EU-US PRIVACY SHIELD PRIVACY POLICY

20/20 Software hosts websites and enterprise management systems (EMS) for clients in the European Economic Area (EEA) (which includes the twenty-eight member states of the European Union (EU) plus Iceland, Liechtenstein and Norway). We do not request, nor gather, nor store personal information about any individuals on our own behalf or for any purpose of our own. We provide a safe and secure storage and processing facility for such information gathered by our clients on their websites and EMS hosted by us.

20/20 Software complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. 20/20 Software has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

To learn more about the Privacy Shield program, and to view our certification page, please visit www.privacyshield.gov

20/20 Software respects individual privacy and values the confidence of its clients, their customers, our business partners and others. Not only do we strive to store personal information in a manner consistent with the laws of the countries in which we do business, but we also have a tradition of upholding the highest ethical standards in our business practices. 20/20 Software is subject to the investigatory and enforcement policies of the Federal Trade Commission. This US-EU Privacy Shield Privacy Policy (the "Policy") sets forth the privacy principles 20/20 Software follows with respect to transfers of personal information from the EEA to the United States.

Note: It must be emphasized that 20/20 Software does not have control over the uses to which our clients may make of personal information disclosed to them.

EU-US PRIVACY SHIELD

The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EEA to the United States (the "EU-US Privacy Shield"). The EEA also has recognized the EU-US Privacy Shield as providing adequate data protection (Directive 95/46/EC ). Consistent with our commitment to protect personal privacy, 20/20 Software adheres to the principles set forth in the EU-US Privacy Shield (the “EU-US Privacy Shield Principles”).

SCOPE

This EU-US Privacy Shield Privacy Policy (the "Policy") applies to all personal information received by 20/20 Software in the United States from the EEA, in any format, including electronic, paper or verbal.

DEFINITIONS

For purposes of this Policy, the following definitions shall apply:

"Agent" means any third party that collects or uses personal information under the instructions of, and solely for, 20/20 Software.

"Client" means any customer of 20/20 Software, located in the EEA, for whom we host a website or enterprise management system on our servers in the United States.

"20/20 Software" means 20/20 Software, Inc., its predecessors, successors, subsidiaries, divisions and groups in the United States.

"Personal information" means any information or set of information that identifies or could be used by or on behalf of 20/20 Software to identify an individual. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.

PRIVACY PRINCIPLES

NOTICE:

20/20 Software does not collect personal information directly from individuals in the EEA. Where 20/20 Software receives, stores, or processes personal information from our clients in the EEA, we will use and disclose such information in accordance with the notices provided by our clients, only if consistent with the EU-US Privacy Shield Principles, and the choices made by the individuals to whom such personal information relates. We will endeavor, as much as is practicable, to enable our clients to publish and follow the EU Data Protection Directive on their websites that we host.

CHOICE:

20/20 Software will enable our clients to offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. 20/20 Software will enable our clients to provide individuals with reasonable mechanisms to exercise their choices.

ACCOUNTABILITY FOR ONWARD TRANSFER:

20/20 Software does not transfer data to third parties outside of its agents. 20/20 Software will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is required by the relevant EU-US Privacy Shield Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), EU-US Privacy Shield certification by the agent, or being subject to another European Commission adequacy finding (e.g., companies located in Canada). Where 20/20 Software has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, 20/20 Software will take reasonable steps to prevent or stop the use or disclosure. 20/20 Software is liable for appropriate onward transfers of personal data to third parties who do not comply with the Privacy Shield principles.

Please be aware that 20/20 Software may be required to disclose an individual's personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

SECURITY:

20/20 Software will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

DATA INTEGRITY AND PURPOSE LIMITATION:

20/20 Software does not use personal information provided by individuals to our clients. When directed by our clients to process such information, 20/20 Software will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. 20/20 Software will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.

ACCESS AND RECOURSE

EU Individuals have the right to access their personal information. Upon request, and with consent of our clients, 20/20 Software will grant individuals access to personal information that it holds about them. In addition, 20/20 Software will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. Note that all websites that 20/20 Software hosts provide a personal profile page that allows the user to modify their personal information and/or request deletion of their account.

ENFORCEMENT AND LIABILITY:

20/20 Software will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that 20/20 Software determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.

DISPUTE RESOLUTION:

Any questions or concerns regarding the use or disclosure of personal information should first be directed to the owner of the website in question (our Client); or if the question or concern is from our Client, then to 20/20 Software at the address given below. 20/20 Software will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information by reference to the principles contained in this Policy. For complaints that cannot be resolved between 20/20 Software and the complainant, 20/20 Software has agreed to participate in the following dispute resolution procedures in the investigation and resolution of complaints to resolve disputes pursuant to the EU-US Privacy Shield Principles:

20/20 Software has committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint.

Finally, as a last resort and in limited situations, EU individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism.

LIMITATION ON APPLICATION OF PRINCIPLES:

Adherence by 20/20 Software to these EU-US Privacy Shield Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations; (c) to the extent expressly permitted by an applicable law, rule or regulation; and (d) to the extent that 20/20 Software has limited or no control over the actions of its Clients regarding use of personal information that they have collected.

INTERNET PRIVACY

20/20 Software recognizes the importance of maintaining the privacy of information collected online and has created a specific Internet Privacy Policy (the "IPP") governing the treatment of personal information collected through web sites that it operates. This IPP is a privacy template to be used by our Clients as a model in developing or updating their website. With respect to personal information that is transferred from the European Economic Area to the U.S., the IPP is subordinate to this Policy. However, the IPP also reflects additional legal requirements and evolving standards with respect to Internet privacy. 20/20 Software's Internet Privacy Policy can be found at: http://www.twensoft.com/ipp_privacy

CONTACT INFORMATION

Questions or comments regarding this Policy should be submitted to the 20/20 Software by mail to:

20/20 Software, Inc.
2001 West Main Street, Suite 270
Stamford, Connecticut 06902
United States

Or by e-mail to info@twensoft.com

CHANGES TO THIS EU-US PRIVACY SHIELD PRIVACY POLICY

This Policy may be amended from time to time, consistent with the requirements of the EU-US Privacy Shield Principles. A notice will be posted on the 20/20 Software web page (www.twensoft.com) for 60 days whenever this EU-US Privacy Shield Privacy Policy is changed in a material way.

EFFECTIVE DATE: AUGUST 1, 2016