information transaction. Before any information is transmitted to CHR, the process removes all information that might be used to identify a particular person, and replaces it with a number that is unique to that particular file of information. It is that number, rather than the identity of the individual, that is used to create messages and select patients that match those messages. The individual's name, address, social security number — even the patient's home zip code -- all stay on the pharmacy side of this filtering process and cannot pass through to the CHR side of the transaction. Once identifying information is completely filtered out from a record, the information remaining in the file is used to create a communication that patients will find useful, relevant, and helpful. To further protect the patient's privacy, CHR does not possess the ability to "reverse" this process. Once the pharmacy has removed the personally identifiable information and then assigned the unique number to the information file, it cannot be restored by anyone in CHR. CHR's processes have been reviewed by an independent HIPAA-compliance auditor, which has certified that CHR does not receive individually identifiable information (or information that can be used to identify an individual) from any of its partner pharmacies. Finally, CHR does not keep any information that would allow the company or any message sponsor to identify a patient after the transaction, nor does CHR sell names or maintain a database of patient-identifiable information. In fact, we could not contact a patient outside of the pharmacy, even if we wanted to, since the necessary personal information is not available to us. CHR is proud to have developed a system that allows us to provide important and relevant health information to consumers in a way that does not violate the patient's right to privacy.

PRIVACY POLICY RESTATED
Our retailer partners have built a sacred trust with their customers, and we, in turn, have developed that same trust with our retailers. We have made and will continue to make a sincere effort to ensure that our consumers' privacy is protected. We have no intention of using or processing the information collected through our retailers in such a way that violates a consumer's right to privacy.

All of our programs are designed to provide value that is relevant to a consumer or household. We will continue to ensure that consumer privacy remains an important component to all of our programs, by evaluating our processes and developing the appropriate guidelines and counsel for our retail and manufacturer partners.

SAFE HARBOR PRIVACY POLICY
Catalina Marketing Corporation is a participant in the Safe Harbor program developed by the U.S. Department of Commerce and the European Union. We have certified that we adhere to the Safe Harbor Privacy Principles with regard to our use of certain personal data. Our Safe Harbor Privacy Policy for HR Personal Data is located here. For more information about the Safe Harbor and to view our certification, visit the U.S. Department of Commerce's Safe Harbor Web site (http://www.export.gov/safeharbor/).