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Introduction
We take ÌìÃÀÍøÕ¾´«Ã½´«Ã½ security seriously. The security of your data is one of our most important responsibilities. This document explains what we do to keep your data secure.
Personnel security
All employees and independent contractors who work with ÌìÃÀÍøÕ¾´«Ã½´«Ã½ and have access to our internal systems are required to understand and follow our internal policies and standards. Before accessing our systems, all workers agree to confidentiality terms and attend security training. This training covers privacy and security, acceptable use, preventing malware, account management, physical security and data privacy.
While working with ÌìÃÀÍøÕ¾´«Ã½´«Ã½, everyone is required to refresh privacy and security training annually. They are also required to acknowledge that they have read and understand our information security policy and incident response plan. Some employees who have elevated access to our systems and data receive additional job-specific training on privacy and security.
Upon termination of work at ÌìÃÀÍøÕ¾´«Ã½´«Ã½, all access to ÌìÃÀÍøÕ¾´«Ã½´«Ã½ systems is removed immediately.
Physical security
ÌìÃÀÍøÕ¾´«Ã½´«Ã½ is hosted with Amazon Web Services (AWS) in their Canadian Region. AWS delivers a scalable, cloud-computing platform designed for high availability and dependability. Among the many benefits of using cloud services, a big one is that expensive physical security systems can be implemented, as the cost of these is spread across thousands of customers.
Secure by design
ÌìÃÀÍøÕ¾´«Ã½´«Ã½ follows a Secure Development Lifecycle. During the design phase, our product team assesses and qualifies any possible security issues. The risk analysis leverages the product team’s experience and aligns with OWASP Top 10 development practices.
All code is checked into our version-controlled repository, and code changes are reviewed by peers. ÌìÃÀÍøÕ¾´«Ã½´«Ã½ has a dedicated application testing team, and all software releases pass rigorous testing before being released to production.
The ÌìÃÀÍøÕ¾´«Ã½´«Ã½ application is deployed on hardened systems, and our development operations team follows recommended practices to secure our OS and web servers. We perform active inspection of vulnerabilities and maintain server-level firewalls.
Our web application performs input validation and safely encodes output. All data transmitted between client and server is done via HTTPS. The ÌìÃÀÍøÕ¾´«Ã½´«Ã½ application uses server-side sessions with defined user roles, user authentication and password management.
Protecting customer data
Compliance certifications and attestations
ÌìÃÀÍøÕ¾´«Ã½´«Ã½ is committed to achieving and maintaining the trust of our customers. As part of this commitment, ÌìÃÀÍøÕ¾´«Ã½´«Ã½ maintains compliance standards aligned with industry best practices, regulatory, federal/state rulings, international/regional laws, and industry-specific requirements.
Data encryption
ÌìÃÀÍøÕ¾´«Ã½´«Ã½ uses strong encryption when transmitting data over public networks, including the use of TLS 1.2 and 1.3 protocols, AES-256 encryption and SHA signatures. This is the standard internet communication encryption used by all e-commerce sites, banking and other high security web-based systems.
We use AWS RDS encryption (we encrypt our database and snapshots). Amazon RDS encrypted instances use the industry standard AES-256 encryption algorithm to encrypt your data on the server that hosts your Amazon RDS instance.
Backups
ÌìÃÀÍøÕ¾´«Ã½´«Ã½ maintains nightly backups of all data, database and customer specific files. We maintain redundant copies at a second Canadian hosting provider. In the event of any data loss, we are able to restore our database and other data from these backups. Our development operations team practices data recovery regularly.
Penetration testing
ÌìÃÀÍøÕ¾´«Ã½´«Ã½ regularly performs application and infrastructure penetration testing. Our security and development team review and prioritize any reported findings. All critical and high priority issues are resolved before being released to our production environment.
Network security
ÌìÃÀÍøÕ¾´«Ã½´«Ã½ maintains separate network environments to protect more sensitive data. Systems supporting testing, development, marketing, customer results sites and our corporate network are separate from our production systems. Administration access to our production systems is limited to our development operations team.
Authentication
Where possible, ÌìÃÀÍøÕ¾´«Ã½´«Ã½ uses multi-factor authentication. This includes administration access to production systems, 3rd-party SaaS providers and internal business systems. ÌìÃÀÍøÕ¾´«Ã½´«Ã½ encourages employees to use an approved password manager to create complex, unique passwords for all systems and services they use.
The ÌìÃÀÍøÕ¾´«Ã½´«Ã½ application requires a strong password and is rate limited to prevent against possible attacks.
System monitoring, logging and alerting
ÌìÃÀÍøÕ¾´«Ã½´«Ã½ actively monitors servers, workstations and mobile devices for possible vulnerabilities and attacks. We maintain user activity logs, server logs and audit logs for all systems. Alerts are examined and acted upon based on priority.
Virus scanning
When files are uploaded into the ÌìÃÀÍøÕ¾´«Ã½´«Ã½ application, they are scanned by our redundant ClamAV instances before they are made available. If a virus is detected, the file is quarantined and a replacement file is put in place to let the exchange leader know to contact our support team. Virus definitions are updated hourly.
Endpoint monitoring and computer security
ÌìÃÀÍøÕ¾´«Ã½´«Ã½ workstations run monitoring tools that can detect malware, virus activity and unsafe configurations. Workstations are required to encrypt data, have strong passwords and lock when idle. Our IT team monitors alerts and resolves any significant issues based on priority.
Mobile device management
Mobile devices that are used at ÌìÃÀÍøÕ¾´«Ã½´«Ã½ are centrally managed and required to be enrolled in our mobile device management system.
Data confidentiality
Our subscription agreement and terms of use require us to maintain the confidentiality of all ‘information’ provided by our customers. This ‘information’ includes both content stored in the ÌìÃÀÍøÕ¾´«Ã½´«Ã½ application and ‘information’ provided to us by our customers in phone calls, meetings, email, etc. More information can be found in our .
Protected data and personally identifiable information
ÌìÃÀÍøÕ¾´«Ã½´«Ã½ maintains policies regarding data security and individual privacy protection. We protect our customers’ and participants’ data with the same care as we protect our own confidential data.
ÌìÃÀÍøÕ¾´«Ã½´«Ã½ has internal controls in place to ensure protected data is safeguarded in accordance with applicable laws based on country, state and provincial regulations, including, but not limited to GDPR, PIPEDA, FERPA, CIPA, PPRA and COPPA.
Participant privacy and terms of use
Our include our privacy policy for participants’ information.
In summary, our privacy policy is that participants’ input (thoughts, stars or other data they provide) can be made public as part of our process; their identity (email address, name and other identifying information) is shared between our customer and ÌìÃÀÍøÕ¾´«Ã½´«Ã½. The association of identity to input (i.e. who said what thought) is kept private by us, except as required by legal considerations.
Data removal
Customer and participant data can be removed upon request by contacting our support team. Backups are purged every 30 days. ÌìÃÀÍøÕ¾´«Ã½´«Ã½ relies on our hosting providers to remove data from disks used by ÌìÃÀÍøÕ¾´«Ã½´«Ã½ before they are repurposed.
Information security incident management
ÌìÃÀÍøÕ¾´«Ã½´«Ã½ maintains security incident response policies and procedures covering initial response, investigation and customer notification. We review these policies annually.
Breach notification
ÌìÃÀÍøÕ¾´«Ã½´«Ã½ makes its best efforts to protect your data; however no method is perfect, and we cannot guarantee absolute security. If ÌìÃÀÍøÕ¾´«Ã½´«Ã½ learns of a security breach, we will notify all affected users. Our breach notification procedures are consistent with our country, state and provincial obligations.
3rd-party suppliers
ÌìÃÀÍøÕ¾´«Ã½´«Ã½ relies on 3rd-party suppliers like Amazon Web Services, Microsoft Azure and Sendgrid to provide our services. ÌìÃÀÍøÕ¾´«Ã½´«Ã½ ensures that our suppliers adhere to our data and confidentiality agreements and perform reviews annually.