I. Policy Statement

Definitions for the purposes of this Privacy Policy (“Policy”):

  1. An Employee is any director, officer, employee, consultant, and contractor (”Employee) of Toku and all jurisdictional entities (the "Company"), who is performing work in the service of the Company.
  2. A Contributor is any director, officer, employee, consultant, and contractor of Toku and all jurisdictional entities (the "Company"), who is performing work in the service of the Company’s Clients.
  3. A Client is any organization that is an actual or prospective purchaser of either the services or products offered by the Company, and/or that Contributors perform working contribution to (”Clients”).

The purpose of the Privacy Policy is to outline the policies, procedures, and practices to be followed by Toku Employees pertaining to the collection, use, and disclosure of personal information (“Personal Information”) of an identifiable person (“Individual”) that is a present, future or former employee of the Company.

The Company recognizes the confidential nature of the Personal Information in its care and is accountable for the compliance of itself and its directors, officers, employees, consultants, and contractors (”Employees”) in protecting this Personal Information.

This Policy provides guidelines to Employees of the Company with respect to Privacy practices including applicable jurisdictional law and regulation, including, but not limited to federal and state laws. In certain instances, it also applies to consultants and contractors providing services to the Company.

Capitalized terms used in this Policy are defined where they first appear in this Policy.

II. Applicability

The Policy applies to all Personal Information, including any information or collection of information in any form, whether oral, electronic, or written, that pertains to the Individual, excluding publicly available information. Personal Information will also include any publicly available information that is combined with non-publicly available information.

This Policy applies to directors, officers, employees, consultants, and contractors (”Employees”) of the Company and its subsidiaries, entities, and jurisdictions.

This Policy also applies to directors, officers, employees, consultants, and contractors of the Company and its subsidiaries, entities, and jurisdictions, who are performing work in the service of the Company’s Clients (”Contributors”).

III. Specific Guidelines

Personal Information

Personal Information includes but is not limited to name, home address, home phone number, home email address, identity verification information, Social Security Number or other jurisdictionally-issued personal identifier and registration information, physical description, age, gender, salary, education, professional designation, personal hobbies and activities, medical history, employment history, credit history, contents of the resume, references, interview notes, performance review notes, and emergency contact information.

Personal Information will not include the Individual’s business title, business address, and contact information when used or disclosed for the purposes of reasonable business communication.

The Company will implement policies and procedures that give effect to this Privacy Policy, including procedures to protect and secure Personal Information, procedures to receive, investigate, resolve complaints, and procedures to ensure adequate training of the Employees concerning the Company’s Privacy Policies, and procedures to distribute new and current information pertaining to the Company’s Privacy Policy.