Privacy Policy

Sterling Commerce (UK) Ltd. (Sterling Commerce) is committed to respecting your privacy in connection with personal data. This Privacy Policy provides information regarding the commitment of Sterling Commerce to protect the personal data of users of this website, or any other website owned, operated, licensed or controlled by Sterling Commerce (collectively the "Site"). The term "personal data" includes any information that enables you to be identified, such as your name, physical address, e-mail address and phone number.

1. Nature of the data collected and purpose of the data processing
When you access the Site, Sterling Commerce collects the IP address of the computer you are using to browse the Site. If this address is a "static" or fixed IP address, Sterling Commerce could in certain circumstances theoretically be able to identify you, and therefore, this type of information could be considered personal data. However, Sterling Commerce only collects this type of information to compile usage statistics on an anonymous basis.

Apart from your IP address, no personal data is transmitted when accessing this Site. Unless you submit personal data about yourself by filling in a form on the Site or by sending us an e-mail, we will not maintain any other personal data as a result of your access and usage of the Site.

The Site invites you to register with us on-line, by providing the following information through a form page: Title, First Name, Last Name, Salutation, E-Mail Address, Company, Industry, Function/Title, Street, City, Postcode, Country, Telephone Number, Fax Number, Preferred Language, Department and other information when needed to provide a product or service.

The Site may also require you to register to enjoy certain services provided through the Site, such as on-line support and on-line education, to subscribe to newsletters, or to participate in a contest, survey, or promotion. The information provided in the context of registering for these services is collected to respond to your inquiry, process an order, to provide you with access to specific account information or to enable us to provide you with the aforementioned on-line services securely through password protection. Unless the registration states that the provision of the personal data is mandatory, your reply is not mandatory, and your failure to reply will not have any consequences. However, if you do not provide the personal data, which is indicated as mandatory, you may not be able to benefit from some of the services, provided through this Site.

In addition, in order to better understand the needs of our customers and of the users of this Site and to adapt the Site to these needs, we occasionally conduct on-line surveys. Participation in these surveys is optional. The data collected through these surveys is used for statistical analysis of user experiences and needs and for direct marketing purposes.

As you permit it, Sterling Commerce will use personal data you submit to send marketing material by e-mail or by fax. You may at any time choose not to receive any marketing information by sending an e-mail message to emea_unsubscribe@stercomm.com.

If we plan to use your personal information differently from the way we said we would at the time we collected it, we will notify you. Naturally, if you notify us that you do not wish us to use your information for a particular purpose, we will not do so.

2. Identity and Location of the Data Controller
Any personal data you provide us through this Site will be processed by Sterling Commerce in the United Kingdom, which determines the purpose and means of the data processing:

Sterling Commerce, EMEA
Kurtz, Catherine
3 Furzeground Way
Stockley Park
Uxbridge
Middlesex
UB11 1EZ
United Kingdom

+44 20 8867 8000
+44 20 8867 8001 (Fax)

Email privacy-emea@stercomm.com

http://www.sterlingcommerce.co.uk/

3. Use of "cookies"
This Site sends "cookies" to your computer to better serve you with more tailored information when you return to the Site and to ensure we are publishing content users need and want. A cookie is a small element of data that can be sent by our Site to your browser and (if the user accepts cookies) is stored on the hard drive. You can set browsers to tell you when you are sent a cookie and to refuse to receive it. Cookies can also be made inactive or deleted upon receipt.

To change the settings on your browser concerning the acceptance of cookies, please refer to your browser's help file. If you are using a browser from Microsoft, you will find more information about cookies at Microsoft's site: http://www.microsoft.com. If you are using a browser by Netscape you can go to the Netscape site at http://home.netscape.com. All other users need to contact the manufacturer for information about browser settings. The refusal or deletion of a cookie may affect functionalities of this Site.

Web logs are used to analyse overall Site usage and aggregate data about areas of interest to all visitors. None of the personal data given in registration processes is matched with the usage-statistics generated from the web logs. Web logs, however, automatically record activity on the web server, and the data recorded may include: date and time of a visit, IP address, the name of the file requested, possible queries contained in the URL, the status of the transfer, the number of bytes received and transferred from the web server, the type of client-browser and the referrer-page, and the used link to enter the Site.

4. Transfer of your data to other entities belonging to the group of Sterling Commerce companies and to third parties
Sterling Commerce may disclose your personal data to affiliates and third parties established within the EU. As you permit it, Sterling Commerce may disclose your personal data to other affiliates located in other countries where the European Commission has not found that the privacy laws ensure an adequate level of protection of personal data. Naturally, if you, at any point in time, notify us that you do not wish us to transfer your information, we will not do so.

The personal data about our users and customers is important to us and we do not sell it to other parties. Except in the limited circumstance set forth below, Sterling Commerce will disclose personal data, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) comply with the law, subpoena, court order or other legal process; (b) protect and defend the rights or property of Sterling Commerce and its affiliates, and (c) protect the personal safety of users of the Site or the public. In limited instances, Sterling Commerce may engage other companies to provide limited services on our behalf, answering customer questions about products or services, packaging, mailing and delivering purchases, processing purchasing transactions, and processing event registration. We will only provide those companies the information they need to deliver the service, and they are prohibited from using that information for any other purpose. These companies will be under the same obligations to protect your personal data as we are. This does not include selling, renting, sharing, or otherwise disclosing personal data from users or customers for commercial purposes in violation of commitment stated in this Privacy Policy. In the event Sterling Commerce is acquired by another company, personal data may be part of the assets transferred to the acquiring party.

Sterling Commerce may also, as you permit, provide personal data to affiliates for them to send marketing material by e-mail or by fax. You may at any time choose not to receive any marketing information by sending an e-mail message to emea_unsubscribe@stercomm.com.

5. Security of your data
Sterling Commerce takes all commercially reasonable precautions to adequately prevent others from freely accessing the information you provide or that we compile. Please be aware, however, of the fact that despite these precautions, zealous hackers may wrongfully gain access to this information. Although such unauthorised access is unlikely, we feel obligated to inform you of the risk and advise you that Sterling Commerce is not liable for any damages caused by such unauthorised access.

6. Your right to access, correction and erasure
You have the right to ask Sterling Commerce which information we hold about you. In addition, you have the right to correct or delete any information we hold about you. If you wish to know which information Sterling Commerce holds about you or if you wish to correct and update this information, please contact us at the address indicated below.

Sterling Commerce endeavours to honour your request within four weeks of receipt. If you want us to delete your private data or to unsubscribe from any mailing list for the future, we will attend to your demand within four weeks of receiving your e-mail.

7. Changes to the Privacy Policy
This Privacy Policy was last updated on 10/04/2007. A notice will be posted on our Site whenever it is changed in a material way.

8. Contact point for any questions or comments you may have about our Privacy Policy
If you have questions or comments about our Privacy Policy and our data processing practices or if you wish to exercise your right to access, correction or erasure mentioned above under paragraph (6) of this Privacy Policy, do not hesitate to contact us at:

Sterling Commerce, EMEA
Kurtz, Catherine
3 Furzeground Way
Stockley Park
Uxbridge
Middlesex
UB11 1EZ
United Kingdom

+44 20 8867 8000
+44 20 8867 8001 (Fax)

Email privacy-emea@stercomm.com

http://www.sterlingcommerce.co.uk/