Safe Harbor Policy

SAFE HARBOR PRIVACY POLICY OF SHORTSTACK.COM

To view our Safe Harbor certification, please visit safeharbor.export.gov

This Safe Harbor Privacy Policy of ShortStack.com (the “Safe Harbor Policy”) is hereby made effective as of October 1, 2012, by Pancake Laboratories, Inc., a Nevada corporation (“Pancake”). Pancake respects individual privacy and values the confidence of its customers, employees, consumers, business partners and others. Pancake strives to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business, and prides itself on upholding the highest ethical standards in its business practices. To learn more about Pancake’s general privacy policies and practices, the current Privacy Policy of ShortStack.com can be reviewed here.

This Safe Harbor Policy sets forth the privacy principles that Pancake follows with respect to personal information transferred from the European Union (the “EU”), European Economic Area (the “EEA”), and Switzerland to the United States.

Safe Harbor

The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions to enable U.S. companies to satisfy the requirement under EU law that adequate protection be given to personal information transferred from the EEA to the United States (the “U.S.-EU Safe Harbor”). The EEA also has recognized the U.S.-EU Safe Harbor as providing adequate data protection (OJ L 45, 15.2.2001, p.47). The United States Department of Commerce and the Federal Data Protection and Information Commissioner of Switzerland have agreed on a similar set of principles and frequently asked questions 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 (the “U.S.-Swiss Safe Harbor”). Consistent with its commitment to protect personal privacy, Pancake adheres to the principles set forth in the U.S.-EU Safe Harbor and the U.S.-Swiss Safe Harbor (the “Safe Harbor Principles”). To learn more about the Safe Harbor program, and to view Pancake’s certification, please visit http://www.export.gov/safeharbor.

Scope

This Safe Harbor Policy applies to all personal information received by Pancake in the United States from the EU, EEA and Switzerland, in any format including electronic, written or verbal.

Definitions

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

“Agent” means any third party that collects or uses personal information under the instructions of, and solely for, Pancake or to which Pancake discloses personal information for use on Pancake’s behalf.

“Customer” means any customer, client or subscriber of Pancake that collects Personal Information, including Sensitive Personal Information, by, though or by means of ShortStack, and which information may be, directly or indirectly, provided or available to Pancake.

“Pancake” or “We” means Pancake Laboratories, Inc., a Nevada corporation, and each of its predecessors, successors or affiliates.

“Personal Information” means any information or set of information that identifies or could be used by or on behalf of Pancake to identify an individual. Personal information does not include information that is obfuscated, anonymous or encoded, or publicly available information that has not been combined with non-public personal information. “Sensitive” means Personal Information that Personal Information related to race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership, or data concerning health or sex life, or information on criminal activity or proceedings. In addition, Pancake will treat as Sensitive Personal Information any information received from a Customer where that Customer treats such information as Sensitive, and notifies Pancake and identifies such information to Pancake as Sensitive. “ShortStack” means ShortStack.com, the application embodied therein, and all related content, materials and services.

Safe Harbor Principles

Notice Where Pancake 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, the types of non-Agent Third Parties to which Pancake discloses that information, the choices and means, if any, Pancake offers individuals for limiting the use and disclosure of Personal Information about them, and how to contact Pancake with any inquiries or complaints. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Information to Pancake, or as soon as practicable thereafter, and in any event before Pancake uses or discloses the information for a purpose other than that for which it was originally collected.

Where Pancake receives Personal Information from Customers or other entities in the EEA, it will use and disclose such information in accordance with the notices provided by such Customer or entity and the choices made by the individuals to whom such Personal Information relates. Pancake does not review the privacy policies and practices of its Customers, and is not responsible for such policies or practices or their compliance or non-compliance with the Safe Harbor Principles, regardless of whether ShortStack is used by such Customer in its collection of Personal Information.

Choice For Personal Information collected by Pancake, Pancake will offer individuals the opportunity to choose (opt-out) whether their Personal Information may be (a) disclosed to a non-Agent Third Party, or (b) used for a purpose other than the purpose for which it was originally collected by Pancake or otherwise authorized by the individual.

For Sensitive Personal Information collected by Pancake, Pancake will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of such information to a non-Agent Third Party or the use of such information for a purpose other than the purpose for which it was originally collected or otherwise authorized by the individual.

Pancake will provide individuals with reasonable mechanisms to exercise the foregoing choices.

Onward Transfer (Transfers to Third Parties) Prior to Pancake disclosing Personal Information to a non-Agent Third Party, Pancake will notify the individual of such disclosure and allow the individual the choice (opt out) of such disclosure. Pancake will ensure that any non-Agent Third Party to which Personal Information may be disclosed subscribes to the Safe Harbor Principles or are subject to law providing the same level of privacy protection as is required by the Safe Harbor Principles and agrees to provide a commercially reasonable level of privacy protection.

Access Upon request, Pancake will grant individuals reasonable access to the Personal Information collected by Pancake that it holds about such individual. In addition, Pancake will take reasonable steps to permit individuals to correct, amend, or delete their Personal Information, or any portion thereof, that is collected by Pancake and which is demonstrated to Pancake’s satisfaction to be inaccurate.

Security Pancake will take commercially reasonable precautions to protect Personal Information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

Data Integrity Pancake will collect Personal Information and will use such information only in ways that are relevant to the purposes for which it was collected or subsequently authorized by the individual. Pancake will take reasonable steps to ensure that Personal Information is reliable for its intended use, accurate, complete, and current.

Enforcement Pancake uses a self-assessment approach to ensure its compliance with this Safe Harbor Policy and will conduct compliance audits of its relevant privacy practices to verify adherence to this Safe Harbor Policy. Any employee that Pancake determines is in violation of this Safe Harbor Policy will be subject to disciplinary action up to and including termination of employment.

Dispute Resolution

In compliance with the Safe Harbor Principles, Pancake commits to resolve complaints about privacy and its collection or use of Personal Information. Any questions or concerns regarding the use or disclosure of Personal Information should be first directed to Pancake at the address given below. Pancake will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information by reference to the principles contained in this Safe Harbor Policy. If Pancake is unable to resolve your dispute to your reasonable satisfaction, Pancake has selected the American Arbitration Association (www.adr.org) to serve as its independent recourse mechanism for the resolution of any unresolved disputes under the Safe Harbor Principles that are not resolved by Pancake internally.

Contact Information

Questions or comments regarding this Safe Harbor Policy should be submitted to Pancake by mail or electronic mail (with copy by mail) to the following address:

Pancake Laboratories, Inc. Attn: Legal Department 201 West Liberty Street, Suite LL1 Reno, Nevada 89501

contact@shortstacklab.com

Changes To This Safe Harbor Policy

This Safe Harbor Policy may be amended by Pancake, in its sole discretion from time to time, consistent with the requirements of the Safe Harbor Principles. A notice will be posted on ShortStack upon any such amendment.

Information Subject to Other Policies

Pancake is committed to following the Safe Harbor Principles for all Personal Information within the scope of the Safe Harbor Principles. However, certain information is subject to policies of Pancake that may differ in some respects from the general policies set forth in this Safe Harbor Policy.

Any questions on this Policy or the privacy practices of Pancake or ShortStack should be directed to contact@shortstacklab.com.

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