Legal

5.1 SECURITY POLICY

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Effective Date: August 15, 2026


1. PURPOSE This Security Policy establishes the administrative, technical, and organizational safeguards implemented by the Platform to protect systems, Services, and data from unauthorized access, disclosure, alteration, and destruction.

The Platform uses commercially reasonable security measures consistent with industry standards and proportionate to the nature, scope, context, and risk of the Services. Security is implemented as a continuous risk management process rather than a fixed state. While security controls are designed to reduce risk, no method of transmission, storage, or electronic processing can be guaranteed to be completely secure.

2. SCOPE This Policy applies to all systems, infrastructure, personnel, contractors, and service providers that support the operation and delivery of the Services. Security controls are implemented using a risk-based approach that considers the sensitivity of data, the current threat landscape, operational requirements, and the proportionality of safeguards.

3. SECURITY GOVERNANCE The Platform maintains internal security governance processes intended to support accountability, oversight, and continuous improvement of the security program. Governance practices include:

  • Security role designation and responsibility assignment;

  • Risk evaluation and control prioritization;

  • Internal policy maintenance;

  • Security awareness practices; and

  • Escalation procedures for security events.

4. RISK MANAGEMENT The Platform applies a structured approach to identifying, evaluating, and addressing security risks. Safeguards are designed to be proportionate to the likelihood and potential impact of identified threats. Risk management activities may include periodic assessments, control reviews, and remediation planning based on internally defined risk tolerance levels.

5. ACCESS CONTROL Access to systems and data is restricted to authorized personnel based on legitimate business needs and the principle of least privilege.

  • Protective measures may include identity verification mechanisms, authentication controls (such as MFA where appropriate), role-based permissions, and access revocation procedures.

  • Monitoring: The Platform reserves the right to monitor access activity where reasonably necessary to protect security and prevent misuse.

6. INFRASTRUCTURE SECURITY The Platform utilizes infrastructure environments intended to support secure service delivery. Protective measures may include network segmentation, environment isolation, system hardening practices, and continuous monitoring capabilities where operationally appropriate.

Infrastructure Disclaimer: The Platform relies in part on third-party infrastructure providers and does not maintain physical control over underlying facilities.

7. CRYPTOGRAPHY AND DATA PROTECTION The Platform implements cryptographic safeguards intended to protect data during transmission and, where appropriate, at rest. Encryption standards and key management practices are selected based on industry norms and evolving security guidance. The Platform reserves the right to modify cryptographic methods, protocols, and configurations without prior notice where reasonably necessary to address security risks, technological developments, or evolving industry standards.

8. VULNERABILITY MANAGEMENT Security vulnerabilities are addressed through processes intended to identify, evaluate, and remediate material risks within reasonable timeframes as determined by the Platform. The Platform may utilize automated scanning tools, vendor notifications, and internal reviews to support detection. Not all vulnerabilities can be prevented, identified, or eliminated.

9. INCIDENT RESPONSE The Platform maintains procedures designed to detect, assess, and respond to security incidents. Response actions are coordinated in accordance with the Platform’s Incident Response Plan (refer to Document 5.5). Where appropriate, containment, mitigation, and recovery measures may be implemented to reduce potential harm.

10. THIRD-PARTY SECURITY Service providers are selected with consideration for their security posture; however, the Platform does not control the independent security practices of third parties. Third-party failures may impact Service availability or security despite reasonable selection efforts.

11. SECURITY TESTING AND IMPROVEMENT Security controls are periodically reviewed and may be updated to reflect operational changes, emerging threats, and industry developments. Testing activities are intended to support program maturity and do not guarantee the prevention of all security events.

12. USER RESPONSIBILITIES Users share responsibility for maintaining the security of their accounts. Users are expected to:

  • Safeguard authentication credentials;

  • Maintain appropriate endpoint security; and

  • Promptly report suspected unauthorized activity.

The Platform is not responsible for security incidents resulting from compromised user credentials or insecure user-controlled environments.

13. LIMITATIONS Security safeguards reduce risk but cannot eliminate it entirely. Accordingly:

  • No system can be guaranteed to be immune from attack;

  • Unauthorized access may still occur despite safeguards; and

  • Security measures do not constitute a warranty of absolute protection.

14. FORCE MAJEURE AND EXTERNAL THREATS To the maximum extent permitted by applicable law, the Platform shall not be responsible for security failures resulting from events beyond its reasonable control, including events affecting the Platform or its service providers, including but not limited to large-scale cyber incidents, zero-day vulnerabilities, infrastructure collapse, acts of government, or other extraordinary events.

15. POLICY MAINTENANCE This Policy is subject to periodic review and may be updated to reflect changes in security practices or legal requirements. Material updates may be communicated through standard Platform channels.

16. NON-CONTRACTUAL NATURE This Security Policy is provided for transparency purposes and does not create contractual obligations, fiduciary duties, heightened standards of care, or warranties unless expressly incorporated into a separate written agreement.