Mining Investor Resources Media Ltd. (“MININGIR”) is committed to providing best-in-class sales and marketing automation software for small businesses. In support of this commitment, MiningIR has developed information security risk management policies to reasonably ensure the confidentiality, integrity, and availability of Your Data that You upload to the MiningIR Service. This Data Security Statement (the “Statement”) describes some of the security controls that MiningIR has implemented pursuant to those policies. This Statement applies to the MiningIR Service but not necessarily to the other related services provided by MiningIR or to our publicly accessible websites.

Capitalized terms used in this Statement but not defined herein shall have the meaning given to them in the MiningIR Subscription Use Agreement.

Audits and Certifications

MiningIR has completed and/or maintains the following data protection audits and certifications:

PCI DSS

MiningIR has completed a PCI DSS level-one onsite assessment and was validated by SecurityMetrics against the Payment Card Industry Data Security Standards. A Certificate of Compliance has been issued to MiningIR and is available to anyone upon request.

U.S.‑EU AND U.S.‑SWISS SAFE HARBOR SELF-CERTIFICATION

MiningIR complies with the U.S.‑E.U. Safe Harbor Framework and U.S.‑Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce. MiningIR has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To view the MiningIR certifications, please visit https://safeharbor.export.gov/list.aspx.

VERASAFE PRIVACY PROGRAM

MiningIR participates in the VeraSafe EU Safe Harbor Program, meaning that VeraSafe has assessed MiningIR’s data governance for compliance with the VeraSafe Website Privacy Program Criteria. The program criteria require that participants maintain a high standard for data privacy and implement specific best practices pertaining to notice, choice, access, data integrity, security, and third-party information sharing.

Infrastructure

Some of the infrastructure that MiningIR uses to host Your Data is owned and controlled by MiningIR and the remaining portions of the infrastructure are provided by carefully selected third party service providers.

In some cases Your Data that You submit to the MiningIR Service is stored in a primary data center and is replicated in near-real-time to a secondary data center. The secondary data center is provisioned with sufficient computational, network, and storage resources to replace the functionality of the primary data center, and restore the MiningIR Service if required.

The secondary data center is geographically remote from the primary data centers.

Vendor Risk Management

In cases where MiningIR engages third party colocation service providers and infrastructure service providers (the “Data Center Providers”), MiningIR ensures that those Data Center Providers have recently completed a Service Organization Controls (SOC) 2 Type II audit. Additionally, those third parties are contractually obligated to maintain the confidentiality of Your Data to the fullest extent allowed by applicable law.

Physical Security Controls

• Access to the Data Center Providers’ data center facilities is restricted to authorized personnel only.
• The Data Center Providers’ data center facilities are secured by professional security guards.
• A physical access control system (ID card and/or biometric) has been implemented at entry and exit points of the Data Center Providers’ data center facilities.
• All visitors must be escorted by an employee of the Data Center Providers or, in some cases, a permanent badge-holder at all times when visiting the Data Center Providers’ data center facilities.

Availability and Disaster Resistance

• The Data Center Providers’ data center facilities are designed, built, and maintained to withstand reasonably foreseeable adverse weather and other natural conditions.
• Processing capacity is monitored on a daily basis.
• The Data Center Providers have installed and maintain at least the following environmental protections:
• Cooling systems
• Battery-powered backup electrical supply and/or backup electrical generators
• Redundant communications lines
• Smoke/fire detectors
• Automatic fire suppression systems
• The status of environmental protections is continuously monitored by the Data Center Providers.
• Environmental protections are tested and maintained regularly by the Data Center Providers.

MiningIR’s Data Security Controls

TECHNICAL SECURITY CONTROLS

MiningIR maintains at least the following technical security controls and policies:

• MiningIR-authored software applications and IT systems are regularly scanned/monitored for vulnerabilities.
• Known exploitable vulnerabilities in MiningIR-authored software applications and IT systems are patched expeditiously.
• External points of connectivity in the MiningIR application architecture are protected by firewall(s).
• Network and database activity is logged and actively monitored for potential security events including intrusion.
• MiningIR user passwords are stored in a one-way hash.

ADMINISTRATIVE SECURITY CONTROLS

• MiningIR maintains at least the following administrative security controls and policies:
• Physical and logical access to IT systems that process Your Data is limited to those officially authorized persons with an identified need for such access.
• MiningIR’s workforce participates in data protection awareness training.
• MiningIR conducts pre-employment background checks to help ensure employee reliability.

AVAILABILITY AND DISASTER RECOVERY

MiningIR has implemented a disaster recovery plan, which will be regularly tested. The IT systems architecture of the MiningIR Service includes redundant backups of critical hardware and software components.

Data Protection Officer

MiningIR has appointed a data protection officer. You may contact MiningIR’s data protection officer by email at [email protected]