Item 1B. Unresolved Staff Comments
ITEM
1B. UNRESOLVED STAFF COMMENTS
Not
applicable.
ITEM
1C. CYBERSECURITY
Organizations
in our industry are frequently confronted with a broad range of cybersecurity threats, ranging from uncoordinated, individual attempts
to gain unauthorized access to an organization’s information technology (“IT”) environment to sophisticated and targeted
cyberattacks sponsored by foreign governments and criminal enterprises. Although we employ comprehensive measures to prevent, detect,
address, and mitigate these threats, a cybersecurity incident could potentially result in the misappropriation, destruction, corruption,
or unavailability of critical data, personal identifiable information, and other confidential or proprietary data (our own or that of
third parties) and the disruption of business operations. The potential consequences of a material cybersecurity incident include remediation
and restoration costs, reputational damage, litigation with third parties, and diminution in the value of our investment in research
and development, which in turn could adversely affect our competitiveness and results of operations. Accordingly, cybersecurity is an
important part of our Enterprise Risk Management (“ERM”) program, and the Company seeks to address cybersecurity risks through
a comprehensive, cross-functional approach.
The
Company’s cybersecurity policies, standards, processes, and practices for assessing, identifying, and managing material risks from
cybersecurity threats and responding to cybersecurity incidents are integrated into the Company’s risk management program and are
based on recognized frameworks established by the National Institute of Standards and Technology. The Company has established controls and procedures, including an Incident
Response Plan, that provide for the identification, analysis, notification, escalation, communication, and remediation of data security
incidents at appropriate levels so that so that decisions regarding the public disclosure and reporting of such incidents can be made
by management in a timely manner. In particular, the Company’s Incident Response Plan (i) is designed to identify and detect information
security threats through various mechanisms, such as through security controls and third-party disclosures, and (ii) sets forth a process
to (a) analyze any such threats detected within the Company’s IT environment or within a third-party’s IT environment, (b)
contain cybersecurity threats under various circumstances, and (c) better ensure the Company can recover from cybersecurity incidents
to a normal state of business operations. The Company has established and maintains other incident response and recovery plans that
address the Company’s response to a cybersecurity incident.
As
part of its cybersecurity program, the Company deploys measures to deter, prevent, detect, respond to and mitigate cybersecurity threats,
including firewalls, anti-malware, intrusion prevention and detection systems, identity and access controls, software patching protocols,
and physical security measures. The Company periodically assesses and tests the Company’s policies, standards,
processes, and practices that are designed to address cybersecurity threats and incidents, including by assessing current threat intelligence,
conducting tabletop exercises, and vulnerability and security testing,. The Company has a process to report material
results of such testing and assessments to the board, and periodically adjusts the Company’s cybersecurity program
based on these exercises. The Company engages third parties to conduct part of such testing The Company identifies and oversees cybersecurity risks presented by third parties and their systems from a risk-based
perspective The Company also conducts cybersecurity
training for employees (including mandatory training programs for system users).
Many
of the Company’s IT systems operate with a hosted architecture or by third-party service providers, and if these third-party IT
environments fail to operate properly, our systems could stop functioning for a period of time, which could put our users at risk. Accordingly,
our ability to keep our business operating is highly dependent on the proper and efficient operation of IT service providers, and our
vendor management process is an important part of our risk mitigation strategy. In particular, we obtain reports from our vendors handling sensitive data as to their efficacy and efficiency in managing cybersecurity
issues and follow-up with them on any potential or actual issues.
Notwithstanding, if there is a catastrophic event, such as an adverse weather condition, natural disaster, terrorist attack, security
breach, or other extraordinary event, the Company, and our service providers, may be unable to provide our products or services for the
duration of the event and/or a time thereafter.
Considering
the pervasive and increasing threat from cyberattacks, the board and the audit committee, with input from management, assess the Company’s
cybersecurity threats and the measures implemented by the Company to mitigate and prevent cyberattacks. The audit committee consults
with management regarding ongoing cybersecurity initiatives, and requests management to report to the audit committee or the full board
regularly on their assessment of the Company’s cybersecurity program and risks. Both the audit committee and the full board will
receive regular reports from its senior management on cybersecurity risks, timely reports regarding any cybersecurity incident that meets
established reporting thresholds, as well as ongoing updates regarding any such incident until it has been addressed. Our board has risk
management experience. We hire consultant and third parties to conduct our threat assessments and supplement the monitoring of such threats
by utilizing online data tools.
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In
addition, the Company’s information security and/cybersecurity program is managed by our Chief Technology Officer
(“CTO”) a, whose team is responsible for leading enterprise-wide cybersecurity strategy, policy, standards,
architecture, and processes. The CTO provides periodic reports to our audit committee as well as our Co-Chief Executive Officers and
Chief Financial Officer and other members of our senior management as appropriate. We have also established cross-functional teams
to collaborate and communicate on cybersecurity-related issues. The reports to management include updates on the Company’s
cyber risks and threats, the status of projects to strengthen our information security systems, assessments of the information
security program, and the emerging threat landscape. Our CTO, Mr. Eliran Ben-Zikri served in the one of the most elite computer units of the Israeli Defense Force and has
over 10 years of experience in the cloud technology, previously holding senior positions in leading Israeli technology companies, including
eToro and SimilarWeb.
As
of the date of this report, the Company is not aware of risks from cybersecurity threats that have materially
affected or are reasonably likely to materially affect the Company, including its business strategy, results of operations, or
financial condition.