Item 1B. Unresolved Staff Comments
Item 1B. Unresolved Staff Comments
None
Item 1C. Cybersecurity
We recognize the importance of developing, implementing, and
maintaining robust cybersecurity measures to protect our information systems and protect the confidentiality, integrity, and availability
of our data. Presently our information systems are limited to databases maintained by third parties. As a result, we have limited
policies and procedures to assess, identify, and manage material risk from cybersecurity threats. We assess risks from cybersecurity threats
against our third-party information systems that may result in adverse effects on our information systems or any information residing
therein. We conduct periodic and ad-hoc assessments to identify cybersecurity threats. Presently we do not believe there are any material
threats to our systems.
Following these risk assessments, if needed, we evaluate whether
and/or how to re-design, implement, and maintain reasonable safeguards to mitigate identified risks and reasonably address any identified
gaps in existing safeguards. We do not yet have an IT manager given our limited exposure to risks, and therefore the review of our limited
systems is undertaken by our President to manage the risk assessment and mitigation process. When applicable to our corporate structure
and when we believe exposure to risks within our systems exceeds the current limited levels of exposure, we will monitor and test our
safeguards and train our employees on the implementation of such safeguards, in collaboration with human resources, IT, and management,
as available. We aim to promote a company-wide culture of cybersecurity risk management as we grow in size.
Risks from Cybersecurity Threats
As of the date of this report, we
are not aware of any cybersecurity incidents, that have had a materially adverse effect on our operations, business, results of operations,
or financial condition.
Governance
Our board of directors is responsible for monitoring and assessing
strategic risk exposure. Our board of directors administers its cybersecurity risk oversight function directly as a whole. Our President
is responsible for assessing and managing our material risks from cybersecurity threats and conducts this assessment on a regular basis,
or at least once per year.
Item 2. Properties
Our corporate office is located at 310 Fourth Avenue South,
Suite 700, Minneapolis, MN 55415. This office space is rented from an unaffiliated third party on a month-to-month basis under terms of
a verbal agreement for a monthly rental of $1,200.
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