10 unchanged sentences
Risk Management and Strategy
−Removed: The Chief Technology Officer (“CTO”) oversees the Company’s information security program and is responsible for the day-to-day information risk management activities through the internal information technology team, and outside resources.
−Removed: The CTO, who has 32 years of Information Technology (“IT”) and IT security experience, employs a team of information technology experts, including a Director of IT who is further supported by other members of the IT and technology department.
+Added: There are no management positions directly responsible for overseeing our cybersecurity risk.
+Added: The Chief Operating Officer (“COO”) who functions as our head of IT and certain members of management assist with our cybersecurity efforts and risk assessments.
+Added: The COO has over 10 years of prior experience in information technology and security.
We have developed and implemented cybersecurity and data privacy processes and procedures that are informed by recognized cybersecurity frameworks and standards, including Microsoft Azure CSPM and SOC 2.
13 unchanged sentences
In the last three years, we have not experienced a material information security breach incident, or any penalties or settlements related to the same, and the expenses we have incurred from information security breach incidents were immaterial.
+Added: We are a remote-first company, founded during the COVID-19 crisis.
+Added: All of our facilities are located on land that is leased from third parties.
+Added: We believe that these facilities meet our current and future anticipated needs.
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.