Global Crossing is committed to protecting the privacy of individuals. This privacy policy sets out our practices regarding any personally identifiable information we collect from you, or that you provide to us, via our websites or our audio, conferencing and on-line services.

What Information May We Collect?
We may collect and process the following information about you, which is referred to in this policy as "personally identifiable information":

• Information which you may submit to us such as name, address, telephone number, e-mail address, and other information. This includes information provided at the time of registering to use our website and/or our services, subscribing to our services, posting material or requesting further services. Such information includes verification details that you provide to us in order to access and use specific features of our services, such as verification details provided to us in order to access our Ready-Access conferencing services. This will include any verification details which you provide in order to access, download or play the taped records.
• Where you are a Global Crossing customer, additional information which your company has provided - such as your company's name and address, your employee ID, your Lotus Notes or Microsoft Outlook short name.
• If you contact us, a record of that correspondence.
• Any surveys you complete that are used for research purposes.
• Details of transactions you carry out through the websites and the fulfillment of your orders for our services.
• Details of your visits including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for billing purposes or otherwise and the resources that you access.
• Information about the types of telecommunications services you currently purchase, how you use those services, and related billing information for those services. This information is collected in the normal course of providing telecommunications services to our customers, and is commonly referred to as customer proprietary network information, or "CPNI". CPNI is discussed in detail below.

The submission of personally identifiable information constitutes your acknowledgment that you have read and understood this privacy policy, and agree to its terms. You also acknowledge and consent to our collection, storage, and processing of such personally identifiable information.

How We Use It
We value your patronage and respect your right to privacy. Because of our commitment to protecting your privacy, personally identifiable information will be collected, processed, stored, and disposed of in accordance with all applicable laws. Where we process information submitted or gathered via our websites, then we use this in order to make our websites more useful and to respond to your queries, inform you of any new promotions, products and services offered, improve the level of service, and provide notifications regarding service changes or outages. We may use your IP address to help diagnose problems with our servers and administer our websites. Your IP address and information regarding the web pages you visit may also be used to gather broad demographic information, interests, and behavior so that we may better understand you. Where we process personally identifiable information in the course of our conferencing, audio or on-line services, this is done to allow us to provide the services which your company has asked us to provide, for example, by allowing us to create an authorized user ID for you, to allow you to use our services and by allowing us to provide billing and service usage information to your company.

Whom We Share It With
We do not sell or disseminate personally identifiable information to third parties without your consent. We may share non-personal, non-individual information in aggregate form with third parties. Your personally identifiable information may also be accessible by third-party service providers to whom we subcontract, including those who host and maintain our websites or our other services, or who provide billing and other out-sourced services to us. All such service providers must commit to complying with our instructions and to keep all personally identifiable information secure.

Notwithstanding other provisions of this privacy policy, we may disclose personally identifiable information and account information in special cases when it is necessary to identify, contact, or bring legal action against someone who may be violating any user agreement or may be causing injury to or interference with us, you, or anyone else that could be harmed by such activities. We reserve the right to disclose your personally identifiable information as explicitly set forth in this privacy policy or any user agreement agreed to by you, or as otherwise required by government or law enforcement officials. We can, and you hereby authorise us to, disclose any information to law enforcement or other parties that we in our sole discretion, believe is required or appropriate in order to comply with the law.

We may disclose, assign, sell, license, or otherwise transfer to a third party, your name, address, e-mail address, member name and any other personally identifiable information in connection with an assignment, sale, joint venture, or other transfer or disposition of a portion or all of our assets or stock.

Direct Marketing
We would like to keep you up to date with details of our products and services using the information that you have supplied. We will do this in accordance with any direct marketing permissions which were given when we collected information from you. If you would like to change these preferences, please e-mail us at privacymatters@globalcrossing.com.

Transfer of Your Information Outside Europe
Global Crossing is a multinational company and the information that we collect from you may be transferred to, and stored at, destinations around the world. All Global Crossing entities comply with this privacy policy when they use personally identifiable information. Users from the European Economic Area ("EEA") should note that we will transfer personally identifiable information to countries outside the EEA, some of which may not have data protection legislation equivalent to EEA legislation. However, we ensure that all transfers of personally identifiable information to such countries to our Affiliates and subcontractors is done in compliance with the applicable laws of the EEA. If and when you provide personally identifiable information to us, we will ask for your consent to this.

How to Review and Update Your Information
You may request a copy of your personally identifiable information and you may review, correct, update, change or delete your personally identifiable information at any time by submitting a request at the location where you originally input such information or replying to the sender of any website information.

Opt-Out Policy
You may request not to be contacted by us in connection with any new services, updates, promotions, news, or system outages. Such "opt-out" requests should be sent to the address indicated on any such material or by replying to such material.

Children's Privacy Protection
Our websites do not target and are not intended for children under the age of 13, and we abide by the United States' Children's Online Privacy Protection Act (COPPA) requirements and do not knowingly collect or maintain personally identifiable information from children under the age of 13.

Cookies
We may use "cookies" to collect IP addresses and information about the pages visited by you. A cookie is a small data text file that a website server writes to your hard-drive when you visit the website. A cookie assigns a unique identification to your computer and may be used to facilitate transactions, personalise the site, or gather information about the visit. The cookie information is sent back to the website server each time you request a new page from the server. Cookies are designed to be read only by the server that originated it. Cookies can enhance the browsing experience. You have the ability to accept or reject cookies by modifying the settings in your browser.

You can find out how to disable/enable cookies at www.allaboutcookies.org

Linked Internet Websites
Our websites may provide hyper-text links to other websites over which we have no control and which may contain privacy provisions that are different from those provided herein. We are not responsible for and expressly disclaim any and all liability for the privacy policies or practices of other websites to which you choose to link from our websites. We encourage you to review the privacy policies of those other websites so you can understand how they collect, use and share your information.

Security
Our websites have security measures in place to protect against the loss, misuse and alteration of information under our control. However, we cannot guarantee that such security measures will be sufficient, will not be breached, and that your information may not be disclosed or otherwise accessed in an unauthorized manner. Certain information may be transmitted to you by electronic mail. Although it may be illegal to intercept or disclose these messages, these transmissions are not secured.

Customer Proprietary Network Information (CPNI)
CPNI is information that we obtain when we provide telecommunications services to you, including services provided through your Global Crossing local telephone company. It includes the types of telecommunications services you purchase from us, how you use them, and the related billing information for those services. CPNI does not include your telephone number, name and address. CPNI also typically includes the type of information found on your bill, such as call details and the types of local, long distance and other services telecommunications services that you have purchased. We have internal policies and safeguards designed to safeguard the privacy of CPNI and protect it from unauthorized access or improper use. In the normal course of providing telecommunications services, we collect and maintain CPNI to enable us to make more meaningful suggestions to you when discussing products and services, packages, and promotions that best suit your communications needs. In the US, we are obliged to protect the confidentiality of your CPNI under federal law. We do not sell, trade or share your CPNI, including your calling records, with anyone outside of the Global Crossing group of companies or to third parties who perform functions on our behalf (such as billing functions) except as may be required by law or authorized by you. Generally, we are permitted to use CPNI in our provision of the services which you purchase from us, and to facilitate billing and collections for those services. We are also permitted to use or disclose CPNI to offer telecommunications services of the same type that you already purchase from us. We may also use or disclose your CPNI for legal or regulatory reasons such as a court order, to investigate fraud or to protect against the unlawful use of our telecommunications network and services and to protect other users of our services.

Scope of this Policy
All Global Crossing group companies comply with this policy. Global Crossing North America Inc. controls personally identifiable information which is gathered or submitted via Global Crossing websites. Personally identifiable information gathered in connection with the provision of our services is controlled by the local Global Crossing which is a party to your service agreement.

Revisions to this Policy
As we grow and new features are added to this site or our services, or legal requirements change, this privacy policy may be modified. Any changes to the privacy policy will be posted on all its applicable websites. All information submitted through the websites is subject to the terms and conditions of this privacy policy, as amended.

Submission of Personal Details To Us
Any personally identifiable information which you submit to us will be treated and processed by us only in accordance with this privacy policy. By submitting any such information, you consent to our holding and processing the information, both electronically and manually, for the expressed purpose. You also consent to the transfer, storage and processing of such information between Global Crossing's offices worldwide.

How to Contact Us
If you have any questions or complaints about our sites, this privacy policy, or the information we collect, please contact us at privacymatters@globalcrossing.com or by writing to us at the following address: Privacy Matters, Global Crossing Legal Department, 200 Park Avenue, Suite 300, Florham Park, NJ 07932-0680, USA

Policy Updated November 2008