Xnet Communications Privacy Statement

General Information

Xnet respects the privacy of our customers, business partners and employees. We recognize the need for appropriate protections and management of your personal information that you provide to us. Xnet has therefore established this Privacy Statement to assist you to understand what information we collect and how that information is used. This Privacy Statement applies to Xnet Communications.

Safe Harbor Compliance

Xnet's privacy practices are in compliance with the U.S. and E.U. Safe Harbor principles. Information about the U.S. Department of Commerce Safe Harbor certification can be found at www.export.gov/safeharbor.

What personal information does Xnet collect?

Personal Information is information that can be used to identify or contact a specific individual, such as a name, address, telephone number or email address. Xnet may collect certain personal information from customers, business partners, employees and candidates for employment. Xnet does not collect personal information when you visit Xnet's web sites unless you choose to provide such personal information.

On Xnet web sites you can order products or services, register products, request information, subscribe to marketing or support materials, register to a secure extranet site to obtain access to product information, support, and services. The types of personal information you provide to us on these pages may include name, address, phone number, e-mail address, user IDs and passwords, billing and transaction information, credit card or other financial information and contact preferences.

How does XNET use personal information?

Xnet will use personal information to provide customers and business partners with information and services and to help us better understand your needs and interests. Specifically, we use your information to help you complete a transaction or order, to communicate with you, to deliver products/services to you, to bill you for products/services you purchased, and to provide ongoing service and support. Occasionally we may use your information to contact you to complete surveys that we use for marketing and quality assurance purposes. Personal information collected online may be combined with information you provide to Xnet through other sources such as trade shows or seminars.

To the extent that Xnet uses personal information to email you about our product and services, Xnet's email practices are in compliance with the U.S. and E.U. SPAM laws. Information about the U.S. and E.U. SPAM laws can be found at http://www.spamlaws.com/.

With whom does Xnet share personal information?

Xnet contracts with third party service providers and suppliers to deliver complete products, services and customer solutions. Xnet may share personal information with its service providers and suppliers for the sole purpose and only to the extent needed to support the customers' business needs. Service providers and suppliers are required to keep confidential the personal information received from XNET and may not use it for any purpose other than as originally intended.

Third parties receiving personal information are expected to apply the same level of privacy protection as contained in this Privacy Statement.

Except as provided above, Xnet will not share personal information with any other third parties without your permission, unless required by, or in connection with, law enforcement action, subpoena or other litigation, or applicable law.

Xnet will not sell, trade or lease your personal information to others.

Choice & Consent

Xnet does not require that you provide Xnet with personal information. The decision to provide personal information is voluntary. If you do not wish to provide the personal information requested, however, you may not be able to proceed with the activity or receive the benefit for which the personal information is being requested.

Except as expressly stated otherwise in this Privacy Statement, you may opt out of having Xnet share personal information with third parties as described in this Privacy Statement by notifying Xnet in writing of your desire to do so.

Sensitive Information

Sensitive information is defined as personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or information specifying the sex life of the individual.

Except as provided below, Xnet does not request or receive sensitive information from visitors to our web sites.

Access to and accuracy of your information

Xnet strives to keep your personal information accurate. We have implemented technology, management processes and policies to maintain data accuracy. We will provide you with access to your information, including making reasonable effort to provide you with online access and the opportunity to change your information. To protect your privacy and security, we will also take reasonable steps to verify your identity, such as a password and user ID, before granting access to your data.

Xnet will not process personal information in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by the individual, as required by applicable law.

Security of Personal Information

Xnet is committed to taking reasonable efforts to secure the personal data you choose to provide us. To protect the privacy of any personal information you may have provided, Xnet employs industry-standard controls including physical access controls, Internet firewalls, intrusion detection, and network monitoring. In addition, access to sensitive data as defined in this Statement is limited to those individuals and agents having a need to know.

Other Information/Logging and Cookies

Xnet collects and/or logs Internet Protocol addresses, Internet domain names, the web browser and operating system used to access the Xnet web site, the files visited, the time spent in each file, and the time and date of each visit.

Xnet also uses cookies on some of its web sites. Cookies are identifiers that can be sent from a web site via your browser to be placed on your computers hard drive. Thereafter when you visit a web site, a message is sent back to the web server by the browser accessing the web site. You may elect not to accept cookies by changing the designated settings on your web browser. However, not utilizing cookies may prevent you from using certain functions and features of web sites. The information collected from the use of cookies is used and analyzed to improve Xnet's web sites.

You can set your browser to notify you when you are sent a cookie, giving you the chance to decide whether or not to accept it. The information we collect and analyze is used to improve our service to you and personalize your web-browsing experience.

Links to Third Party Sites

This Web site may contain links to Web Sites controlled by third parties. Xnet provides these links merely as a convenience and has no influence on the contents of these websites. No guarantee can therefore be given in relation to the contents of other websites. The party responsible for the contents of the linked pages is always the provider in question or the operator of the website. At the time when these links were created an assessment was carried out as to whether the websites in question might possibly contain illegal contents. No such contents were found. However, Xnet cannot be reasonably expected to maintain constant surveillance over the contents of the individual links without any concrete grounds to suspect that they contain illegal contents. If Xnet becomes aware of such illegal contents, the links in question will be removed immediately.Access to other Web sites is at your own risk and Xnet is not responsible for and does not endorse or accept any responsibility over the content or use of those Web Sites.

Verification

Xnet will engage in periodic self-assessment to verify that it continues to be in compliance with this Privacy Statement.

Contact Information

If you have any questions regarding the Privacy Statement or believe that the privacy of your personal information has not been respected, you may submit a complaint in writing to the attention of.

Xnet Communications, Stresemannstr. 375, 22761 Hamburg, Germany.

Changes to this Statement

Xnet will review and update this Statement periodically.