Dell MessageOne^™ Company Privacy Policy

1. Introduction
   1. This Statement relates to the collection, processing, use and disclosure of data and information about individuals by Dell MessageOne and each of its subsidiaries and group companies (“Dell MessageOne”).
   2. Dell MessageOne endorses and respects all applicable privacy and data protection laws in every country, state and other territory in which it does business, and expects and requires its employees, contractors and consultants to do likewise.
2. Purpose of Policy
   1. Various national and international laws and regulations protect the rights of individuals in connection with data relating to them.
   2. The purpose of this Policy is to make sure that the aims of national and international laws and regulations on data protection are respected and that the collection, processing, use and disclosure of data by Dell MessageOne is in line with those laws and regulations.
3. Scope of this Policy
   1. This Policy applies to all of Dell MessageOne operations throughout the world. Where local laws and regulations which go beyond the scope of this Policy apply to the collection, processing, use and disclosure of data, then there may be additional provisions of this Policy applying in the relevant location. Ask the privacy officer about local compliance if you are unsure about local requirements.
   2. This policy applies to all:
      1. officers, directors and employees;
      2. temporary staff;
      3. consultants and advisors; and
      4. contractors;
      5. of Dell MessageOne.
   3. Failure by an employee to comply with the Policy without reasonable excuse is a disciplinary offence and may result in disciplinary procedures and sanctions being taken against the employee concerned. Failure by any contractor or consultant to comply will also be taken seriously and may lead, subject to agreed contractual terms, to the termination of their relationship with Dell MessageOne.
4. Privacy Officer
   1. There is a specific person within Dell MessageOne appointed to oversee compliance with this Policy and to make decisions regarding the steps which need to be taken in particular circumstances in order to ensure compliance. The identity of that person will be notified to Dell MessageOne personnel. He or she is referred to in this Policy as the "privacy officer".
   2. Personnel with concerns or questions relating to privacy or data protection matter should contact the privacy officer. If personnel have concerns that other employees, consultants or contractors are not observing this policy or the related policies, they should contact the privacy officer.
5. Start Date
   1. This Policy comes into effect on June 29, 2007. Any new activities undertaken by Dell MessageOne after that date must comply with the Policy.
6. Categories of data collected and used by Dell MessageOne
   1. Broadly the majority of personal information used by Dell MessageOne in its business falls into one of two categories:
      1. Personal information collected by Dell MessageOne relating to its employees, contractors and contacts at customer or supplier organizations;
      2. Personal information collected by or on behalf of Dell MessageOne customers and held by Dell MessageOne in order to provide services to those customers.
7. Personal information collected by Dell MessageOne relating to its employees, contractors and contacts
   1. For this category of information, Dell MessageOne is responsible for complying with applicable regulations relating to ensuring:
      1. Dell MessageOne is entitled to collect and use the information. This may mean obtaining consents from relevant individuals for collection, use and disclosure or, depending on the nature of the information and the requirements of local regulation ensuring transparency and openness in respect of collection, use and disclosure;
      2. personal information is only used for those purposes for which Dell MessageOne is legally entitled to use them;
      3. personal information is deleted or edited in accordance with applicable laws;
      4. personal information processed is subject to reasonable measures with a view to ensuring it is secure and that appropriate levels of confidentiality are maintained, that unauthorised persons are not allowed access to personal data;
      5. personal information is, as and where required by applicable law, accurate, up-to-date and not excessive given the purposes for which it was collected; and
      6. individuals’ rights to access to information held about them and to have inaccurate or unlawfully held information corrected or erased are respected.
8. Personal information collected by or on behalf of Dell MessageOne customers and held by Dell MessageOne in order to provide services to those customers
   1. For this category of information, Dell MessageOne has no direct contact with the individuals in question and is not responsible for compliance relating to most privacy issues.
   2. However, in relation to this category:
      1. Dell MessageOne may have made contractual commitments to its customers in connection with the use and security of that information
9. Use of Dell MessageOne Website at www.messageone.com
   1. The terms and conditions with respect to privacy while visiting the Dell MessageOne website are set forth at http://www.messageone.com/website-privacy and are incorporated herein by reference.
10. Local legislation and regulations
    1. Wherever local regulation requires Dell MessageOne to register in order to process personal data, all registrations must be made and maintained in accordance with the applicable regulatory requirements. All processing or personal data must be carried out in accordance with applicable regulation and within Dell MessageOne registrations. This Policy must also be complied with in full save to the extent it conflicts with local regulation.
11. Specific policies
    1. The following Dell MessageOne policies and procedures contain specific guidance on privacy-related areas and form part of this Policy:
       1. Information Disposal Procedure (general)
       2. Acceptable Use Policy (general)
       3. Information Security Policy (general)
       4. Monitoring and Response Policy (production and support)
       5. Security Operations Policy (production and support)
       6. EMS Production Site Security (production and support)
    2. Each of the above listed policies and procedures are tailored to address the activities of specific groups of employees within Dell MessageOne. Employees must be familiar with those policies relevant to their role within Dell MessageOne. Policies applicable to all employee are marked general and are accessible on the Dell MessageOne intranet.
12. Updating
    1. This Policy will be updated from time to time to take account of regulatory and other changes. Staff will be notified when this occurs and updated versions of this Policy will be issued.