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Security Policies and Procedures <br />3. Phone Numbers <br />4. Email Address <br />5. Dates of birth <br />6. Social Security Numbers <br />7. Ages <br />8. Gender <br />9. Personal Financial Information <br />10. Personal Medical Information <br />11. Criminal History Information <br />12. Personal Employment Information <br />13. Personal Buying Histories <br />14. IP Addresses <br />Aggregated and statistical data developed from this personal information is not <br />personally identifiable and, thus, does not need the approval of the ISO for sharing and <br />re -use. <br />Virtru will comply with all applicable laws and regulations regarding the privacy of <br />personal information, including such laws as: <br />1. Health Insurance and Portability and Accountability Act (HIPAA) <br />2. Health Information Technology for Economic and Clinical Health (HITECH) <br />3. Family Educational Rights and Privacy Act (FERPA) <br />4. Criminal Justice Information Systems (CJIS) <br />S. Federal Information Security Management Act (FISMA) <br />Virtru's workforce members, contractors, vendors and suppliers may come into <br />possession of Personally Identifiable Information as a part of their relationship with <br />Virtru. Each person must comply with all laws, regulations and policies and ensure <br />such information is properly protected. <br />H. Release of company information <br />Virtru's information may only be released with the approval of the ISO or the <br />information owner. This includes the posting of Virtru's information of any type onto <br />bulletin board systems, public networks, social media or other open sharing tools. Any <br />information released must contain proper copyright, trademark, disclaimer and patent <br />notices as appropriate. <br />X. Risk Analysis and Management <br />Risks to Virtru's assets and environment should be addressed proactively rather than <br />reactively. The controls applied to the risks must also be periodically reviewed to ensure <br />the controls are working properly and efficiently. <br />Rev.2015.8.6 <br />25 <br />