UNRESOLVED STAFF COMMENTS
−Removed: CYBERSECURITY RISK MANAGEMENT, STRATEGY AND GOVERNANCE
+Added: CYBERSECURITY RISK MANAGEMENT, STRATEGY
+Added: AND GOVERNANCE
Risk Management and Strategy
−Removed: We have implemented a cybersecurity process that is
−Removed: designed to assess, identify, manage and govern material risks from cybersecurity threats and requires a firewall for outside connections.
+Added: We have implemented a cybersecurity process that
+Added: is designed to assess, identify, manage and govern material risks from cybersecurity threats and requires a firewall for outside connections.
We operate a closed server in a locked room and regularly examine cybersecurity threats that could compromise our information system’s
5 unchanged sentences
cybersecurity process through trainings.
−Removed: We do not engage third party professionals or disclose
−Removed: our internal security measures to private parties.
+Added: We do not engage third party professionals or
+Added: disclose our internal security measures to private parties.
We have never experienced a cybersecurity incident
7 unchanged sentences
Our board of directors monitors and assesses strategic risk exposure, and our executive officers manage the material risks we face.
−Removed: Our Vice President of Operations, who has over 30
−Removed: years of experience in IT and marketing, works with our board of directors to manage our cybersecurity policies and processes, including
−Removed: those described in the “Risk Management and Strategy” section above.
−Removed: Together, they stay informed and manage how we identify,
−Removed: address, prevent and resolve cybersecurity issues and related matters.
−Removed: They also track how we prevent, identify, lessen, and address cybersecurity
−Removed: This is done through regular checks of our systems, tests to identify security weaknesses, and maintaining an incident response
−Removed: In addition to such regular system checks, our Vice
−Removed: President of Operations, together with the board, regularly discuss active, emerging and potential cybersecurity risks.
−Removed: They keep each
−Removed: other informed about significant changes affecting cybersecurity, and they periodically update management with these changes, as well
−Removed: as our cybersecurity risks, so that management can administer its oversight function as a part of its broader oversight and risk management.
+Added: Vice President of Operations , who has over 30 years of experience in IT and marketing, works with our board of directors to manage
+Added: our cybersecurity policies and processes , including those described in the “Risk Management and Strategy” section
+Added: Together, they stay informed and manage how we identify, address, prevent and resolve cybersecurity issues and
+Added: related matters.
+Added: They also track how we prevent, identify, lessen, and address cybersecurity issues.
+Added: This is done through regular
+Added: checks of our systems, tests to identify security weaknesses, and maintaining an incident response plan.
+Added: In addition to such regular system checks, our
+Added: Vice President of Operations, together with the board, regularly discuss active, emerging and potential cybersecurity risks.
+Added: each other informed about significant changes affecting cybersecurity, and they periodically update management with these changes, as
+Added: well as our cybersecurity risks, so that management can administer its oversight function as a part of its broader oversight and risk
Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.