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Copyright © FREEDOM4 2007-2008. All rights reserved.

1. Introduction The purpose of this policy is to explain how FREEDOM4 collects, protects, and uses personal data. FREEDOM4 is committed to ensuring that any personal data supplied by its customers or is otherwise generated by its business activities is collected and processed fairly and lawfully.

2. What Types Of Personal Data Does FREEDOM4 Collect? FREEDOM4 needs certain personal data to enable it to provide its products and services to its customers and end users. The personal data collected will generally include: company name, company size and sector, individual contact names and job titles for delivery, installation, support and billing, postal address, telephone and fax numbers, e-mail addresses.FREEDOM4 also has access to personal data that is generated over the Network utilised by FREEDOM4services including IP and email addresses for incoming and outgoing data and network usage data. In certain circumstances FREEDOM4 may also collect financial information about FREEDOM4 customers and end users from third parties to enable FREEDOM4 to assess its risks in granting credit terms and contact information about organisations FREEDOM4 considers may be interested in FREEDOM4 products and services.

3. How Does FREEDOM4 Obtain Personal Data? FREEDOM4 obtains personal data in a number of ways including from orders placed by customers and end users (whether by telephone, fax or email or by application form); from enquiries made by existing customers and potential customers, (including information gathered at marketing events and via the FREEDOM4 website); from third party list brokers; from resellers who pass on personal data to FREEDOM4 about end users; and directly from the Network utilised by FREEDOM4 services.

4. How Does FREEDOM4 Use The Personal Data It Holds? 4.1 Providing and Improving the FREEDOM4 Service Most of FREEDOM4's use of personal data is necessary to enable it to provide a service to its customers and its end users, including order processing, delivery, installation and support services as well as for invoicing and in order to answer general customer enquiries. In addition, FREEDOM4 may also use personal data to improve on the level and type of service FREEDOM4 offers to its customers. As part of this interest in improving the service provided FREEDOM4 may process personal data for the purposes of sales analysis and customer usage statistics.

4.2 Direct Marketing FREEDOM4 may from time to time inform its customers, end users and potential customers about FREEDOM4 and FREEDOM4 affiliate products and services and other information FREEDOM4 feels may be of interest.

Customers and other recipients of information from FREEDOM4 may indicate at the time they first place an order with FREEDOM4 whether or not they wish to receive such information or at any later time by simply contacting FREEDOM4 as indicated in paragraph 9 below.

5. Does FREEDOM4 Transfer Personal Data Overseas? As FREEDOM4 is part of a global organisation with local operating companies in a number of countries worldwide, to fulfil its customer service obligations it is necessary for FREEDOM4 to transfer and process personal data outside the country in which the personal data is collected. This will include transfers to FREEDOM4 affiliates based in the United States. Prior to making any such transfer FREEDOM4 will put in place security procedures and firewalls designed to prevent unauthorised use of or access to personal data.

6. To Whom Does FREEDOM4 Disclose Personal Data? FREEDOM4 will pass personal data within its internal departments in order to fulfil sales and support obligations as well as to finance departments to enable invoicing.

As a general rule, FREEDOM4 does not disclose personal data to unaffiliated third parties except where customer consent has been obtained, where FREEDOM4 is under an obligation by law to disclose personal data or where FREEDOM4 has contracted with third parties to assist in providing services to FREEDOM4 customers such as for delivery, installation and systems support services.

7. How Does FREEDOM4 Protect the Personal Data it Holds? FREEDOM4 takes customer confidentiality and security very seriously. FREEDOM4 has implemented appropriate internal security procedures that restrict access to and disclosure of personal data within FREEDOM4. These procedures will be reviewed from time to time to determine whether they are being complied with and are effective.

8. Customers' Rights The law in certain jurisdictions (including countries within the European Economic Area) gives individuals whose personal data is held by FREEDOM4 specific rights to access and rectify personal data held about them. These include the right to:

8.1 obtain from FREEDOM4, for a prescribed fee, confirmation that personal data is held, as well as a written description of such personal data, the purpose(s) for which it is being used, the source(s) of the personal data and details of any recipients;

8.2 request the deletion or rectification of personal data which is inaccurate; and

8.3 as explained in paragraph 4.2 above to object to any unsolicited information sent by FREEDOM4 regarding promotions or new products and services.

9. Contact Details If any individual wishes to contact FREEDOM4 regarding the personal data held about them or has any other question about FREEDOM4's data privacy procedures, they should direct an email to privacy@freedom4.com or send a letter to the direction of "FREEDOM4 Customer Services Department" at the local FREEDOM4 office.

10. Policy Updates As part of FREEDOM4's commitment to compliance with data privacy requirements, and to reflect changes in FREEDOM4's operating procedures, FREEDOM4 may update the terms of this policy from time to time, and will post the revised policy here.