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                                                       Security and Privacy Policy


This Security and Privacy Policy ("Policy") outlines our security and privacy policies. It is a work in progress. From time to time, as our business changes, we will update the Policy but the underlying goal of protecting the security of our customers' transmissions and their privacy will remain. We welcome your continuous input into these guidelines. Give us your feedback at

A&P Technology, Inc. ("Impact") has created this Policy in order to demonstrate our firm commitment to security and privacy. The Policy applies to the Impact FAX service and the Impact VoiceMail service (collectively, the "Service"), and does not apply to other online or offline Impact sites, products or services. By accepting our Terms of Service, and/or by using the Impact FAX service or the Impact VoiceMail service, you expressly consent to the security and privacy practices described in this Policy. The capitalized terms in this Policy not defined in this document are defined in the Terms of Service.

DEFINITIONS

"Transmissions" means any pages that are sent to Impact via your dedicated Impact FAX Phone Number.

"Contents" of your Transmissions means any page transmitted through the Service.

PROCESSING OF YOUR TRANSMISSIONS

The Contents of your Transmissions. The Service is intended as a secure passive conduit for the transmission of the Contents of your faxes, to the Recipient via Internet email. Impact does not retain any of the Content transmitted through the Service. To the extent that electronic copies of any Content are created during transmission, such copies will be automatically deleted from Impact's system immediately after the transmission is completed. Once the Contents have been sent to the public Internet, it is no longer under the control of Impact, and Impact shall have no further liability with respect thereto.

Fully Automated System. Impact's system is fully automated and Impact personnel will not review the contents of your Transmissions through the Service, except as necessary to debug errors in Transmissions or in our system, in which case an Impact technician may view the transmission log files. Impact technicians who are authorized to view the extracted logs of transmission have signed written confidentiality agreements with Impact to protect the confidentiality of such information.

Content Pages are Converted During Transmission. Impact's system converts the Contents of your Transmission to electronic format. The Content pages are not de-skewed or materially altered in any way.


OUR SECURITY PRACTICES

Physical Security. Impact's service is currently hosted at a premium, tier one, co-location facility located in Ohio. All fax traffic is delivered via normal Public Switched Telephone Network (PSTN) infrastructure into this secure facility where transmissions are automatically processed and routed to the Internet. Impact's facility offers a wide range of physical security features, including state-of-the-art smoke detection and fire suppression systems, motion sensors, 24x7 secured access, and security breach alarms. Impact reserves the right to expand or change physical locations or co-location providers, but will require future locations and/or co-location providers to have similar or better physical security.

Electronic and Network Security. Impact's entire network is protected by commercial grade, state-of-the art firewalls. The only public network interface between the Internet and your Transmission data is via our outgoing Email servers. Otherwise your Transmissions are firewalled off from external Internet access. Impact's secure system is continuously monitored for attempted intrusions and updated accordingly. Impact reserves the right to modify, change and continually improve the electronic and network security of its system.

Mail Delivery Security. Impact will attempt to deliver your faxes to the Recipient and transmission confirmation emails to the Sender using ESMTP, which is SMTP with Transport Layer Security (TLS) extensions. TLS provides an encrypted tunnel between Impact's mail server and the Recipient's and Sender's mail server. If ESMTP is not available, Impact delivers your email using standard SMTP.

 

OUR DATA PRACTICES

Information Collected by Impact. Impact stores any information that you directly or indirectly provide to Impact ("Collected Information"), with the exception of the Contents of your Transmission. The Collected Information includes, for example, the information you provide when you sign-up for the Service (such as your name, address, financial information, list of registered phone numbers), information received by Impact from its telephone system when calls are made to your dedicated Impact FAX Phone Numbers (such as the phone number from which the call is made, the duration of the call, the number of pages sent), the personal preferences you select for your Account.

General Permissible Uses and Disclosures of the Collected Information. The Collected Information may be used and disclosed by Impact for its general business purposes, including without limitation to provide and customize your services, to process new orders, to verify your identity, for billing purposes, to contact you, and to improve the Services and/or the Web Site. This Collected Information will not be disclosed to any third party.  As this Policy changes from time to time, the use and disclosure of the Collected Information is subject to the Policy in effect at the time of such use and disclosure.

Marketing Practices. Impact will not (a) share any personally identifiable information collected from you with any third parties, and (b) will not collect e-mail address from your Transmissions for the purpose of sending future marketing messages. Impact reserves the right to send you, at the Sender e-mail address, requests for feedback, user tips, information about new features, and other important announcements from Impact and its partners.

 
Other Uses of the Collected Information. Notwithstanding the foregoing, Impact reserves the right to:

(a) provide any of your information to companies or individuals with whom we have contracted to perform services on our behalf (our "Agents"), but only if the Agents have entered into written agreements with us promising the same or a higher level of security and privacy as set forth in this Policy;

(b) transfer all of the information collected about you to its corporate affiliates or to a successor of all or substantially all of its business pertaining hereto, whether by way of merger, sale or transfer of all or substantially all of its assets hereof, consolidation, operation of the law, or otherwise;

(c) collect, preserve and/or disclose your Collected Information and Content, if Impact believes in good faith that such actions are required by law; and

(d) otherwise collect, preserve and/or disclose your Collected Information, but not your Content, if Impact believes in good faith that such actions are necessary to enforce the Agreement, defend itself against claims asserted against Impact, or protect the rights, property, or personal safety of Impact, its users and the public.

 

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