Security Statements

NowVertical Group Inc. and our subsidiary entity, NowVertical Group, Inc., (collectively, “NowVertical”, “we”, “us” and “our”) are committed to sound information security practices, including cybersecurity, in ensuring the confidentiality, integrity, and availability of assets, and protection against both external and internal threats.

This Security Statement aims to provide you with more information about our security infrastructure and practices. In our Privacy Policy, you can find more details about how we handle the data we collect.

Information Security Policy

NowVertical maintains a written Information Security policy that defines employee’s responsibilities and acceptable use of information system resources. This policy is periodically reviewed and updated as necessary. Also, we receive signed acknowledgements from users indicating that they have read, understand, and agree to abide by the rules of behaviour, before providing authorized access to NowVertical information systems.

Our security policies cover important security-related topics ranging from general standards with which every employee must comply, such as account, data, and physical security, to more specialized security standards covering internal applications and information systems.

Organizational Security

Information security roles and responsibilities are defined within the organization. The security team focuses on information security, global security auditing, compliance, and defining the security controls to protect NowVertical’s assets (People, Processes, and Technology). The security team receives information system security notifications regularly and distributes security alerts and advisory information to the organization on a routine basis after assessing the risk and impact as appropriate.

Asset Management

NowVertical’s data and information system assets typically do not contain customer or end-user assets. Our corporate assets are managed under our security policies and procedures. NowVertical authorized personnel who handle these assets are required to comply with the procedures and guidelines defined by NowVertical security policies. In rare and exceptional cases where end-user assets are contained within our Information technology ecosystem, the same corporate assets security policies and procedures apply.

Personnel Security

NowVertical employees are required to conduct themselves in a manner consistent with the company’s guidelines, including those regarding confidentiality, business ethics, appropriate usage, and professional standards. All newly hired employees must sign confidentiality agreements and acknowledge the NowVertical code of conduct policy. The code outlines the company’s expectation that every employee will conduct business lawfully, ethically, with integrity, and with respect for each other and the company’s users, partners, and competitors. Processes and procedures are in place to address employees who are on-boarded and off-boarded from the company.

Employees are provided with regular security awareness training as part of new hire orientation. In addition, each NowVertical employee is required to read, understand, and take a training course on the company’s code of conduct.

Physical & Environmental Security

NowVertical has policies, procedures, and infrastructure to handle both the physical security of its data centers as well as the environment from which the data centers operate.

Our information systems and infrastructure are hosted in world-class data centers (Azure, AWS and Digital Ocean) that are geographically dispersed to provide high availability and redundancy to NowVertical and its customers. We make full use of the security products embedded within these ecosystem. At a minimum, these data centers have successfully completed ISO 27001 and SOC 2 Type II audits.

Secure Network Connections

HTTPS encryption is configured for customer web application access. This helps to ensure that user data in transit is safe, secure, and available only to intended recipients. The level of encryption is negotiated to either SSL or TLS encryption and is dependent on what the web browser can support.

Network Security

Our infrastructure servers reside behind high-availability firewalls and are monitored for the detection and prevention of various network security threats. Firewalls are utilized to help restrict access to systems from external networks and between systems internally. By default, all access is denied and only explicitly allowed ports and protocols are allowed based on business needs.

• to respond to your communications and requests

• to meet legal, regulatory, audit, security and financial requirements under federal and provincial regulations

• to maintain business records for reasonable periods of time

• to conduct market research and gather demographic and statistical information about our users in order to manage and improve our business

• to provide you with our press releases, alerts and updates, in accordance with applicable law. You can unsubscribe from such communications at any time by clicking on the unsubscribe link included in each communication.

NowVertical maintains separate development and production environments. We ensure adequate network segmentation through the establishment of security zones that control the flow of network traffic. Strict firewall security policies define these traffic flows.

Automated tools are deployed within the network to support near-real-time analysis of events to support detection of system-level attacks.

Software Development Lifecycle

We follow a defined methodology for developing secure software designed to increase our products’ resiliency and trustworthiness. Our products are deployed on an iterative, rapid-release development lifecycle. Security and security testing are implemented throughout the entire software development methodology. Quality Assurance is involved at each phase of the lifecycle, and security best practices are a mandated aspect of all development activities.

Our secure development lifecycle follows standard security practices, including vulnerability testing, regression testing, penetration testing, and product security assessments. The NowVertical architecture teams review our development methodology regularly to incorporate evolving security awareness and industry practices and to measure its effectiveness.

Supplier and Vendor Relationships

NowVertical likes to partner with suppliers and vendors that operate with the same or similar values around lawfulness, ethics, and integrity that NowVertical does. As part of its review process, we screen our suppliers and vendors and bind them to appropriate confidentiality and security obligations, especially if they manage customer data.

We perform audits from time to time on NowVertical suppliers and vendors in an effort to ensure the confidentiality, integrity, and availability of data that our third-party suppliers or vendors may handle.

Change Management

NowVertical maintains a change management process to ensure that all changes made to the production environment are applied in a deliberate manner. Changes are reviewed, approved, tested, and monitored post-implementation to ensure that the expected changes are operating as intended. Changes to information systems, network devices, and other system components, and physical and environment changes are monitored and controlled through a formal change control process.

We will keep Personal Information only for as long as it remains necessary for the purposes for which it was collected, or as required by law. We use secure means of disposing of Personal Information.

Auditing and Logging

The Site may contain links to third party platforms to which the Policy does not apply. Should you select such a link, you will leave the NowVertical Site. Please note that we do not monitor or control the content that appears on these third-party sites and such content may be constantly changing. If you view these third-party sites, the sites may assign a cookie. NowVertical does not control these cookies, nor is it responsible for any marketing or other use of your information by these third parties. All Personal Information you provide via those third-party sites will be governed by the privacy policies applicable to those sites and not this Policy. We encourage you to review all such privacy policies before you provide any Personal Information to third-party sites.

Antivirus and Malware Protection

Anti-virus (XDR) tools are configured to run scans, virus detection, real-time file write activity and signature file updates. Antivirus (XDRs) and malicious code protection are centrally managed and configured to retrieve the updated signatures and definitions available. Malicious code protection policies automatically apply updates to these protection mechanisms. Laptop and remote users are covered under virus protection.

System Backups

NowVertical has backup standards and guidelines and associated procedures for performing backup and restoration of data in a scheduled and timely manner. Although we typically do not house customer data as our products are deployed on the customer premise, we can support and advise our customers on appropriate back-up mechanisms to employ for our deployed solutions. Controls are established to help safeguard backed-up data (onsite and off-site). Periodic tests are conducted to test whether data can be safely recovered from backup devices.any questions, concerns or would like more information about the collection, use or disclosure of your Personal Information by NowVertical, you may contact us as follows: EVP, Corporate Development & Legal Affairs, privacy@nowvertical.com.

Data Protection

NowVertical continually works to develop products that support the latest recommended secure cipher suites and protocols to encrypt traffic while in transit. We monitor the changing cryptographic landscape closely and work to upgrade our products to respond to new cryptographic weaknesses as they are discovered and implement best practices as they evolve. For encryption in transit, we do this while also balancing the need for compatibility for older clients.

We apply a common set of personal data management principles to customer data that we may process, handle, and store. We protect personal data using appropriate physical, technical, and organizational security measures. Any non-public information NowVertical may process, handle or store is encrypted at rest.

We give additional attention and care to sensitive personal data and respect local laws and customs, where applicable. NowVertical only processes personal information in a way that is compatible with and relevant for the purpose for which it was collected or authorized in accordance with our Privacy Policy. We take all reasonable steps to protect the information we receive from our users from loss, misuse, or unauthorized access, disclosure, alteration and/or destruction.

Vulnerability Management

Security assessments are done to identify vulnerabilities and to determine the effectiveness of the patch management program. Each vulnerability is reviewed to determine if it is applicable, ranked based on risk, and assigned to the appropriate team for remediation.

Patch Management

NowVertical strives to apply the latest security patches and updates to operating systems, applications, and network infrastructure to mitigate exposure to vulnerabilities. Patches are tested before being deployed into production. Patch management processes are in place to implement security patch updates as vendors release them.

Incident Management

NowVertical has a formalized incident response plan (Incident Response Plan) and associated procedures in case of an information security incident. The Incident Response Plan defines the responsibilities of key personnel and identifies processes and procedures for notification. Incident response personnel are trained, and execution of the incident response plan is tested periodically.

An incident response team is responsible for providing an incident handling capability for security incidents, including preparation, detection and analysis, containment, eradication, and recovery.

Business Continuity and Disaster Recovery

We implement a disaster recovery program to minimize service interruptions due to hardware failure, natural disasters, or catastrophes. This program includes multiple components to minimize the risk of any single point of failure. Also, we leverage the redundancy built into the tools we use.

Authentication and Authorization

We require that authorized users be provisioned with unique account IDs. Our password policy covers all applicable information systems, applications, and databases. Our password policies enforce the use of complex passwords, which are deployed to protect against unauthorized use of passwords.

NowVertical employees are granted a limited set of default permissions to access company resources, such as their email, and the corporate intranet. Employees are granted access to certain additional resources based on their specific job functions. Requests for additional access follow a formal process that involves a request and approval from a data or system owner, manager, or other executives, as defined by our security guidelines.

Role-Based Access

Role-based access controls are implemented for access to information systems. Processes and procedures are in place to address employees who are voluntarily or involuntarily terminated. Access controls to sensitive data in our databases, systems, and environments are set on a need-to-know / least privilege necessary basis. Access control lists define the behaviour of any user within our information systems, and security policies limit them to authorized behaviours.