Zubr Communications Policies - Privacy Policy

Zubr Communications utilizes the following internal Privacy Policy in handling the Personal Information of its Customers.

The text of the policy is accurate and current as of April 15, 2010.

This document defines the Privacy Policy that applies to the services of Zubr Communications, L.L.C. ("Zubrcom"). The following describes how Zubr Communications treats Personal Information that it collects and receives, including information related to Customer's past use of Zubr Communications products and services. This policy is to ensure the privacy of Zubrcom's Customers. This policy does not apply to the practices of companies that Zubr Communications does not own or control, or people that Zubrcom does not employ or manage. 1. Personal Information. For the purpose of this document, Personal Information is information about Customer that is personally identifiable i.e., Customer's name, address, telephone number, email address, etc., and that is not otherwise publically available. 2. Collection of Personal Information. Zubr Communications collects Personal Information when during registration to use Zubr Communications' products or services, during utilization of products or services or at any other time when the Customer provides information to the Zubr Communications. Zubr Communications may collate information that it collects with the information Zubr Communications obtains from other sources, including but not limited to, Zubrcom's business partners or other companies. The following describes how such information is collected: a. Registration Upon registration to use Zubr Communications' products or services, Zubr Communications may ask for certain Personal Information of the applicant, including but not limited to, information such as one's name, address, zip code, country, telephone number and email address(es) for service activation or billing purposes. b. Establishment of Credit Terms If a Customer seeks to establish credit terms for the products or services provided by Zubr Communications, Zubr Communications may request applicant's SSN, EIN or D&B number in order to determine if Zubr Communications can extend credit terms based on applicant's creditworthiness. c. Accessing Zubr Communications web, mail, SFTP, FTP and other services All Zubr Communications servers, including but not limited to web, mail, SFTP, FTP and other servers and the devices that provide one with ability to interact with such devices over the network may and typically do collect certain information about the incoming connections including but not limited to IP address requesting a connection, date and time of the connection, the nature of the connection and some additional technical details pertaining to the connection. 3. Usage of the Personal Information. Zubr Communications routinely uses the collected Personal Information pertaining to Zubr Communications' Customers to provide the service(s) requested by the Customer. If necessary, for the purpose of carrying out collection activities on past-due accounts, Zubrcom may disclose the Personal Information about the Customer associated a past due account to parties involved in collection activities. 4. Personal Information Disclosure Process. Zubr Communications does not rent, sell, or share Personal Information with third parties except when necessary to provide product(s) or service(s) that Customer has requested, or when Zubr Communications has Customer's permission, or under the following circumstances: a. Zubr Communications responds to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claim; Zubr Communications believes it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Zubr Communications Acceptable Usage Policy, or as otherwise may be required by law. b. Zubr Communications transfers Personal Information about Customers if Zubr Communications is acquired by or merged with another company. In such event, Zubr Communications will notify its Customers before Personal Information about the Customers is transferred and becomes subject to a different Privacy Policy. 5. Protection of The Information Collected. a. Employees and contractors who at the discretion of Zubrcom must come into contact with Customer's Personal Information in the course of providing the Customer with the requested products or services have such access strictly limited by Zubr Communications. b. Zubr Communications has physical, electronic, and procedural safeguards to protect Personal Information about its Customers. 6. Changes to Zubr Communications Privacy Policy. Zubr Communications may make changes to the Privacy Policy as we deem necessary. If and when this Privacy Policy does change, Zubr Communications will attempt to notify its Customers via electronic mail sent to the primary email address on file for the Customer. In addition, Zubr Communications will publishing the new Privacy Policy on its website.

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