Legal

Version 2.0 – Dated September 14, 2022

1. Commitment to Information Security

With an understanding that ensuring information security is one of the most critical tasks of management, Webscale Networks will ensure that every person engaged in its operations will be committed to it.

2. Information Security Policy

To build an information security management system aimed at protecting information assets, Webscale Networks will set out an Information Security Policy that serves as a foundation for the system. It will comply with it and continuously review it to improve its services.

3. Protection of Information Assets

Webscale Networks will institute appropriate management measures according to the state of individual operations to unfailingly protect information assets from any threat to its confidentiality, integrity, and availability.

4. Compliance with Laws and Regulations

Webscale Networks will comply with applicable laws and regulations, other rules, and contractual requirements to ensure information security.

5. Education and Training

Webscale Networks will offer education and training to personnel engaged in its operations to improve their awareness of information security and familiarize them with the Information Security Policy.

6. Prevention of Accidents and Actions

Webscale Networks will run its information security management system to ensure that every employee works to prevent information security accidents from occurring. Should an accident take place, we will swiftly implement appropriate actions, including those for preventing recurrence.

7. Auditing

Webscale Networks will regularly audit the operation of its information security management system and carry out remedial actions as needed to maintain information security.

8. Continuous Improvement

Every year we set information security goals, define, and plan activities to achieve those objectives, then, according to periodical review results, set the following year’s goals. In addition, we regularly evaluate and review our Information Security Policy, its related internal regulations, and our management system, pursuing continuous improvement of information security.​​

9. Webscale Platform Security Commitments:

• Protect the confidentiality and integrity of Webscale’s SaaS platform and sensitive information
• Provide uptime and availability to the Platform and associated services as stated in customer agreements
• Ensuring quality, accuracy, and security of the Platform and data therein
• Ensuring security, confidentiality, and integrity of data coming in contact with third parties

10. Data Security Measures

Webscale has implemented and will maintain appropriate technical and organizational security measures to protect customer personal data from security incidents and to preserve the security and confidentiality of the customer personal data (“Security Measures”). The Security Measures applicable to the Services are as follows:

a) Web Application Penetration Test: Webscale shall continue to annually engage in web application penetration testing. Upon any customer’s written request, we will provide the executive summary of the report to Customer. We will address all medium, critical and severe vulnerabilities in the findings of the report within a reasonable, risk-based timeframe.

b) Security Awareness Training: Webscale will provide annual security training to all personnel. “Security Training” shall address security topics to educate users about the importance of information security and safeguards against data loss, misuse or breach through physical, logical and social engineering mechanisms. Training materials will address industry standard topics which include, but are not limited to:

• The importance of information security and proper handling of PII
• Physical controls such as visitor protocols, safeguarding portable devices and proper data destruction.
• Logical controls related to strong password selection/best practices.
• How to recognize social engineering attacks such as phishing.

c) Vulnerability Scan: Webscale shall ensure that vulnerability scans are performed on servers continuously and network security scans are completed at a minimum biannually, in each case using an industry standard vulnerability scanning tool.

d) Employee-Related Policies:

• Unauthorized persons will be prevented from gaining physical access to our premises and the rooms where data processing systems are located.
• Employees will only be allowed access to tasks assigned to them.
• We will ensure that all computers processing personal data (including computers with remote access) are password protected, both after booting up and when left, even for a short period.
• We will assign individual user passwords for authentication. Passwords must include at least 8 characters, with both upper and lower case characters, at least one digit, and one symbol.
• We will only grant system access to our authorized personnel and strictly limit their access to applications required for those personnel to fulfill their specific responsibilities.
• We will implement a password policy that prohibits the sharing of passwords, outlines procedures to follow after disclosure of a password, and requires that passwords be changed regularly.
• We will ensure that passwords are always stored in encrypted form.
• We will have adopted procedures to deactivate user accounts when an employee, agent, or administrator leaves our employ or moves to another responsibility within the company.
• We will be able to retrospectively examine and establish whether and by whom your customer personal data has been entered into data processing systems, modified or removed.
• We will log administrator and user activities. Logs will include the User Name, IP Address, Port Accessed, destination host access details. Webscale will retain the logs for 6 months.
• We will process the customer personal data received from different clients so that in each step of the processing the controller can be identified and so that data is always physically or logically separated.
• Employees are required to enable multi-factor authentication.

e) Process-Level Requirements: We will implement the following processes to ensure security and privacy:

• Webscale shall implement user termination controls that include access removal / disablement promptly upon termination of staff.
• Webscale shall have and maintain a patch management process to implement patches in a reasonable, risk-based timeframe.
• Webscale shall use firewall(s), Security Groups/VPCs, or similar technology to protect servers storing Customer Personal Data.
• Where Webscale handles customer personal data, servers shall be protected from unauthorized access with appropriate physical security mechanisms including, but not limited to, badge access control, secure perimeter, and enforced user provisioning controls (i.e. appropriate authorization of new accounts, timely account terminations and frequent user account reviews). These physical security mechanisms are provided by data center partners such as, but not limited to, AWS, Azure, and Google. All cloud-hosted systems shall be scanned, where applicable and where approved by the cloud service provider.
• Webscale will virtually segregate all Customer Personal Data in accordance with its established procedures. The Customer instance of Services may be on servers used by other non-Customer instances.
• Whenever an employee or contractor leaves or is terminated, that individual’s access to customer user accounts shall be immediately terminated or disabled.

f) Application-Level Requirements

• Webscale shall maintain documentation on overall application architecture, process flows, and security features for applications handling customer personal data.
• Webscale shall employ industry standard scanning tools and/or code review practices, as applicable, to identify application vulnerabilities.

g) Data-Level Requirements

• Encryption and hashing protocols used for customer personal data in transit and at rest shall support NIST approved encryption standards (e.g. SSH, TLS).
• Webscale shall ensure that access to information and application system functions is restricted to authorized personnel only.
• Customer personal data stored on archive or backup systems shall be stored at the same level of security or better than the data stored on operating systems.

h) End User Computing Level Requirements

• Webscale will require anti-virus scans with frequent signature updates for end-user computing devices to run at least weekly.
• Webscale will prohibit the use of removable media for storing or carrying customer personal data. Removable media include flash drives, CDs, and DVDs.

i) Compliance Requirements

• Webscale will implement building access control to control and track access to its networks and other equipment.
• Webscale will determine each year which officers and employees within the company will have access to which categories of data and shall review this list annually at the executive level.

j) Personnel: Webscale restricts its personnel from downloading and/or processing Customer Personal Data without authorization by Webscale as set forth in the Security Measures and shall ensure that any person who is authorized by Webscale to process Customer Personal Data is under an appropriate obligation of confidentiality.

k) Security Incident Response: Upon becoming aware of a Security Incident, Webscale will notify Customer without undue delay and, in any case, where feasible, within seventy-two (72) hours after becoming aware. Webscale will provide information relating to the Security Incident as it becomes known or as is reasonably requested by Customer to fulfill its obligations as controller and will also take reasonable steps to contain, investigate, and mitigate any Security Incident.

l) SOC 2 Certification: Webscale has earned SOC 2 type II certification and we go through an annual review.

m) Data Minimization: Webscale will ensure that the personal data it collects and processes will be adequate, relevant, and limited to what is necessary to provide the Services

n) Data Retention and Destruction: Webscale will have in place secured destruction processes and will delete Customer personal data utilizing secure methods (equivalent to or greater than that of NIST SP-800-88 Rev. 1 or its successor guidelines) that render the data unreadable and unrecoverable.

o) Security Incident Response:
Upon becoming aware of any incident in which it suspects that unauthorized access has been gained to Webscale’s systems, the executives of the company at the highest levels will be immediately notified.

• Executives will immediately confer with each other and with legal counsel regarding any security incident to ensure compliance with legal and contractual obligations.
• We will notify the impacted customer(s) within seventy-two hours after learning of the incident.
• We will immediately investigate and mitigate any security incident.
• Webscale will obtain and maintain reasonable insurance to cover itself for cyber liability.