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Complaint determinations and actions that Virtru takes pursuant to such complaints, if <br />any, shall be reported to the submitter of the complaint, if such person is known. <br />Privacy Officer, or his designated agent, shall update the complaint tracking system with <br />the findings of the Privacy Officer's investigation, any determination made, direction or <br />actions of the Virtru CEO and Privacy Officer with regard to the complaint, and a copy of <br />any information provided to the submitter in response to their complaint. <br />F. Enforcement <br />Any 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 />IX. Fax Policy <br />A. Overview <br />The Privacy Rules require that Virtru implement appropriate administrative, technical, <br />and physical safeguards to protect the privacy of Personally -Identifiable Information. <br />B. Purpose <br />To provide instructions to all Virtru employees regarding the use of faxes with respect to <br />Personally -Identifiable Information and the measures necessary to maintain an adequate <br />level of security for such information. This policy defines rules necessary to achieve this <br />level of protection. These standards are designed to minimize the potential exposure to <br />Virtru from damages, which may result from unauthorized disclosure of Personally - <br />Identifiable Information through facsimile use. <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 />D. Special Definitions <br />Fax: An electronic facsimile of a document stored as a series of zeroes and ones (binary <br />data) that can be transmitted like normal computer data. When received by a fax machine, <br />the incoming stream is translated into dots creating a representation of the original <br />document. <br />Inappropriate Disclosure: The intentional or unintentional revealing of <br />Personally -Identifiable Information to people who do not have a need to know such <br />information. <br />Rev.2015.8.25 <br />21 <br />