THIRTY-ONE GIFTS LLC

• •Retained Kroll Inc. to conduct a thorough investigation of the incident and to prepare a report, which was provided to the Federal Bureau of Investigation to assist it in its efforts.
• •All affected Consultants and employees will be offered, without charge, one year of enrollment in Kroll's ID TheftSmart service.
• •A toll-free telephone number will be established where affected Consultants and employees can obtain more information.
• •Engaged Internet Security Advisors Group to conduct a complete assessment of Thirty-One's systems and policies and to provide recommendations for improvement.
• •Licensed the Party Plan software source code in order to exercise better control over its security features.
• •Hired an expert in payment card industry and information security procedures as a full-time employee in Thirty-One's Information Technology Department.
• •Strengthened its policies regarding system access rights to ensure that personal information may only be accessed by persons who have a legitimate business use for that information.
• •Providing training to Thirty-One consultants regarding current best practices for handling credit card information.

• •Licensed the Party Plan software source code in order to exercise better control over its security features.
• •Hired an expert in payment card industry and information security procedures as a full-time employee in Thirty-One's Information Technology Department.
• •Strengthened its policies regarding system access rights to ensure that personal information may only be accessed by persons who have a legitimate business use for that information.
• •Providing training to Thirty-One consultants regarding current best practices for handling credit card information.

DisclosureLens links to the originating regulator URL — full filing bodies are not redistributed from public surfaces (§4.5).