CARLON BUSINESS SEGMENT OF LAMSON & SESSIONS PRIVACY POLICY

Last Updated: November 1, 2001

Your privacy concerns are important to us at Carlon, a business segment of the Lamson & Sessions company ("Carlon"). We are committed to protecting your privacy. Please read the following Privacy Policy to understand how your personal information will be treated as you use this Web Site. When you use this Web Site, you consent to the use of your personal information by Carlon in the manner specified in this Privacy Policy. This policy may change periodically, so please check back from time to time. For your information, the date of the last update to this Privacy Policy is stated at the top of this document.

Please note that Carlon's Web Site contains links to other sites, including links to industry organizations, publications, local sales contacts, and trade shows. Carlon is not responsible for the privacy practices, privacy statements, or content relating to these other sites.

THIS POLICY WILL EXPLAIN:

1. What Information We Collect From You, and How We Use That Information
2. How We Protect Your Information
3. Your Control of Your Information
4. Questions About the Privacy Policy

1. WHAT INFORMATION WE COLLECT AND HOW WE USE THAT INFORMATION

Carlon does not collect any personally identifiable information from you (e.g., name, address, telephone number, e-mail address) unless you voluntarily choose to disclose such information. We will not sell, trade or rent your personally identifiable information to third parties. Your information may be used for research on usage patterns, online site customization, targeted marketing, and other internal business purposes.

Customer Surveys: If you are interested in finding out about our new products, Carlon asks that you fill out a customer survey, which includes some personally identifiable information. We will use this information for internal purposes to improve our products, respond to customer demands, to send you more information about our products, and for other internal business purposes.

Carlon eConnect: Carlon eConnect is a Web site designed for our channel partners, to provide them with real-time access to our Enterprise Business System. To use this part of our site, your company must be pre-approved by Carlon. As part of the approval process, we ask that you register with us and provide certain information about you and your company. Each eConnect channel partner is assigned a user name and password. We will use the information you provide to allow you to access information about your orders and for other internal business purposes, including e-mail updates.

New Product Ideas: If you have a new and innovative product idea you would like to submit to Carlon, the New Product Idea area of our Web Site allows you to submit certain personal information and requires that you print and sign an agreement before submitting any new ideas to us. Carlon will use the information that you provide to review the idea and determine whether or not Carlon would like to pursue your idea further. All New Product Idea submissions are also governed by our Policy and Agreement Concerning Ideas Submitted by Persons Outside of The Lamson & Sessions Co.

Apply for a Job: If you decide to apply for a job with Carlon online, you will be asked to provide certain personal information, including education and employment history. Carlon will use this information to determine your qualifications for any job openings.

Cookies: Carlon from time to time may collect information about your use of the Web Site through the use of cookies. A "cookie" is a small data file stored by your web browser on your computer's hard drive. Cookies allow us to recognize who you are when you arrive at our Web Site. Information collected via cookies helps Carlon determine what areas of our Web Site are important to our users and to provide you with a more personalized experience. Carlon does not use cookies to identify individual users.

Aggregate Information: We may from time to time collect non-personal information about our customers, and aggregate this statistical information in order to improve our Web Site. When we say that we may share such information in "aggregate" form, we mean that we will not disclose individual names, addresses, telephone numbers and e-mail addresses unless we have your permission. External companies may be provided aggregate information about our customers.

Use of IP Addresses: An Internet Protocol ("IP") address is a number that is automatically assigned to your computer whenever you are surfing the Web. Web servers automatically identify your computer by its IP address. When visitors request pages from the Web Site, our servers log the guests' IP addresses. We do not normally link IP addresses to anything personally identifiable, which means that a visitor's session will be logged, but the visitor remains anonymous to us. Carlon collects IP addresses for the purposes of system administration and to audit the use of this Web Site, along with the uses described below. We may also use IP addresses to collect statistical information for our marketing and promotional purposes.

Information from Children: Carlon does not direct its Web Site to children under thirteen (13) years of age. Individuals under eighteen (18) should consult with their parent or guardian about the use of this Web Site for their benefit.

Monitoring, Enforcement and Legal Requests: Carlon has no obligation to monitor the Web Site or the use of the Web Site, or to retain the content of any user session. However, Carlon reserves the right at all times to monitor, review, retain, and/or disclose any information as necessary to satisfy any applicable law, regulation, legal process, or governmental request or to cooperate with law enforcement and other authorities in investigating a claim of illegal activity. We may use IP addresses to identify a user when we feel it is necessary to protect our service, Web Site, customers, or others.

Change of Ownership or Control: If Carlon becomes owned or controlled by other individuals or entities, the information we have collected may be transferred to such party or parties. In this case, such individuals or entities will follow this Privacy Policy.

Other Sites: Except as otherwise expressly discussed in this Privacy Policy, this policy only addresses Carlon's use and disclosure of information we collect from you. To the extent that you disclose personal information to other web sites, you are subject to the privacy customs and policies of these other web sites. We encourage you to ask questions before you disclose any personal information.

2. HOW WE PROTECT YOUR INFORMATION

Transmission Errors or Unauthorized Acts: Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, Carlon cannot ensure or warrant the security of any information you transmit to us or any information provided by our online products or services, and you do so at your own risk. Carlon will not be liable for disclosures of your personal information due to errors in transmission or unauthorized acts of third parties. However, once we receive your transmission, we do our best to ensure its security on our systems by making reasonable efforts to protect the information.

Security: Any information provided to Carlon is treated with care and discretion. When information is shared, Carlon will take a proactive approach to ensure the information is kept private and not misused.

Passwords: Normally, you do not need a password to access the majority of our Web Site. However, if you are approved to register with Carlon eConnect, your customer account and personal information is password protected. Carlon encrypts your password on its database. However, you are responsible for maintaining the confidentiality of your password. Therefore, we recommend that you do not divulge your password to anyone. We will never ask you for your password in an unsolicited phone call or in an unsolicited e-mail. Also, remember to close your browser window when you have finished using our Web Site.

3. YOUR CONTROL OF YOUR INFORMATION

Your Choice: Carlon respects your decisions about the collection and use of your information. You may have the opportunity to elect to receive information about new products, future press releases, and investor-oriented materials from us. Based on this choice, you may receive information from Carlon or a trusted third party. Every communication we send to you will contain instructions on how to cancel receiving similar information in the future. By accessing and using this Web Site, you consent to the use of your personal information by Carlon in the manner specified in this Privacy Policy.

Update Information: If you have given Carlon information in the past and now wish to change such information, please send us an e-mail through the Contact Us pages of our Web Site. Although Carlon will make reasonable efforts to make the changes you have requested, we may be unable to update other types of information provided to us, such as aggregate or cookie information, or information that has been stored in our system.

Delete Information: If at any time you wish to stop receiving information that we think you will find valuable, you can elect to do so by sending an e-mail to us through the Contact Us pages of our Web Site. You can also choose to delete your profile from our active database by either using the online system or by e-mailing us at the same address. Unfortunately, Carlon may not be able to delete other types of information, such as aggregate or stored information.

4. QUESTIONS ABOUT THE PRIVACY POLICY

Privacy and security is important to us all. We pursue a full-disclosure approach to responsibly care for the information you have entrusted with us, and we depend on information sharing as our principal means to best serve you. This is why we are committed to building a trusting relationship with you. We will continually monitor customer feedback and seek to improve our services to meet your needs. If you have any questions about this Privacy Policy, the practices of this Web Site, or your dealings with the Web Site, or would like to provide comments, you can send us an e-mail at webmaster@carlon.com, or contact us by phone at 216-766-6110.