AppsCo Inc. Data Security Policy

Introduction

The purpose of this Data Security Policy (“Policy”) is to describe AppsCo's security policy regarding customer information, including without limitation personal information collected and processed by AppsCo's online services.

Specifically, this Policy is intended to identify AppsCo's policies, procedures, and auditing and training practices utilized for data security, and our resulting responsibilities to protect personal information from loss, misuse, unauthorized access, disclosure, alteration and destruction.

Personal Information

AppsCo Inc. provides its customers with online data processing services. In this capacity, we do not own or control any of the information we process on behalf of our customers; all such information is owned and controlled by our customers. This customer information is stored in a secure facility of a third-party independent data processor service provider on hardened systems using industry standard data security methods. Access to this information is restricted to authorized personnel only as dictated by operational policies.

AppsCo Inc. also collects personal information from identifiable persons for purposes of product registration and support, and to complete transactions. This information may be stored on AppsCo's internal computer network or in offline filing systems. Access to this information is restricted to authorized personnel only as dictated by operational policies.

Approach to Security

The following sections describe AppsCo's comprehensive approach to ensuring enterprisewide compliance with its Policy. This consists of four (4) major areas: Security, Personnel Education, Audits and Contracts.

Security

Security of data is the cornerstone of verifying privacy of data. AppsCo Inc. maintains a rigorous security posture through focused methodology. It is founded on the implementation of best practices and security policies in five (5) major areas providing enterprise wide coverage including:

• Regulatory Controls
• Organizational Controls
• Service Provider Controls
• Standardized Process and Practices
• Business Partner Controls

Key policies in place that contribute to the verification and compliance with the Policy are:

• Awareness and Training
• Personnel Practices
• Administrative Roles and Responsibilities
• Computer, Email and Internet Use Policies
• Network and Telecommunications Security
• Incident Detection and Reporting
• Malicious Code Control (Antivirus)
• Portable Computers
• Logical and System Access
• Physical Access
• Remote Access
• Firewall Management
• Third Party Services
• Software Licensing and Appropriate usage
• Auditing and Monitoring
• Data Classification, Confidentiality, Integrity and Availability
• Policy Compliance

Operational procedures demonstrating compliance with the Policy are:

• Change Control
• Event monitoring
• Data backup
• System hardening

The above referenced policies and procedures are documented and available for review.

Our Personnel

Our personnel consist of employees and contractors.

Personnel Education

AppsCo Inc.regularly notifies and reinforces its Privacy And Cookie Policy with its personnel. This is done using the following process:

• The Privacy And Cookie Policy is distributed company-wide via email quarterly and when updated.
• The Privacy And Cookie Policy is displayed on AppsCo's website.
• At least once per year, the this Security Policy is presented and discussed at a companywide meeting.
• This Security Policy is prominently displayed in an a common area of the office.

Verification

This Security Policy is self-verified periodically by AppsCo's Security Officer. The Security Officer is responsible for:

• Ensuring that the policies, guidelines, internal procedures, personnel training, and other measures necessary to implement the Policy are developed and put into practice,
• Working with AppsCo's legal counsel to ensure AppsCo's ongoing compliance with applicable privacy laws and agreements, as well as any of AppsCo's other related legal obligations, and
• Overseeing annual assessments of AppsCo's internal and external practices to ensure that they conform to the Policy and related company obligations.

In addition, AppsCo, through its internal audit processes, conducts an audit of its security controls a minimum of once per year. This independent review assesses the physical security, network security and operational policies and controls in place to protect customer data. The latest copy of the security review is available to customers, personnel and prospects upon request.

Contracts

Prior to (i) processing any personal information on behalf of an individual or entity, or (ii) transferring any personal information, AppsCo Inc.requires contracts with data security provisions consistent with by this Security Policy.

As a condition of employment, all AppsCo Inc. personnel must sign a confidentiality agreement.