Information Security Policy

The following company policies and procedures address this issue. Security Awareness and Procedures Keeping Sensitive Information secure requires periodic training of employees and contractors to keep security awareness levels high. The following company policies and procedures address this issue. • Hold periodic security awareness training meetings of employees and contractors to review correct handling procedures for Sensitive Information. Offline Merchant Security Policy • Employees are required to read this security policy and verify that they understand them by signing an acknowledgement form (see Appendix A). • Background checks (such as credit and criminal record checks, within the limits of local law) will be conducted for all employees that handle Sensitive Information. • All third parties with access to credit card account numbers are contractually obligated to comply with card association security standards (PCI/DSS). • Company security policies must be reviewed annually and updated as needed. Security Management / Incident Response Plan There will be an employee of the company designated as the security officer. The security officer is responsible for communicating security policies to employees and contractors and tracking the adherence to policies. In the event of a compromise of Sensitive Information, the security officer will oversee the execution of the incident response plan. Security Management / Incident Response Plan 1. If a compromise is suspected, alert the information security officer. 2. Security officer will conduct an initial investigation of the suspected compromise.

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