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Privacy, Confidentiality and Data Protection Policy

Last Updated: Friday October 8th, 2010.

1. GENERAL PRINCIPLES:

xcentra ("xcentra") is committed to respect privacy and confidentiality to protect personal data. We hope that the following information will show you how xcentra collects, uses and protects this information.

Our aim is to ensure that the processing of personal data by xcentra is fair and reasonable and that personal data is secure, accurate and up to date.

xcentra usually only collects personal data during form submissions or by means of different registration processes, if required, for which xcentra understands that you consent us to store and internally use the information you type when pressing the button to submit the corresponding form.

Bear in mind that because xcentra online services are accessible from any location throughout the world, personal data may be transferred over data networks in countries that do not have data protection laws.

2. SCOPE:

The present Privacy, Confidentiality and Data Protection Policy statement only applies to the Internet website ("the website") provided by xcentra ("xcentra") at the following address: "http://www.xcentra.com". Please read it carefully.

3. INFORMATION xcentra COLLECTS DURING FORM SUBMISSION/REGISTRATION PROCESSES AND WHY:

As mentioned above, xcentra could collect information about its users during form submission or different registration processes. This information usually consists of mandatory data and optional data.

Examples of mandatory data are usernames (required to define new accounts) or email addresses. If a password is provided, it will always be possible to be changed afterwards. Email addresses might also be used to provide different services like user surveys, newsletters, etc.

Other optional information (i.e., the data the user is not actually required to provide) is only collected for better performance of present or future services. This type of information may include, for example, the user's website address, his/her approximate geographical location, fixed and/or mobile phone numbers, fax number, etc.

xcentra may in the future, and for the same purposes, collect other optional information either by direct contact with users or automatically when services are provided. In that case, that change will be clearly announced in the website.

Any user information described above will be deleted by xcentra after an individual de-registers him or herself from xcentra, if xcentra decides to terminate user's access to the xcentra website or to any of the Products and Services or for correction/cancellation of personal information purposes, according to the requirements of the applicable legislation. In case of user de-registration, he/she may be required to log in to xcentra for a last time as a security measure before the de-registration is processed.

xcentra might contact users to obtain feedback on the service or any improvements that could be introduced. xcentra can also reply to enquiries received by means of any web form submitted.

Every registered user is responsible for maintaining the confidentiality of the ID and password provided by xcentra, and is fully responsible for all activities that occur under his/her ID and/or password. The user agrees to (a) immediately notify xcentra of any unauthorized use of his/her password or account or any other breach of security, and (b) to ensure that he/she exits from his/her account at the end of each session. xcentra cannot, and will not, be liable for any loss or damage arising from the user's failure to comply with this requirements.

The law allows you to write and ask to see and correct the information held about you. xcentra will always proceed to modify, cancel or inform you about such kind of information on a free-of-cost basis, including the user account itself. In particular you have the following rights with respect to the information provided to xcentra:

• To review the user information that you have supplied to us.
• To request that we correct any errors, outdated information, or omissions in user information that you have provided to us.
• To request that your user information not be used to contact you.
• To request that your user information be removed from any solicitation list that we use.
• To request that your user information be deleted from our records and...
• To opt out of being solicited by this website.

If you request that your user information be deleted from our records, there may be a brief delay in our processing that request, while it is verified that the request is valid and originates from you as opposed to an unauthorized third party. We reserve the right to terminate and/or limit access to the xcentra website for any user requesting end of services or cancellation of personal data.

4. NON TRANSFER OF DATA TO THIRD PARTIES:

xcentra is the solely proprietary and holder of the personal information collected through its Internet website and DOES NOT sell, transfer, share or rent personal data to any third parties outside its organization, under no circumstances.

5. COOKIE USE POLICY:

According to national electronic communication laws in effect in several countries, all visitors of cookie enabled websites are hereby informed that this website uses "cookies". We also want to inform how they are used and how to avoid them.

A "cookie" is a piece of information, which may be sent to your computer and that can be stored on it as small files on request from a website. They contain information that the website wants your browser to present every time you request a web page from it. In most cases cookies just contain configuration settings that you have made on the website, credentials for login, etc. Cookies are restricted in size to 4 KBytes (4 KiB) and they simply just can't make any harm to your system. They do not have access to essential or confidential parts of your computer. Moreover, they have absolutely no relationship with viruses, trojans, or any other kind of malicious software designed with destructive purposes. Cookies just enable xcentra to personalize the website according to your preferences. They also allow us to automate login procedures each time you decide to log in into the website. If a cookie is sent to your computer, it will ONLY AND EXCLUSIVELY be to collect information for the purposes stated above. Cookies in the xcentra website will only hold information about general usage within the current session and WILL NOT IN ANY WAY EVER be shared with or sent to other websites, companies or third parties, nor used to personally identify you individually.

The most common types of cookies used by xcentra are:

• If you are a non registered user, xcentra just sends a cookie to your computer which keeps the last language used to access the xcentra website. It has a validity of 1 day(s).

• If you are a standard registered user, xcentra will send you a cookie when you register yourself for the first time, when you log in or whenever you make a major change in your customization settings. This kind of cookie expires after 1 day(s).

xcentra NEVER sends third party cookies onto the user's computer.

How to turn cookies off in your web browser
There is no way of preventing the xcentra website from sending cookies. What you can do instead is to configure your browser so it doesn't accept cookies. Most web browsers also allow to selectively turning cookies off for specific websites. Please read your web browser's documentation to find out how to turn cookies off.

What happens if the browser doesn't accept cookies?
If the user's web browser is configured not to accept any cookies, the user may not be able to log in to certain services or areas on the xcentra website. However, he/she will still be able to access the information that does not require login. Please note that even if the user enables the web browser to accept cookies, he/she always has the possibility to explore, edit and delete the cookies installed in his/her system, as described in the corresponding web browser's documentation.

6. DATA PROTECTION AND PASSWORD STORAGE POLICY:

No method of safeguarding information is 100% secure. xcentra uses a variety of security technologies and procedures to help protect your personal information from unauthorized access, use or disclosure. xcentra secures the information you might provide on computer servers in a controlled, secure environment. More specifically, any password used in the xcentra website is encrypted using a strong security algorithm right after the user types it so the storage of any password in our servers is always done with the encrypted version of the password. This means that no xcentra team members can access any plain, non-encrypted password, thus preventing any potential malicious use of customer passwords.

Should a password be modified or deleted from our servers, it will be done by using a management system that hides it from the person in charge, even if he/she is a system administrator or webmaster. Specifically, if the user requests xcentra to send him/her a new password ("password modification procedure"), this will be done without any access to the user's original plain password, since it is stored in encrypted form, as explained above.

7. IP ADDRESS TRACKING POLICY:

IP addresses corresponding to connections towards xcentra website could be tracked whenever it is considered necessary. The information collected by this means is handled according to the principles described under section 4. Non Transfer Of Data To Third Parties above, just for generic statistical purposes and is NEVER used by xcentra or any other third parties to personally identify visitors nor individual use patterns.

8. SPYWARE, ADWARE, HIJACKERS AND OTHER MALICIOUS SOFTWARE:

xcentra NEVER sends, nor makes the user's browser to stealthily download, any kind of malicious software on purpose.

9. LINKS TO OTHER WEBSITES:

The xcentra website contains hyperlinks to other Internet websites. xcentra can not accept, in any way, any liability, in any form, regarding the Privacy Policy of those linked websites. xcentra users are warned to be careful whenever they leave the xcentra website. It is always a good practice to read the Privacy Policy information of every visited website that could collect personal data.

10. CHANGES TO THIS STATEMENT:

xcentra will occasionally update this Privacy, Confidentiality and Data Protection Policy statement to reflect internal and/or customer feedback. We encourage you to periodically review this statement to keep yourself updated of how xcentra is protecting your information. When such a change is made, we will update the "Last Updated" date above.

11. QUESTIONS AND CONTACT INFORMATION:

If you have additional questions about xcentra's Privacy, Confidentiality and Data Protection Policy statement, please do not hesitate to contact us through our Contact Form. You can also use the same form if you believe that xcentra has not adhered to this statement. We will do all commercially reasonable efforts to investigate, determine and remedy the problem as promptly as possible.

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