Plenish and Pioneer Global Information Privacy Policy

I. We respect the privacy rights of individuals. Pioneer will respect the legal requirements that exist regarding the privacy of Personal Information and is committed to complying with all applicable law. Pioneer will, from time to time, review its Personal Information collection, use and disclosure practices in order to assure compliance with laws and regulations.

II. We give notice of all Personal Information collection. Pioneer will give notice when Personal Information is collected or when any collected information is later to be provided to third parties. All notices will explain the need for the information and describe how the information will be used. Personal Information will not be used to directly market any products or services to identifiable persons unless that possibility has been disclosed in advance and the opportunity not to participate has been given.

III. We explain the consequences of collecting and processing. Pioneer will state the consequences of any decision by individuals not to provide Personal Information requested by Pioneer.

IV. We get explicit consent for sensitive information/opt-in. Pioneer will maintain procedures to assure that sensitive information is only collected with explicit consent and is protected against improper use, consistent with applicable law.

V. We process and distribute information consistent with notice. Pioneer will collect and use Personal Information consistently with the notices that have been provided. However, Pioneer may decide to remove identifiable features from collected Personal Information and the resulting information may then be used for statistical, historic, scientific or other purposes, consistent with applicable law.

VI. We provide information security. Pioneer will maintain the security of Personal Information, and protect the integrity of such information with a commercially reasonable degree of care.

VII. We provide individuals a way to access and correct their information. Pioneer will maintain procedures consistent with applicable law for individuals to gain access to their collected Personal Information and, when appropriate, correct any information that is inaccurate or incomplete, change their individual consent level, or have their Personal Information deleted.

VIII. We require others who process Pioneer data to comply with the Pioneer policy. Pioneer will contractually require others who acquire or provide Personal Information from or to Pioneer, including those engaged to provide support services, at a minimum to comply with the principles and objectives of this policy.

IX. We provide a way to process complaints. Pioneer will publish the procedures for responding to complaints, questions and enquiries regarding its established procedures for protecting Personal Information.

X. We will disclose Personal Information when required by Law or court order. Pioneer will, under certain circumstances permitted or required by law or court order, collect, use, and/or disclose Personal Information pursuant to procedures that do not require giving notice or conducting related activities (for example, in connection with law enforcement investigations).

XI. We will align our Human Resource processes with the Pioneer policy. Pioneer will align its Human Resources processes, policies, practices, and guidelines (for information that is collected or used relating to former, current, or prospective employees) to comply with this Policy.

XII. We retain the flexibility to change this policy. Pioneer will, and reserves the right to, modify and update this policy or its related business practices at any time. Pioneer will NOT apply changes to this Policy retroactively to information Pioneer has previously collected.

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