Privacy Policy

LAST REVISED: February 28, 2007 Dick Wray

We recognize that you have an interest in how we collect, retain and use information about you. Wray Executive Search has created this Privacy Policy statement in order to demonstrate and communicate our commitment to doing business with the highest ethical standards and appropriate internal controls.

To contact Wray Executive Search about privacy issues, to report a violation of our Privacy Policy or to raise any other issue, please e-mail us at dick.wray@dickwray.com. This Policy is the sole authorized statement of Dick Wray’s practices with respect to the online and off-line collection of personally identifiable information through the site or our authorized consultants and the usage of such information. Any summaries of this Policy generated by third-party software or otherwise, shall have no legal effect, are in no way binding upon Dick Wray, shall not be relied upon in substitute for this Policy, and neither supersede nor modify this Policy.

Our Executive Search Services

Wray Executive Search is a leading provider of executive human capital solutions, providing a range of services including executive search and middle-management recruitment (collectively, our Search Service). Please review the information in Services for a complete description of our services, or contact us for additional information.

The Information We Collect

Wray Executive Search collects personally identifiable information (that is, information from which an individual can be identified, such as full name, e-mail address and physical address) and other information that visitors to the site choose to provide to us, for example, when registering as a candidate for our Search Services, when uploading or building a resume, in responding to employment opportunities posted on the site, when taking assessment tests or when contacting us via e-mail. We also collect information from our clients and others in the course of the various Search Services that we provide, as well as by conducting research using the Internet and other resources. We do not knowingly collect personally identifiable information from children (that is, minors younger than eighteen years of age).

How We Use and Disclose t he Information We Collect

We generally use the information we collect for the purposes for which it is provided and to enhance our Search Services. The following paragraphs describe various specific ways in which we may use personally identifiable and other information. These descriptions are examples and should not be considered as a complete list of the ways in which we may use or disclose information we have collected.

Information Concerning Candidates

• Identifying positions of interest. We use information that we have collected concerning candidates to identify professional opportunities that we think may be of interest. We may contact potential candidates from time to time regarding such opportunities.

• Providing data to clients and references. We generally provide personally identifiable information regarding candidates to prospective employers or reference sources only if the candidate has requested or otherwise consented that we do so. However, on rare occasions we are engaged to conduct highly confidential searches for senior executives, and on those rare occasions, prospective candidates’ information may be provided to the client without the candidates’ prior request or knowledge. In addition, through our Board Search Services practice, we recruit senior-level individuals with broad ranges of experience to become board members for selected clients. When Dick Wray is retained in connection with a search for a client’s board of directors, it is possible that information may be provided to the client without the candidate’s prior request or knowledge.

• Soliciting information regarding candidates. We may contact individuals from time to time to solicit names of or other information regarding potential candidates in connection with a search that we are conducting.

• Refining our Search Services. We may use information we collect concerning candidates for purposes of developing and improving our Search Services, and for purposes of collecting and disclosing diversity statistics and other statistical information regarding our candidates and placement activities.

• Search service announcements. We may periodically send registered candidate users Web site update information and service announcement updates via e-mail. Because these announcements contain important information about search services, as long as you remain a registered user you will not be able to unsubscribe from these announcements.

Client Data

We collect information pertaining to our clients, including business contact information, and retain and use such information in providing our Search Services. We may contact you from time to time regarding your needs and the services we provide.

Other Uses of Information

• Access to your data. You have complete access to your profile on the the site via your user name and password to manage your information. An indivdual may remove his or her profile and resume via the site or by contacting Dick Wray at dick.wray@dickwray.com.

• Updating your data. We may contact you from time to time to ensure that the information we have collected about you is accurate and current. You can also to manage your personal information via the site to make changes, additions and amendments to keep your profile accurate and current.

• Responding to inquiries. If you contact us by e-mail through the site, we may keep a record of your contact information and correspondence, and we may use any information you provide in your message to respond to your inquiry.

• Other communications. From time to time Wray Executive Search may send informational or promotional e-mails concerning its Search Services.

• Disclosure to service providers. Wray Executive Search works with third parties who provide services that may include, but may not be limited to, assessment services, including assessment validation services, Web site hosting, data analysis, resume verification, background checking and other administrative and backup and security services. We reserve the right to share personally identifiable and other information with such third parties for the purpose of providing their services. In addition, our software development partners may use such information for purposes of modifying, improving, refining or validating their technology, research and development.

• Disclosure to affiliates. We share the information we collect with our affiliated companies and we may share the information with our strategic partners.

• Compliance; emergencies. Subject to applicable law, we reserve the right to use and release any information that we have collected when we believe in good faith that the law requires it, that unlawful activity may have taken place, to enforce our other policies or published guidelines, to protect the rights, property, safety or security of Wray Executive Search, our visitors or the public, or to respond to an emergency.

Use of Data by Clients and Others

We cannot and do not assume any responsibility for the actions or omissions of third parties, such as clients, service providers or strategic partners, including the manner in which they use information received either from Dick Wray or from other independent sources. The site may contain links to other Web sites, including co-branded or other affiliated sites which may or may not be owned or operated by Dick Wray. Unless otherwise expressly stated, we are not responsible for the privacy practices or content of such Web sites, including such sites’ use of any information collected through cookies or other technologies when visitors to our site click on links to those sites. You should review the privacy policies associated with such sites to understand how their operators collect and use information. THIS POLICY DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES.

Tracking Data

Dick Wray monitors visitor traffic patterns throughout the site by logging tracking data, which is collected automatically from each site visitor. Tracking data may include information such as the IP address of the visitor’s computer, its browser type and operating system, the referring site, which pages of the site were visited, the order in which they were visited and which hyperlinks were clicked. Dick Wray uses tracking data and other non-personally identifiable information in aggregate form to perform statistical analyses of the collective characteristics and behavior of our visitors, and by measuring demographics and interests regarding specific areas of the site. We may provide this information to affiliates, current and potential clients, and other business partners.

Cookies

We use “cookies”—that is, small text files placed on a visitor’s hard drive—and other technologies to help us determine information such as the type of content a visitor to the site links to, and the length of time each visitor spends at any particular area of the site. In addition, if you register as a member of the Site, you have the option of requesting that we save your login ID and password so that you don’t have to reenter that information when you revisit the site—this function is accomplished using a cookie. Dick Wray cookies are read only by Dick Wray servers and are unable to execute any code or virus. You can configure your browser to accept all cookies, reject all cookies or notify you when a cookie is set. (Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences.) If you reject all cookies, you will not be able to use those services that require you to sign in. Please note that you should activate only the “Save ID & Password” feature on the site if you are the exclusive user of your computer. The use of this feature entails saving your login ID and password in a cookie placed on your computer; thus, anyone who uses your computer may be able to access your Dick Wray account without your permission. You may turn off the “Save ID & Password” feature at any time by deselecting this option on the login page.

Changing or Deleting Personal Information

You may change information that you have provided on the site (for example, through the candidate profile features) by following the posted instructions. If you would like to have your information removed from the Dick Wray database, please contact us at dick.wray@dickwray.com, put “Remove User“ in the subject line of the e-mail, and include your full name, user ID and telephone number in the body of the message. We will make a reasonable effort to comply with your request. (We may need to contact you to be sure that we are deleting the appropriate information.) Please keep in mind that residual information will remain within Dick Wray databases, access logs and other records, which may or may not contain your personally identifiable information. The residual information will not be used for commercial purposes; however, Dick Wray reserves the right to recontact former users of our Search Services from time to time.

Executive Connection E-news

Dick Wray offers registered users the Executive Connection (the “E-news”) via e-mail on a regular basis along with other timely e-mails about the restaurant and foodservice industry, upcoming events, job opportunities or other items of interest.

Registration to the E-news

Registration to the e-news is independent of registration as a Dick Wray candidate. If you wish to unsubscribe from an e-newsletter and not receive any further e-mail notices from Dick Wray, please follow the directions at the bottom of the e-newsletter and or e-mail notice and you will be permanently taken off the recipient list. This does not change the status of your registration as a candidate. Nor does registration to the e-news qualify as registration as a candidate. We have a firm commitment to not send unwanted or unsolicited e-mail.

Surveys and Contests

From time to time, the Web site will request information from you via surveys or contests. Participation in these surveys or contests is voluntary, and you choose whether to disclose any information. These surveys and contests are not limited to registered users. Contact information and demographic information may be requested. Contact information will be used to notify and award winners. Survey information will be used for purposes of monitoring, improving or enhancing the use and satisfaction of the Web site or gathering general information on the nature of the restaurant and foodservice industry.

Additional Guidelines

Dick Wray may from time to time sponsor special features or promotions on the site and additional privacy information may be posted. That privacy information, to the extent that it conflicts with this Policy, will govern that particular feature or promotion.

Security

Dick Wray has security measures in place to protect against the loss, misuse and alteration of visitor information which is under our control. Unfortunately, however, no security system or system of transmitting data over the Internet can be guaranteed to be 100 percent secure. As a result, while we strive to protect your personally identifiable information, we cannot guarantee the security of our servers, the means by which information is transmitted between your computer and Dick Wray’s servers, or any information provided to us or to any third party through or in connection with the Site.

Business Transfers

Dick Wray reserves the right to transfer, without your further consent, any and all information that we collect from visitors, or that we otherwise collect concerning the Site, to a third party in connection with a strategic alliance with such third party, or in the event of a sale of our company or one of our affiliates, a merger or consolidation involving Dick Wray or one of its affiliates, or a sale or transfer of assets of any portion of our business or the business of one or more of our affiliates.

Questions?

Questions regarding this Policy should be directed to Dick Wray at dick.wray@dickwray.com Dick Wray Executive Search, 3123 Hannan Lane, Soquel, CA 95073, Attn: Dick Wray.