Item 1B. Unresolved Staff Comments
Item 1B. UNRESOLVED STAFF COMMENTS
None.
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Item 1C. CYBERSECURITY RISK MANAGEMENT, STRATEGY
AND GOVERNANCE
Risk Management and Strategy
We have implemented a cybersecurity process that
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
security or data and otherwise maintain our cybersecurity policies and procedures in accordance with industry standard control frameworks
and applicable regulations, laws, and standards.
We regularly check and improve our security measures
and educate our employees about such measures with the help of our information technology (IT) team. Key personnel are made aware of our
cybersecurity process through trainings.
We do not engage third party professionals or
disclose our internal security measures to private parties.
We have never experienced a cybersecurity incident
that was determined to be material, although, like many technology-dependent companies operating in the current environment, we have experienced
cybersecurity incidents in the past. For additional information regarding whether any risks from cybersecurity threats are reasonably
likely to materially affect us, including our business strategy, results of operations, or financial condition , please see the section
titled “ Risk Factors. ”
Governance
One of the key functions of our board of directors,
in connection with our IT team, is informed oversight of our risk management process, which includes risks from cybersecurity threats.
Our board of directors monitors and assesses strategic risk exposure, and our executive officers manage the material risks we face.
Our
Vice President of Operations , who has over 30 years of experience in IT and marketing, works with our board of directors to manage
our cybersecurity policies and processes , including those described in the “Risk Management and Strategy” section
above. Together, they stay informed and manage how we identify, address, prevent and resolve cybersecurity issues and
related matters. They also track how we prevent, identify, lessen, and address cybersecurity issues. This is done through regular
checks of our systems, tests to identify security weaknesses, and maintaining an incident response plan.
In addition to such regular system checks, our
Vice President of Operations, together with the board, regularly discuss active, emerging and potential cybersecurity risks. They keep
each other informed about significant changes affecting cybersecurity, and they periodically update management with these changes, as
well as our cybersecurity risks, so that management can administer its oversight function as a part of its broader oversight and risk
management.