Item 26 - Agreement with Allied Network Solutions, Inc. for Adobe Software and Subscription

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I. Company Virtru may be referred to as "Company." A. Document Control A staff copy of this document is available with the Virtru Privacy Officer, Will Ackerly, willackerly@virtru.com or (202) 577-3683. B. Security Document Library These policies and procedures and related privacy and security practice information will be kept in our Security Documentation Library (SDL). The Library is located in Google Drive and backed up to a local NAS. Outdated and superseded materials from the Security Documentation Library (or Notebook) will be kept in an archive (the Security Documentation Archive) for at six (6) years after the date when they are first outdated or superseded. II. Management and Protection of Personally -Identifiable Information A. Overview The Privacy Rules place certain restrictions on the acquisition, use and disclosure of Personally -Identifiable Information (PII). These policies establish the minimum care with which PII in the custody of Virtru personnel must be maintained. B. Purpose The purpose of this document is to provide basic instruction to all Virtru employees regarding the management and protection of Personally -Identifiable Information. C. Applicability This policy applies to all Virtru employees, which are defined for the purposes of this document to be employees of all current and future subsidiaries of Virtru. D. Definitions Covered Entity means a health plan, a health care clearinghouse, or a health care provider that transmits any health information in electronic form relating to any covered transaction. Personally -Identifiable Information (PII) means any information about an individual maintained by Virtru, including: 1. Any information that can be used to distinguish or trace an individual's identity, such as name, social security number, date and place of birth, mother's maiden name, or biometric records; and Rev.2015.8.25 4