Security

Information Security Policy
Veloframe, developed and maintained by IT IS CHAOS, Inc.

Last updated: May 05, 2022

Veloframe considers protection of subscriber data a top priority. As further described in this Information Security Policy, Veloframe uses commercially reasonable organizational and technical measures designed to prevent unauthorized access, use, alteration or disclosure of subscriber data stored on systems under our control.

Subscriber Data and Management,

Veloframe limits its personnel’s access to subscriber data as follows:

• Requires unique user access authorization through secure logins,
• Limits the subscriber data available to Veloframe personnel on a “need to know” basis;
• Restricts access to Veloframe’ production environment by Veloframe personnel on the basis of business need;
• Encrypts user security credentials for production access.
• Veloframe logically separates each of its subscribers’ data and maintains measures designed to prevent susbcriber data from being exposed to or accessed by other customers.

Data Encryption,

Veloframe provides industry-standard encryption for subscriber data as follows:

• Implements encryption in transport and at rest;
• Uses strong encryption methodologies to protect subscriber data, including AES 256-bit encryption for subscriber data stored in Veloframe’ production environment; and
• Encrypts all subscriber data located in cloud storage while at rest.

Network Security, Physical Security and Environmental Controls

• Veloframe uses firewalls, network access controls and other techniques designed to prevent unauthorized access to systems processing subscriber data.
• Veloframe maintains measures designed to assess, test and apply security patches to all relevant systems and applications used to provide the Services.
• Veloframe monitors privileged access to applications that process subscriber data, including cloud services.
• The Services operate on Heroku and Amazon Web Services (“AWS”) and are protected by the security and environmental controls of Heroku and AWS. Detailed information about Heroku security is available at https://heroku.com/security/. 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/.
• Subscriber data stored within Heroku is encrypted at all times. Heroku does not have access to unencrypted subscriber data.

Incident Response,

If Veloframe becomes aware of unauthorized access or disclosure of subscriber data under its control (a “Breach”), Veloframe will:

• Take reasonable measures to mitigate the harmful effects of the Breach and prevent further unauthorized access or disclosure.
• Upon confirmation of the Breach, notify customer in writing of the Breach without undue delay. Notwithstanding the foregoing, Veloframe is not required to make such notice to the extent prohibited by applicable laws, and Veloframe may delay such notice as requested by law enforcement and/or in light of Veloframe legitimate needs to investigate or remediate the matter before providing notice.

Each notice of a Breach will include:

• The extent to which subscriber data has been, or is reasonably believed to have been, used, accessed, acquired or disclosed during the Breach;
• A description of what happened, including the date of the Breach and the date of discovery of the Breach, if known;
• The scope of the Breach, to the extent known; and
• A description of Veloframe’ response to the Breach, including steps Veloframe has taken to mitigate the harm caused by the Breach.

Personnel Management

• Veloframe performs employment verification, including proof of identity validation and criminal background checks for all new hires in accordance with applicable law.
• Veloframe provides training for its personnel who are involved in the processing of the subscriber data to ensure they do not collect, process or use subscriber data without authorization and that they keep subscriber data confidential, including following the termination of any role involving the subscriber data.
• Veloframe conducts routine and random monitoring of employee systems activity.
• Upon employee termination, whether voluntary or involuntary, Veloframe immediately disables all access to Veloframe systems.