JUSTFAB JUSTFAB ACCEPTABLE USE POLICY - VERSION CONTROL

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JustFAB

              JustFAB Acceptable Use
                              Policy

                             Version Control
 Version      Date          Author             Modifications
1.0        6/24/2014    Jason Loomis, VP IT               Initial release
                       Security/Operations

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1. Overview

       The functioning and success of JustFAB is critically dependent on information
       and information systems. If important information were disclosed to
       inappropriate or unauthorized persons, the company could be held financially
       liable by our customers and partners. The good reputation that JustFAB is
       establishing is also directly linked with the way that it manages both information
       and information systems. For example, if private customer information were to
       be publicly disclosed, the organization’s reputation would be harmed as well as
       subjecting JustFAB to serious risk of lawsuits. Executive management has
       initiated and continues to support an information security effort. One part of
       that effort is the definition of these information security policies.

       To be effective, information security must be a team effort involving the
       participation and support of every JustFAB worker who deals with information
       and information systems. In recognition of the need for teamwork, this policy
       statement clarifies the responsibilities of users and the steps they must take to
       help protect JustFAB information and information systems.

2. Purpose
      The purpose of this policy is to outline the acceptable use of computer
      equipment, networks and infrastructure at JustFAB and to ensure rules are in
      place to protect JustFAB workers and JustFAB.

3. Scope
      This policy applies to employees, contractors, consultants, interns, vendors and
      other workers at JustFAB, including all personnel affiliated with third parties.

       This policy applies to all computer and network systems owned, leased, licensed
       or administered by JustFAB. This includes, but is not limited to all operating
       systems, computer systems, and application systems. The policy covers only
       information handled by computers and networks. Although this document
       includes mention of other manifestations of information such as voice and
       paper, it does not directly address the security of information in these forms. For
       information about the protection of information in paper form, see the
       employee handbook.

4. Policy

   4.1. Need to know
       Access to information in the possession of, or under the control of JustFAB must
       be provided based on a need to know. Information must be disclosed only to
       people who have a legitimate business need for the information. Workers must

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not attempt to access sensitive information unless the appropriate management
   has granted them access. When a worker changes job duties, including
   termination, transfer, promotion and leave of absence, his or her supervisor
   must immediately notify Human Resources.

4.2. Information Classification

   JustFAB has adopted an information classification system that categorizes
   information into three groupings. All information under JustFAB control,
   whether generated internally or externally, falls into one of these categories:
   Secret, Confidential, or Public. All workers must familiarize themselves with the
   definitions for these categories and the steps that must be taken to protect the
   information within each of these categories. Details can be found in the JustFAB
   Information Classification Standard. For purposes of this policy, “sensitive
   information” is information that falls into either the Secret or Confidential
   categories.

   4.2.1.     Secret

   This classification label applies to the most sensitive business information that is
   intended for use strictly within JustFAB. Its unauthorized disclosure could
   seriously and adversely impact JustFAB, its customers, its business partners, and
   its suppliers. Examples include but are not limited to merger and acquisition
   documents, corporate level strategic plans, litigation strategy memos, reports on
   breakthrough new product research, and Trade Secrets such as certain computer
   code or programs.

   4.2.2.     Confidential

   This classification label applies to less-sensitive business information that is
   intended for use within JustFAB. Its unauthorized disclosure could adversely
   impact JustFAB or its customers, suppliers, business partners, or employees.
   Information that some people would consider to be private is included in this
   classification. Examples include employee performance evaluations, customer
   transaction data, strategic alliance agreements, unpublished internally-
   generated market research, computer passwords, identity token personal
   identification numbers, and internal audit reports. Personally Identifiable
   Information, Credit Card information, and other applicable information is an
   example of Confidential Information. If Information or a system has no label or
   is not known, it is to be considered confidential and handled according to the
   “confidential” rating noted within this policy.

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4.2.3.     Public

   This classification applies to information that has been approved by JustFAB
   management for release to the public. By definition, there is no such thing as
   unauthorized disclosure of this information and it may be disseminated without
   potential harm. Examples include finalized product and service brochures,
   advertisements, job opening announcements, and press releases.

   4.2.4.     Additional Information

   For additional guidance on labeling and handling of secret and confidential
   information refer to the JustFAB Information Classification Standard or contact
   the IT Security Department.

4.3. User IDs and Passwords

   JustFAB requires that each worker accessing multi-user information systems
   have a unique user ID and a private password. Each worker is personally
   responsible for the usage of his or her user ID and password. Passwords must
   follow the guidelines below (for additional guidance, refer to the JustFAB
   Information Security Policy on the selection of IT Security approved passwords.

             Minimum password requirements
                      Your password must be at least 8 characters long
                      Your password cannot contain more than two consecutive
                       characters of your full name
                      Your password must contain characters from three of the four
                       following categories:
                           o English uppercase characters (A through Z)
                           o English lowercase characters (a through z)
                           o Base 10 digits (0 through 9)
                           o Non-alphabetic characters (all symbols)

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Difficult-to-guess passwords - passwords must not be related to one’s
              job or personal life or be common words found in a dictionary
              (regardless of language).

              Repeated password patterns - Users must not construct passwords
              that are identical or substantially similar to passwords they have
              previously employed.

              Password storage - Passwords must not be stored in readable form in
              batch files, automatic logon scripts, software macros, terminal
              function keys, in computers without access control systems, or in
              other locations where unauthorized persons might discover them.
              Passwords must not be written down in some readily-decipherable
              form and left in a place where unauthorized persons might discover
              them.

              Sharing passwords - Passwords must never be shared with or revealed
              to others except when first created by IT.

              Suspected unauthorized use - If a user believes that his or her user ID
              and password are being used by someone else, the user must
              immediately notify Info Sec

4.4. Release of Information to Third Parties
    Unless it has specifically been designated as public information, all JustFAB
    internal information must be protected from disclosure to third parties. Third
    parties may be given access to JustFAB internal information only when a
    demonstrable need to know exists and when a JustFAB non-disclosure
    agreement has been signed. If sensitive information is lost, is disclosed to
    unauthorized parties, or is suspected of being lost or disclosed to unauthorized
    parties, the Security Department must be notified immediately.

4.5. Physical Security to Control Information Access
    Access to every office, computer machine room, and other JustFAB work area
    containing sensitive information must be physically restricted to those people
    with a need to know. When not in use, Secret/Confidential information must
    always be protected from unauthorized disclosure. Workers must position their
    computer screens such that unauthorized people cannot look over their shoulder
    and see the Secret/Confidential information displayed.

4.6. Network Connections
    All JustFAB computers that store Secret/Confidential information and that are
    permanently or intermittently connected to internal computer networks must

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have a password-based access control system. Users working with all other types
   of computers must employ the screen saver passwords that are provided with
   operating systems, so that after a period of no activity the screen will go blank
   until the correct password is again entered. Multi-user systems throughout
   JustFAB must employ automatic log off systems that automatically terminate a
   user’s session after a defined period of inactivity.

   It is prohibited to enable your computer as a hotspot while connected to the
   JustFAB corporate or wireless networks. Only approved IT network devices are
   allowed on the JustFAB corporate network, this includes, but is not limited to,
   wireless access points, network hubs/switches, and media devices such as
   Sonos/Roku for example.

   When using JustFAB computers, JustFAB workers must not establish connections
   with external networks including, but not limited to, Internet Service Providers,
   anonymizers, or remote access software to non-JustFAB systems, unless these
   connections have been approved by the IT Security Department.

4.7. Internet Access
    Workers are provided with Internet access to perform their job duties. All
    information received from the Internet should be considered to be suspect until
    confirmed by reliable sources. Secret/Confidential information, including, but
    not limited to, passwords and credit card numbers, must not be sent across or
    placed on the Internet unless this information is encrypted and such
    transmission has been authorized. These and related considerations are
    discussed in greater detail in the Internet Communications Standard and the
    Electronic Mail Standard. Using company provided Internet access to view or
    store to offensive or objectionable material or information is
    prohibited. Workers are prohibited from using company provided Internet
    access to engage in any actions that violate any federal, state or local laws or
    regulations. These and related considerations are discussed in greater detail in
    the Internet Communications Standard and the Electronic Mail Standard.

   4.7.1.      Electronic Mail
   Every JustFAB worker who uses computers in the course of their regular job
   duties will be provided JustFAB email address. A personal Internet service
   provider electronic mail account or any other electronic mail address must not
   be used for JustFAB business. These and related considerations are discussed in
   greater detail in the Electronic Mail Standard. Using electronic mail to send
   offensive or objectionable material or information is prohibited. Workers are
   prohibited from using the company’s electronic mail to transmit or receive any
   information in violation of federal, state or local laws or regulations, including

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trade secrets. These and related considerations are discussed in greater detail in
   the Internet Communications Standard and the Electronic Mail Standard.

4.8. Security Software
    All personal computers provided by JustFAB may have security software installed
    and enabled. Workers must not bypass, tamper, modify, remove or disable any
    security software.

   4.8.1.      Malicious software

   All computers connected to the JustFAB network must have approved anti-
   malware software installed as applicable. Any non-JustFAB managed anti-
   malware software must have the most current updates. Anti-malware screening
   software must be used to scan all software and data files coming from third
   parties. This scanning must take place before new data files are opened and
   before new software is executed. If workers suspect infection by malware they
   must immediately stop using the involved computer, disconnect from the
   network, and notify the JustFAB Servicedesk.

4.9. Software
    JustFAB computers and networks must not run software that comes from
    sources other than other JustFAB, knowledgeable and trusted user groups, well-
    known systems security authorities, or established computer, network, or
    commercial software vendors. Users must not copy software provided by
    JustFAB to any storage media, transfer such software to another computer, or
    disclose such software to outside parties without advance permission from their
    manager.

4.10. Backup Responsibility

   Backups are not generally provided for personal computers. Any data that may
   require a backup located on the user’s personal computer, must be
   copied/moved to a JustFAB provided network resource. Third party backup
   solutions are strictly prohibited.

4.11. Right to Search and Monitor
   JustFAB management reserves the right to monitor, inspect, or search at any
   time all JustFAB information systems, networks, files and emails. This
   examination may take place with or without the consent, presence, or
   knowledge of the involved workers. All searches of this naturewill be conducted
   after the approval of the Legal and Security departments has been obtained.
   Because JustFAB computers and networks are provided for business purposes
   only, and at all times remain the property of JustFAB, workers have no

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expectation of privacy associated with the information they store in or send
       through these information systems, networks and/or devices.

   4.12. Personal Use
      JustFAB information systems are intended to be used for business purposes only.
      Incidental personal use is permissible if the use does not consume more than a
      trivial amount of resources that could otherwise be used for business purposes,
      does not interfere with worker productivity, does not preempt any business
      activity and is appropriate within a business environment.

   4.13.   Security Testing

       Unless specifically authorized by the IT Security Department, JustFAB workers
       must not acquire, possess, trade, or use hardware or software tools that could
       be employed to evaluate or compromise information systems security. Without
       this type of approval, workers are prohibited from using any hardware or
       software that monitors the traffic on a network or the activity on a computer.

5. Violation and Incident Reporting
      All JustFAB workers must report suspected violations of this policy or any other
      Information Security policy or standard. Additionally, all JustFAB workers will
      report to the IT Security Department any actual or suspected security issues or
      losses including, but not limited to, system intrusions, malicious software
      infestations, and other conditions that might jeopardize JustFAB information or
      JustFAB information systems.

6. Enforcement
      Failure to comply with, or violation of, these polices may subject workers to
      disciplinary warnings and/or disciplinary action including possible termination
      and prosecution.

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