Item 1B. Unresolved Staff Comments
Item
1B. Unresolved Staff Comments
Not
Applicable.
Item
1C. Cybersecurity
As
a tech-powered media company, we face cybersecurity threats, such as ransomware and denial-of-service, and attacks on technical infrastructure.
Our customers and suppliers face similar cybersecurity threats, and a cybersecurity incident impacting us or any of these entities could
materially adversely affect our operations, performance and results of operations.
We
maintain a cyber risk management program designed to identify, assess, manage, mitigate, and respond to cybersecurity threats. This program
addresses cybersecurity risks to the corporate information technology (“IT”) environment including systems, hardware, software,
data, people, and processes.
The
Audit Committee of the Board of Directors oversees management’s processes for identifying and mitigating risks, including cybersecurity
risks. Our Head of Information Security has primary responsibility for our entity-wide information security program. Our current Head
of Information Security has held that position since 2019 and has broad information technology and cybersecurity experience as a result
of that role and past work experience which includes cybersecurity consulting. Our Head of Information Security regularly briefs senior
leadership on our cybersecurity and information security posture including on the prevention, detection, mitigation, and remediation
of cybersecurity incidents, and senior leadership will then brief the Audit Committee. In the event of an incident, we intend to follow
our incident response playbook, which outlines our planned response from incident detection to mitigation, recovery and notification,
including notifying functional areas (e.g. legal), as well as senior leadership and the Board, as appropriate.
Our
security team is responsible for our overall information security strategy, including policy, security engineering, operations and cyber
threat detection and response. Our security team has extensive experience selecting, deploying, and overseeing cybersecurity technologies,
initiatives, and processes. Employees outside of our security team and third parties also have a role in our cybersecurity defenses. Such employees are given training which we believe improves our cybersecurity. We engage third parties to conduct risk assessments and evaluations
of our security controls. Such risk assessment and evaluations identify, quantify, and categorize any cyber risks. In addition, we, along
with third party cyber risk management specialists, develops a risk mitigation plan to address such risks, and where necessary, remediate
potential vulnerabilities identified through the assessment and evaluation process.
We
have processes to oversee and identify cybersecurity risks associated with the use of third party service providers in our organization’s
operations. Third party cybersecurity risk management engagement also includes activities such as penetration testing, independent audits
or consulting on best practices to address new challenges. We include security and privacy addendums to our contracts where applicable.
We also perform third party risk management assessments to help manage the risks associated with reliance on vendors, critical
service providers, and other third-parties that may lead to a service disruption or an adverse cybersecurity incident.
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Our
Head of Information Security and cybersecurity stakeholders regularly brief the senior leadership team on cyber vulnerabilities identified
through the risk management process, the effectiveness of our cyber risk management program, the emerging threat landscape, and new cyber
risks on at least an annual basis. This includes updates on our processes to prevent, detect, and mitigate cybersecurity incidents.
Notwithstanding
the approach we take to cybersecurity, we may not be successful in preventing or mitigating a cybersecurity incident that could have
a material adverse effect on us. While we maintain cybersecurity insurance, the costs related to cybersecurity threats or disruptions
may not be fully insured. We have not identified any risks from known cybersecurity threats, including as a result of any prior cybersecurity
incidents, that have materially affected or are reasonably likely to materially affect our operations, business strategy, regulatory
compliance, results of operations, or financial condition. The Company proactively seeks to detect and investigate unauthorized attempts
and attacks against Company IT assets, data, and services, and to prevent their occurrence and recurrence where practicable through changes
or updates to internal processes and tools and changes or updates to Company service delivery; however, potential vulnerabilities to
known or unknown threats will still remain. See Item 1A. “Risk Factors” for a discussion of cybersecurity risks.