Information Security Policy

Introduction

Belay Inc. (Belay) considers protection of Customer Data a top priority. As further described in this Belay Information Security Policy, Belay uses commercially reasonable organizational and technical measures designed to prevent unauthorized access, use, alteration or disclosure of Customer Data stored on systems under Belay's control.

1. Customer Data and Management

Belay 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 Belay personnel on a “need to know” basis;

1.3. Restricts access to Belay's production environment by Belay personnel on the basis of business need;

1.4. Encrypts user security credentials for production access; and

1.5. Prohibits Belay personnel from storing Customer Data on electronic portable storage devices such as computer laptops, portable drives and other similar devices.

1.6. Belay 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

Belay provides industry-standard encryption for Customer Data as follows:

2.1. Uses strong encryption methodologies to protect Customer Data, including AES 256-bit encryption for Customer Data stored in Belay's production environment; and

2.2. Encrypts all Customer Data located in cloud storage while at rest.

3. Network Security, Physical Security and Environmental Controls

3.1. Belay uses firewalls, network access controls and other techniques designed to prevent unauthorized access to systems processing Customer Data.

3.2. Belay maintains measures designed to assess, test and apply security patches to all relevant systems and applications used to provide the Services.

3.3. Belay monitors privileged access to applications that process Customer Data, including cloud services.

3.4. The Services operate on Amazon Web Services ("AWS") and the Vercel platform and are protected by the security and environmental controls of Amazon and Vercel, 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/. Information about Vercel security is available at https://vercel.com/security.

3.5. Customer Data stored within AWS is encrypted at all times.

4. Incident Response

If Belay becomes aware of unauthorized access or disclosure of Customer Data under its control (a "Breach"), Belay will:

4.1. Take reasonable measures to mitigate the harmful effects of the Breach and prevent further unauthorized access or disclosure.

4.2. Upon confirmation of the Breach, notify Customer in writing of the Breach without undue delay. Notwithstanding the foregoing, Belay is not required to make such notice to the extent prohibited by Laws, and Belay may delay such notice as requested by law enforcement and/or in light of Belay's legitimate needs to investigate or remediate the matter before providing notice.

4.3. Each notice of a Breach will include:

4.3.1. The extent to which Customer Data has been, or is reasonably believed to have been, used, accessed, acquired or disclosed during the Breach;

4.3.2. A description of what happened, including the date of the Breach and the date of discovery of the Breach, if known;

4.3.3. The scope of the Breach, to the extent known; and

4.3.4. A description of Belay's response to the Breach, including steps Belay has taken to mitigate the harm caused by the Breach

5. Business Continuity Management

5.1. Belay maintains an appropriate business continuity and disaster recovery plan.

5.2. Belay maintains processes to ensure failover redundancy with its systems, networks and data storage.

6. Personnel Management

6.1. Belay performs employment verification, including proof of identity validation and criminal background checks for all new hires, including contract employees, in accordance with applicable law.

6.2. Belay 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.

6.3. Belay conducts routine and random monitoring of employee systems activity.

6.4. Upon employee termination, whether voluntary or involuntary, Belay immediately disables all access to Belay systems, including Belay's physical facilities