FLASHTRACT SECURITY & PRIVACY POLICY

Flashtract, Inc. (“Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes the types of information we may collect from you or that you may provide when you visit the website


www.flashtract.com or use any of our related software services (the “Services”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect: (i) on the Company website, (ii) in email, text, and other electronic messages between you and the Company, (iii) through mobile and desktop applications you download from the Company website, (iv) when you interact with our advertising and applications on third-party websites and services, (v) or otherwise during the course of our engagement with you.

It does not apply to information collected by: (i) the Company offline or through any other means, including on any other website operated by Company or any third party, or (ii) any third party, including through any application or content (including advertising) that may link to or be accessible from or on our website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Services. By accessing or using our Services, you agree to this privacy policy. This policy may change from time to time. Your continued use of the Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Virus Prevention Policy

All desktop systems that connect to Flashtract's network must be protected with an approved, licensed anti-virus software product that it is kept updated according to the vendor's recommendations. All servers and workstations that connect to the network and that are vulnerable to virus or worm attack must be protected with an approved, licensed anti-virus software product that it is kept updated according to the vendor's recommendations.

Intrusion Detection Policy

Intruder detection is implemented on all servers and workstations containing data classified as high risk. Operating system and application software logging processes are enabled on all host and server systems.

Internet Security Policy

All connections to the Internet go through a properly secured connection point to ensure the network is protected when the data is classified confidential.

System Security Policy

All systems connected to the Internet should have a supported version of the operating system installed. All systems connected to the Internet must be current with security patches.

Acceptable Use Policy

It is against Flashtract policy to install or run software requiring a license on any Flashtract computer without a valid license. Decryption of external or internal passwords is not permitted, except by authorized staff performing security reviews or investigations. Use of network sniffers shall be restricted to system administrators who must use such tools to solve network problems. Auditors or security officers in the performance of their duties may also use them.

Privacy Policy

Flashtract recognizes that privacy is important. This policy applies to all of the SAAS products, services, and websites owned and offered by Flashtract, Inc. If you have any questions about this policy, please feel free to write to us at:

Flashtract, Inc.

75 14th St. NE

Suite 3050

Atlanta, GA 30309

Attn: Chief Executive Officer

Information We Collect And How We Use It:

We offer a number of Services that may or may not require you to register for an account or provide any personal information to us. In order to provide our full range of SAAS Services, we may collect many types of information, including, but not limited to, the following: IP addresses, login credentials, browser type, number of invoices processed, invoice approval rate, time it takes to approve invoices, time it takes to issue payments, number of projects, size of projects, duration of projects, project cash flow position, time spent on our software, and financial data. This information stays in our company and may be shared with authorized vendors and other parties related to your transactions using our software.

Information You Provide – When you sign up for a Flashtract account or other Flashtract service or promotion that requires registration, we ask you for personal information (such as your name, email address and an account password). For certain Services, we also may request credit card, bank account and routing numbers or other payment account information which we maintain securely. We may combine the information you submit under your account with information from other Flashtract services or third parties in order to provide you with a better experience and to improve the quality of our Services. For certain Services, we may give you the opportunity to opt out of combining such information.

Cookies – When you visit Flashtract, we send one or more cookies – a small file containing a string of characters – to your computer or other device that uniquely identifies your browser. We use cookies to improve the quality of our service to you, our valued customer, including for storing user preferences, improving search results, and tracking user trends.

Log Information – When you access Flashtract website, our servers record information that your browser sends whenever you visit a website. These server logs may include information such as your web request, Internet Protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser.

Consent To Our Communication With You By E-Mail – By establishing a registered account with us, and/or each time you make a purchase through our site, you grant permission for Flashtract to contact you at your e-mail address provided to us. To stop receiving our newsletters, promotional/marketing, or special announcement e-mails follow the opt-out procedures set forth at the bottom of each email sent to you by our company.

Other Sites – This policy applies to Flashtract website and SAAS Services. We do not exercise control over external links from our site to other third-party sites. These other sites may place their own cookies or other files on your computer, collect data or solicit personal information from you not related to Flashtract. Flashtract only processes personal information for the purposes described in this policy and/or the supplementary privacy notices for specific services. In addition to the above, such purposes include: (i) Providing our products & Services, including the display of customized content and product presentations; (ii) Auditing, research and analysis in order to maintain, protect, and improve our products & Services; (iii) Ensuring the technical functioning of our website; (iv) Protecting the rights or property of Flashtract or our users; and (v) Developing new services.

Choices for Personal Information

When you sign up as a registered user on Flashtract that requires registration, we ask you to provide personal information. If we use this information in a manner different than the purpose for which it was collected, then we will ask for your consent prior to such use. If we propose to use personal information for any purposes other than those described in this policy and/or in the specific service privacy notices, we will offer you an effective way to opt out of the use of personal information for those other purposes. We will not collect or use sensitive information for purposes other than those described in this policy and/or in the supplementary service privacy notices, unless we have obtained your prior consent. Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some Flashtract features, SAAS products may not function properly if your cookies are disabled. You can decline to submit personal information to any of our Services, in which case Flashtract may not be able to provide those Services to you.

Information Security

We take reasonable security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data.

Data Integrity

Flashtract processes personal information only for the purposes for which it was collected and in accordance with this policy or any applicable service-specific privacy notice. We take reasonable steps to ensure that the personal information we process is accurate, complete, and current, but we depend on our users to update or correct their personal information whenever necessary.

Accessing and updating personal information

When you use Flashtract software, we make good faith efforts to provide you with access to your personal information and either to correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes. We ask our online customers to identify themselves and the information requested to be accessed, corrected or removed before processing orders.

Enforcement

Flashtract regularly reviews its compliance with this policy. Please feel free to direct any questions or concerns regarding this policy or Flashtract’s treatment of personal information by writing to us at:

Flashtract, Inc.

74 14th St NE

Suite 3050

Atlanta, GA 30309

Attn: Chief Executive Officer

Changes to Our Privacy Policy

Please note that this policy may change from time to time. We will post any policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain Services, email notification of policy changes). If you have any additional questions or concerns about this policy, please feel free to contact us any time.