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11. Workers' Compensation: Personally -Identifiable Information may be disclosed <br />as authorized and to the extent necessary to comply with laws relating to <br />workers' compensation and other similar programs. <br />F. Procedures <br />The following procedures will be implemented to ensure that this policy is enforced <br />effectively across all parts of Virtru. <br />Any request for disclosure of Personally -Identifiable Information, 1) pursuant to a court <br />order, warrant or subpoena; 2) by a law enforcement agent; 3) by a public health <br />authority; or 4) by a national security, intelligence or other federal company, must be <br />directed to the Privacy Officer and the CEO for review and action. Any such request will <br />include an acknowledgement of receipt to insure that the document was actually received <br />by the appropriate corporate individual and will retain a copy of the request. If the <br />acknowledgement is not received within two working days of submitting to the <br />appropriate corporate individual, then the request will be resubmitted to the Privacy <br />Officer and CEO. <br />G. Enforcement <br />An employee found to have violated this policy shall be subject to disciplinary action, up <br />to and including termination of employment. In the case where inappropriate access, use <br />or disclosure of Personally -Identifiable Information was or may have been involved, such <br />individuals may additionally be reported to the appropriate enforcement agencies. <br />VIII. Complaint Process <br />A. Overview <br />The Privacy Rules require that Virtru provide a process for individuals to make <br />complaints concerning the Company's policies and procedures required by these <br />regulations and document all complaints received, and the dispositions of these <br />complaints, if any. <br />B. Purpose <br />To issue instructions regarding Virtru obligations relating to the Privacy Rules to provide <br />a process for individuals to complain about the Company's policies and procedures and <br />the requirement to document complaints received and the disposition of these <br />complaints. <br />C. Applicability <br />This policy applies to all Virtru employees, which is defined for the purposes of this <br />document to be employees of all current and future subsidiaries of Virtru. <br />Rev.2015.8.25 <br />19 <br />