Data Protection and Privacy Policy

1. Introduction
The purpose of this policy is to explain how Pipex collects, protects, and uses personal data. Pipex 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 Pipex Collect?
Pipex 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. Pipex also has access to personal data that is generated over the Network utilised by Pipex services including IP and email addresses for incoming and outgoing data and network usage data. In certain circumstances Pipex may also collect financial information about Pipex customers and end users from third parties to enable Pipex to assess its risks in granting credit terms and contact information about organisations Pipex considers may be interested in Pipex products and services.

3. How Does Pipex Obtain Personal Data?
Pipex 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 Pipex website); from third party list brokers; from resellers who pass on personal data to Pipex about end users; and directly from the Network utilised by Pipex services.

4. How Does Pipex Use The Personal Data It Holds?

• 4.1 Providing and Improving the Pipex Service Most of Pipex'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, Pipex may also use personal data to improve on the level and type of service Pipex offers to its customers. As part of this interest in improving the service provided Pipex may process personal data for the purposes of sales analysis and customer usage statistics.
• 4.2 Direct Marketing Pipex may from time to time inform its customers, end users and potential customers about Pipex and Pipex affiliate products and services and other information Pipex feels may be of interest.

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

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

6. To Whom Does Pipex Disclose Personal Data?
Pipex will pass personal data within its internal departments in order to fulfill sales and support obligations as well as to finance departments to enable invoicing. Pipex may also pass your personal data to group companies so that they may market their services to you. As a general rule, Pipex does not disclose personal data to unaffiliated third parties except where customer consent has been obtained, where Pipex is under an obligation by law to disclose personal data or where Pipex has contracted with third parties to assist in providing services to Pipex customers such as for delivery, installation and systems support services.

7. How Does Pipex Protect the Personal Data it Holds?
Pipex takes customer confidentiality and security very seriously. Pipex has implemented appropriate internal security procedures that restrict access to and disclosure of personal data within Pipex. These procedures will be reviewed from time to time to determine whether they are being complied with and are effective. Pipex will also actively investigate and cooperate with law enforcement agencies any allegations of abuse or violation of system or network security as set out in the applicable Pipex Acceptable Use Policy found on http://www.pipex.co.uk.

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

• 8.1 obtain from Pipex, 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 Pipex regarding promotions or new products and services.

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

10. Policy Updates
As part of Pipex's commitment to compliance with data privacy requirements, and to reflect changes in Pipex's operating procedures, Pipex may update the terms of this policy from time to time, and will post the revised policy at http://www.pipex.co.uk/legal/.

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