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D. Policy <br />Virtru shall maintain a process to receive complaints from individuals about Company <br />Privacy Policies and Procedures, for complaints from individuals who believe their <br />privacy rights have been violated and from employees or Business Associate <br />Subcontractors who believe that Virtru is not abiding by its policies and procedures <br />and/or assurances concerning Personally -Identifiable Information. This process shall <br />include the following: <br />1. Any complaints or questions should be submitted to the Privacy Officer or his <br />assistant. <br />2. All service and complaint issues will be stored in the Desk.com app. <br />Virtru shall work in good faith to resolve complaints received to the satisfaction of the <br />submitter, where possible. <br />E. Procedures <br />The following procedures will be implemented to ensure that this policy is enforced <br />effectively across all parts of Virtru. <br />1. Complaints shall be submitted in writing on paper or electronically. <br />2. Complaints shall be entered into the complaint tracking system either <br />automatically or by the individual designated to provide information on the <br />Company complaint process. and when manually entered shall be in the exact <br />words provided by the submitter. <br />3. The Virtru Privacy Officer shall investigate complaints and make a <br />determination as to whether or not the complaint has merit. <br />4. The Virtru Privacy Officer shall present complaints received to Virtru's senior <br />executive for immediate action. <br />S. If the Privacy Officer has completed the investigation of the complaint and <br />made a determination, such determination shall be presented to the Virtru <br />Executive Board <br />6. If the investigation has not been completed nor a provisional determination <br />made by the Privacy Officer, it shall be the prerogative of the senior executive <br />to make a summary determination or to direct the Privacy Officer to continue <br />with the investigation and to report on the complaint at the next scheduled <br />meeting. <br />If a determination is made that Virtru is in violation of the privacy provisions of the <br />Privacy Rules or that changes are needed in the Privacy Policies or Business Associate <br />Agreement to clarify the allowed practices of Virtru, the Virtru CEO and Privacy Officer <br />shall determine the actions that the Company shall take. <br />Rev.2015.8.25 <br />