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

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V. Business Associate Agreements A. Overview The Privacy Rules impose certain requirements on Business Associates who create, receive, use or disclose Personally -Identifiable Information on behalf of their Covered Entity partners. Vitru must comply with the requirements in this section. B. Purpose To provide instructions to all Virtru employees regarding the necessity of and the requirements for Business Associate Agreements relating to Covered Entities. C. Applicability This policy applies to all Virtru employees, which is defined for the purposes of this document to be employees of all current and future subsidiaries of Virtru. D. Policy 1. Generally: A Covered Entity may disclose Personally -Identifiable Information to Virtru, or allow Virtru to create or receive PII on the Covered Entity's behalf. Virtru will appropriately safeguard the PII obtained from the Covered Entity. Virtru will document these assurances through a written agreement. 2. Content Requirements: The agreement between the Covered Entity and Virtru must meet the following requirements, as applicable: a. Establish permitted and required uses or disclosures of Personally -Identifiable Information that are consistent with those authorized for the Covered Entity, except that the agreement may permit Virtru to use or disclose Personally -Identifiable Information for its own management and administration if such use or disclosure is required by law, or Virtru provides reasonable assurance to the Covered Entity to which the Personally -Identifiable Information is disclosed that the confidentiality of the PII will be maintained. b. Provide that Virtru will: 1. Not use or disclose the Personally -Identifiable Information except as authorized under the agreement or required by law. 2. Use safeguards to prevent unauthorized use or disclosure. 3. Report unauthorized uses or disclosures to the Covered Entity. Rev.2015.8.25 13