Item 1B. Unresolved Staff Comments
ITEM 1B. UNRESOLVED STAFF COMMENTS.
None.
ITEM 1C. CYBERSECURITY
Risk Management and Strategy
We acknowledge the critical
importance of developing, implementing, and maintaining robust cybersecurity measures to safeguard our information systems and protect
the confidentiality, integrity, and availability of our data. While we are in the process of enhancing our cybersecurity practices, we
are committed to continually improving and adapting to evolving threats to maintain a high standard of protection and to meet industry
best practices.
Managing Material Risks and Integrated Overall
Risk Management
We have developed and implemented
a cybersecurity program that seeks to ensure the confidentiality, integrity , and availability of our information assets, including its
critical systems. We use information security management standards, such as ISO 27001, as a guide to help us identify, assess, and manage
cybersecurity risks relevant to our business.
We have integrated cybersecurity
risk management into our broader enterprise risk management framework. This integration is designed to promote a company-wide culture
of cybersecurity awareness and risk management. Our risk management team, in collaboration with external consultants, has assessed and
addressed and continues to assess and address cybersecurity risks in alignment with our operational and business needs. This integration
ensures that cybersecurity considerations are increasingly embedded in our decision-making processes at every level.
Our cybersecurity framework
also draws upon the National Institute of Standards and Technology Cybersecurity Framework (at its currently 2.0 version), which provides
guidance for identifying, assessing, and managing cybersecurity risks. While we are in the early stages of fully implementing this framework,
we are committed to following its principles as we strengthen our cybersecurity measures to protect both our digital and physical assets.
Engage Third-parties on Risk Management
Recognizing the evolving nature
of cybersecurity threats, we have engaged with external experts, including cybersecurity assessors, consultants, and auditors, to assess
and enhance our risk management systems. These third-parties have and continue to assist us with evaluating our cybersecurity posture,
recommending improvements, and advising on the implementation of best practices. In 2025, we completed a comprehensive cybersecurity assessment
across all platforms with external experts, such as Amazon Web Services, amongst others. As we progress, we will continue leveraging these
external insights to enhance our cybersecurity strategies and ensure alignment with industry standards.
Oversee Third-party Risk
We understand the potential
risks associated with third-party service providers, and we are working on implementing stronger oversight processes. While we have initiated
security assessments for our third-party providers, we are in the process of enhancing these efforts to include more frequent evaluations
and ongoing monitoring. This will help mitigate the risk of security incidents originating from third-parties.
Risks from Cybersecurity Threats
To date, we have not encountered
cybersecurity incidents that have materially impaired our operations or financial condition. However, given the data-driven nature of
our business and the prevalent use of technology in operating our business, we face cybersecurity risks inherent to our normal course
of operation that, if realized, are reasonably likely to materially affect our operations or financial condition. As a result, we have
a dedicated cybersecurity response team and proactively prepare for the possibility of cybersecurity risks, ensuring that our systems
are protected against potential threats. The cybersecurity response team (i) responds to actual and suspected cybersecurity threats, (ii)
assesses the severity of any such actual or suspected cybersecurity threat, (iii) prepares and maintains incident reports and (iv) prepares
cybersecurity incident response procedures designed to help protect the security of the Company’s systems.
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Governance
Our Board understands the
critical nature of cybersecurity and is closely involved in overseeing our efforts to mitigate cybersecurity risks. We continue to formalize
governance structures and oversight mechanisms to ensure that these risks are managed effectively, with the aim of strengthening our operational
integrity and enhancing stockholder confidence. As of December 31, 2025, no risks from cybersecurity threats, including as a result of
cybersecurity incidents we have experienced in the past, have materially affected us, including our results of operations and financial
condition .
Management’s Role Managing Risk
Our Chief Technology Officer
(“CTO”) is the senior officer responsible for cybersecurity risk management. Our CTO receives regular updates, which include
an overview of the current cybersecurity landscape, the status of ongoing initiatives, and compliance with regulatory requirements. We
are establishing structured processes for ongoing communication among the executive team to ensure they remain informed and timely involved
in key cybersecurity decisions.
Risk Management Monitoring
We are committed to regularly
monitoring cybersecurity risks and are in the process of implementing enhanced monitoring systems. With the assistance of cybersecurity
consultants, we are refining our cybersecurity policies and controls, including regular audits and the deployment of advanced security
measures such as Multi-Factor Authentication and stronger email filtering protocols. In addition, we have an incident response team and
are continuing to refine our incident response plans, communication protocols, and disaster recovery plans to be prepared for any potential
cybersecurity incidents.
Security Training
We are providing cybersecurity
training to our employees and plan to continue enhancing this program on an ongoing basis. Regular updates and internal campaigns will
ensure that our employees are well-prepared to identify and respond to cybersecurity threats in an effective manner.
Reporting to Management and the Board
The CTO regularly provides
reports and informs the CEO and CFO cybersecurity profile. These reports address the status of risk mitigation initiatives, the evolving
threat landscape, the results of vulnerability assessments and penetration testing, and the progress of key cybersecurity programs, including
the implementation of a Zero Trust access framework, continuous vulnerability scanning with centralized alerting, and our pursuit of SOC
2 readiness.
The Board maintains direct
oversight of the Company’s cybersecurity program. Management provides the Board with no fewer than annual comprehensive briefings
on cybersecurity risk assessment, the effectiveness of the Company’s information security controls and the status of ongoing cybersecurity
initiatives. These briefings also cover the Company’s incident response preparedness and any changes in the regulatory environment
affecting the Company’s cybersecurity obligations.
In addition to the regularly
scheduled briefings, significant cybersecurity matters will be escalated to the Board for review, where management, including the CTO,
will provide detailed updates on risk assessments, incident responses, and the effectiveness of our cybersecurity strategies. The Board
will continue to evaluate the progress of our cybersecurity initiatives and offer guidance to help strengthen our efforts.