1.0 Purpose

The purpose of this document is to describe the details and requirements of Acuative Corporate Contractor Privacy Policy. In this age of the Internet where privacy has become an increasing concern, Acuative takes your privacy very seriously. The privacy and security of your personal data (the “Personal Identifiable Information” or (“PII”)) which we collect from you is important to us. It is equally important that you understand how we handle this data. Protecting PII about our contractors is something we are concerned about at Acuative. This policy explains the types of information we collect and how we protect it. The purpose of this policy is to enhance the management of PII that could be used, possibly in conjunction with other information, to impersonate a Contractor in ways that might cause serious loss of privacy and/or financial damage. By accepting to contract with Acuative Corporation (hereafter, “Acuative” or the “Company”), you expressly acknowledge that you have read, understand and agree to all of the terms of this Privacy Policy as outlined below and acknowledge it may be modified by us from time to time with or without prior notice.

2.0 Scope

This policy applies to all Acuative contractors and to anyone who may have access to Acuative personnel PII.

3.0 Collection of PII

In the course of conducting our business and complying with federal, state, and local government regulations governing such matters as invoicing, tax, insurance, etc., we must collect personal information from you. The nature of the information collected varies somewhat for each contractor, depending on your contract terms and conditions, responsibilities, and other factors. We collect personal information from you solely for business purposes and those required by governmental agencies.

PII Data collected may include, without limitation, such things as:

• Your name
• User ID(s)
• Phone numbers
• Email address (es)
• Mailing addresses
• Banking and other financial data
• Government identification numbers, e.g., Social Security number, driver’s license number
• Date of birth
• Gender, race, and ethnicity

3.1 Collection of Location Information (GPS)

Field Engineer - 1099 Contractors

1. GPS starts being collected when the Field Engineer accepts (downloads) a work ticket (GPS is polled every 15 minutes).
2. GPS stops being collected when the work ticket is completed and submitted to Acuative.

Field Engineer - Employees

1. GPS starts being collected when the Field Engineer clocks in at the start of their work schedule (GPS is polled every 15 minutes).
2. GPS stops being collected when the Field Engineer clocks out at the end of their work schedule.

Location data that is collected is only used within Acuative Corporation and not shared and disclosed to any other 3rd parties. Acuative Corporation protects this confidential location data with appropriate security and access controls.

When we have location information, we use it to ensure that we allocate the proper contractor to optimize service delivery to our customers. In addition, we use the location data to confirm that contractors are located in appropriate areas to be able to deliver service in the best manner possible.

4.0 Policy Statement

Anyone who sends solicited or unsolicited data to Acuative by any means, (e.g., mail, email or fax), expressly consents to the storage, destruction, processing, or disclosure of the data, as well as any other reasonable business-related use by the Company of the data.

We monitor Contractor use of the Acuative Internet services in order to detect access to inappropriate websites or other misuse of Acuative’s computer network. We also use email filters to block spam and computer viruses. These filters may from time to time block legitimate email messages.

Acuative will not knowingly collect or use personal data in any manner not consistent with this policy, as it may be amended from time to time, and applicable laws.

Because the PII collected by Acuative is necessary for business purposes, you are required to provide it. Your refusal or failure to provide the requested PII may, therefore, disqualify you from a contract with Acuative.

5.0 Use of the Information We Collect

The primary purposes for collection, storage and/or use of your PII include, but are not limited to:

• Business Processes and Management. PII is used to run our business operations including, for example, scheduling work assignments, managing company assets, reporting and/releasing public data (e.g., Annual Reports, etc.); and populating contractor directories. Information may also be used to comply with government regulations.
• Safety and Security Management. We use PII as appropriate to ensure the safety and protection of contractos, assets, resources, and communities.
• Communication and Identification. We use PII to identify you and to communicate with you.
• Authorized Use Only. Only authorized employees, who are trained in the proper handling of PII shall be permitted to have access to said information.
• No Sale or Distribution. The Sale or distribution of contractor PII to any external organization is strictly prohibited unless required by law to do so.
• Other Uses. For purposes of verification and risk management, exchange of information with reputable reference sources and clearing house services is permitted.

6.0 Disclosure of Data

Acuative acts to protect your PII and ensure that unauthorized individuals do not have access to your PII by using security measures to protect PII. We will not knowingly disclose, sell or otherwise distribute your PII to any third party without your knowledge and, where appropriate, your express written permission, except under the following circumstances.

• Legal Requests and Investigations. We may disclose your PII when such disclosure is reasonably necessary (i) to prevent fraud; (ii) to comply with any applicable statute, law, rule or regulation; or (iii) to comply with a court order.
• Third-party Vendors and Service Providers. We may, from time to time, outsource services, functions, or operations of our business to third -party service providers. When engaging in such outsourcing, it may be necessary for us to disclose your PII to those service providers, (e.g., a payment service. We will work with any such providers to restrict how the providers may access, use and disclose your PII.
• Protection of Company and Other. We may release PII when we believe release is necessary to comply with the law; enforce or apply our policies and other agreements; or protect the rights, property, or safety of the Company, our contractors, or others. This disclosure will never, however, include selling, renting, sharing or otherwise disclosing your PII for commercial purposes in violation of the commitments set forth in this Privacy Policy.
• Contractor Privacy. All information generated, processed, transmitted and stored on Acuative computing systems and facilities are the property of Acuative. Acuative HR management has the right to examine all information within the company.

7.0 Security of Your PII

We employ reasonable security measures and technologies, such as password protection, encryption, physical locks, etc., to protect the confidentiality of your PII.

Only authorized employees have access to PII. Acuative employee with such authorization will take the appropriate safeguards to protect such PII. Paper and other hard copy containing PII (or any other confidential information) will be secured in a locked location when not in use. Computers and other access points will be secured when not in use by logging out or locking. Passwords and user ID's will be guarded and not shared. When no longer necessary for business purposes, paper and hard copies will be destroyed using paper shredders or similar devices. Copies will not be left in unsecured locations waiting to be shredded or otherwise destroyed. Unauthorized copies of documents or other tangible medium containing PII will not be distributed. Electronic files containing PII will only be stored on secure computers and not copied or otherwise shared with unauthorized individuals within or outside of Acuative. Acuative will make reasonable efforts to secure PII stored or transmitted electronically secure from hackers or other persons who are not authorized to access such information.

Compliance with this Privacy Policy is important to Acuative. Any violation or potential violation of this Policy should be reported to the Director of Human Resources. The failure by any contractor to follow this Privacy Policies or other policies may result in discipline up to and including discharge of the contractor. Any questions or suggestions regarding this policy may also be directed to the Director of Human Resources.

8.0 Updating and Accessing Your Personal Data

You must promptly inform us when changes occur in PII you have provided so that we can maintain accurate information about you. Although you may update or change your PII, we may maintain such PII previously submitted in historical archives

9.0 Enforcement

Any contractor found to have violated this policy may be subject to disciplinary action, up to and including termination of contract.

10.0 Responsibility

This document is maintained by the Director of Human Resources.

11.0 Penalties

Violation of any of the requirements in this policy by any contractor will result in suitable disciplinary action, up to and including prosecution and / or termination.

Violation of any of the requirements in this policy by any Visitor can result in similar disciplinary action against the sponsoring employee, and can also result in termination of services with any associated consulting organization or prosecution in the case of criminal activity.