Spring Systems Privacy and Data Handling policy:

Spring Systems is committed to manage, handle, and use customer information and data in a careful and responsible manner.  While such information or data may be accessed from, or stored on, a company or third-party computer or device, this expectation of responsibility remains in force.

The protection of confidential information whether it is customer information or company information is vital to the interests and success of Spring Systems and our customers. Such confidential information includes, but is not limited to the following items:

• Customer information and preferences
• Vendor or seller order detail including but not limited to end consumer name and detail.
• Spring Systems business information
• New material research
• Scientific data
• Technological data
• Proprietary processes
• Inventions
• Trade secrets
• New products
• Formulas
• Marketing plans
• Pricing strategies and information
• Computer systems and programs
• Terms of agreement with suppliers or customers
• Financial data
• Business plans
• Budgets
• Forecasts
• Unpublished financial statements
• Licenses
• Supplier lists and budgets
• Software programs and other tangible property and specifications owned by Spring Systems

Transactional Data Handling - Transactional data can include order and other transactional information including but not limited to end consumer Personal Identifiable Information (PII). PII is defined as: Any representation of information that permits the identity of an individual to whom the information applies to be reasonably inferred by either direct or indirect means. PII Transactional Data is collected on behalf of Spring Systems customers and is stored in encrypted format. Access and usage of PII Transactional Data is restricted by role based security profiles to limit access to only those users that require access to complete their processing responsibility. PII Transactional data is disposed of 90 days after transaction completion. PII Transactional data is not to be shared.

Employees shall not disclose or discuss confidential information with anyone outside the Company without written permission of the President of Spring Systems. Under no circumstances are confidential materials, documents, or other information to be removed from Spring Systems’ premises without the prior express permission of the President of the Company.

As a condition of employment with Spring Systems, certain employees may be required to sign and abide by separate written agreements covering restrictive covenants that may include confidentiality, non-solicitation, and non-competition clauses. Copies of such agreements will be provided to the employee and kept in the employee’s personnel file. These documents are designed to safeguard Spring Systems’ proprietary information.

This policy is not intended to interfere with protected concerted activity or infringe on employee rights under applicable state and federal regulations.