Exhibit A - INFORMATION SECURITY POLICY
Introduction
BrandOps considers protection of Customer Data a top priority. As further described in this BrandOps Information Security Policy, BrandOps uses commercially reasonable organizational and technical measures designed to prevent unauthorized access, use, alteration or disclosure of Customer Data stored on systems under BrandOps’ control. BrandOps maintains these security measures in accordance with best practices.
1. Customer Data and Management. BrandOps limits its personnel’s access to Customer Data as follows:
1.1. Requires unique user access authorization through secure logins and passwords, including multi-factor authentication for Cloud Hosting administrator access and individually-assigned Secure Socket Shell (SSH) keys for external engineer access;
1.2. Limits the Customer Data available to BrandOps personnel on a “need to know” basis;
1.3. Restricts access to BrandOps’ production environment by BrandOps personnel on the basis of business need;
1.4. Encrypts user security credentials for production access; and
1.5. Prohibits BrandOps personnel from storing Customer Data on electronic portable storage devices such as computer laptops, portable drives and other similar devices.
1.6. BrandOps logically separates each of its customers’ data and maintains measures designed to prevent Customer Data from being exposed to or accessed by other customers.
2. Data Encryption. BrandOps provides industry-standard encryption for Customer Data as follows:
2.1. Implements encryption in transport and at rest;
2.2. Uses strong encryption methodologies to protect Customer Data, including AES 256-bit encryption for Customer Data stored in BrandOps’ production environment; and
2.3. Encrypts all sensitive Customer Data located in cloud storage while at rest.
3. Network Security, Physical Security and Environmental Controls
3.1. BrandOps uses firewalls, network access controls and other techniques designed to prevent unauthorized access to systems processing Customer Data.
3.2. BrandOps maintains measures designed to assess, test and apply security patches to all relevant systems and applications used to provide the Services.
3.3. BrandOps monitors privileged access to applications that process Customer Data, including cloud services.
3.4. The Services operate on Amazon Web Services (“AWS”) and Google Cloud (“GCS”) and are protected by the security and environmental controls of Amazon and Google, respectively. Detailed information about AWS security is available at https://aws.amazon.com/security/ and http://aws.amazon.com/security/sharing-the-security-responsibility/. For AWS SOC Reports, please see https://aws.amazon.com/compliance/soc-faqs/. Detailed information about GCS security is available at https://cloud.google.com/docs/tutorials#security.
3.5. Customer Data stored within AWS or GCS is encrypted at all times. AWS and GCS do not have access to unencrypted Customer Data.
4. Security Assessments. BrandOps assesses the security of its systems and the Services as follows:
4.1. Regularly scheduled security assessments of the Services that include a code analysis and a comprehensive security review.
4.2. Regularly scheduled penetration testing of BrandOps systems and applications to test for exploits such as XSS, SQL injection, access controls, and CSRF.
4.3. Regularly scheduled vulnerability scanning.
5. Incident Response. If BrandOps becomes aware of unauthorized access or disclosure of Customer Data under its control (a “Breach”), BrandOps will:
5.1. Take reasonable measures to mitigate the harmful effects of the Breach and prevent further unauthorized access or disclosure.
5.2. Upon confirmation of the Breach, notify Customer in writing of the Breach without undue delay. Notwithstanding the foregoing, BrandOps is not required to make such notice to the extent prohibited by Laws, and BrandOps may delay such notice as requested by law enforcement and/or in light of BrandOps’ legitimate needs to investigate or remediate the matter before providing notice.
5.3. Each notice of a Breach will include:
5.3.1. The extent to which Customer Data has been, or is reasonably believed to have been, used, accessed, acquired or disclosed during the Breach;
5.3.2. A description of what happened, including the date of the Breach and the date of discovery of the Breach, if known;
5.3.3. The scope of the Breach, to the extent known; and
5.3.4. A description of BrandOps’ response to the Breach, including steps BrandOps has taken to mitigate the harm caused by the Breach.
6. Business Continuity Management
6.1. BrandOps maintains an appropriate business continuity and disaster recovery plan.
6.2. BrandOps maintains processes to ensure failover redundancy with its systems, networks and data storage.
7. Personnel Management
7.1. BrandOps performs employment verification, including proof of identity validation and criminal background checks for all new hires, including contract employees, in accordance with applicable law.
7.2. BrandOps provides training for its personnel who are involved in the processing of the Customer Data to ensure they do not collect, process or use Customer Data without authorization and that they keep Customer Data confidential, including following the termination of any role involving the Customer Data.
7.3. BrandOps conducts routine and random monitoring of employee systems activity.
7.4. Upon employee termination, whether voluntary or involuntary, BrandOps immediately disables all access to BrandOps’ systems and physical facilities.