3 unchanged sentences
We have developed and implemented a cybersecurity risk management program intended to protect the confidentiality, integrity and availability of our critical systems and information.
−Removed: Our cybersecurity risk management program includes a cybersecurity incident response plan.
We design and assess our program based on the Center For Internet Security (“CIS”) Controls.
8 unchanged sentences
• a third-party risk management process for key service providers based on our assessment of their criticality to our operations and respective risk profile.
−Removed: We have not identified risks from known cybersecurity threats, including as a result of any prior cybersecurity incidents, that have materially affected or are reasonably likely to materially affect us, including our operations, business strategy, results of operations or financial condition .
+Added: We have not identified risks from known cybersecurity threats, including as a result of any prior cybersecurity incidents, that have materially affected us, including our operations, business strategy, results of operations, or financial condition.
+Added: We face risks from cybersecurity threats that, if realized, are reasonably likely to materially affect us, including our operations, business strategy, results of operations or financial condition.
For more information, see the section titled “ Risk Factor—Risks related to our intellectual property, information technology and data security—If we or our critical third-party providers experience a significant disruption in our information technology systems or breaches of data security, our business could be adversely affected.
Cybersecurity Governance
−Removed: Our Board considers cybersecurity risk as part of its risk oversight function and has delegated to the Audit Committee oversight of cybersecurity and other information technology risks.
−Removed: The Audit Committee oversees management’s implementation of our cybersecurity risk management program.
−Removed: The Audit Committee receives periodic reports from management on our cybersecurity risks, including written reports.
−Removed: In addition, management updates the Audit Committee, as necessary, regarding any material cybersecurity incidents, as well as any incidents with lesser impact potential.
+Added: Our Board considers cybersecurity risk as part of its risk oversight function and has delegated to the Audit Committee oversight of cybersecurity and other information technology risks, including management’s implementation of our cybersecurity risk management program.
+Added: The Audit Committee receives regular reports from management on our cybersecurity risks, including written reports.
+Added: In addition, management updates the Audit Committee regarding any cybersecurity incidents it considers to be significant or potentially significant.
The Audit Committee reports to the full Board regarding its activities, including those related to cybersecurity.
−Removed: Our management team, including our Chief Legal Officer, President, Chief Financial Officer and Vice President of Data Analytics and Information Security is responsible for assessing and managing our material risks from cybersecurity threats.
+Added: Our management team, including our General Counsel, President and Chief Financial Officer, is responsible for assessing and managing our material risks from cybersecurity threats.
The team has primary responsibility for our overall cybersecurity risk management program and supervises both our internal cybersecurity personnel and our external cybersecurity consultants.
−Removed: Our management team’s cumulative experience includes decades of experience managing cybersecurity risks including serving in similar roles leading and overseeing cybersecurity programs at other companies.
−Removed: Our Vice President of Data Analytics and Information Security has served in various roles in information technology and information security for more than 10 years.
−Removed: He holds an undergraduate degree in engineering science from Harvard University and postgraduate degrees in computer science from Massachusetts Institute of Technology.
−Removed: Our Chief Legal Officer has over 25 years of experience managing risks, including risks arising from cybersecurity threats, at several large publicly-traded technology companies.
Team members who support our information security program have relevant educational and industry experience, including holding similar positions at large technology companies.
Our management team takes steps to stay informed about and monitor efforts to prevent, detect, mitigate and remediate cybersecurity risks and incidents through various means, which may include briefings from internal security personnel;
−Removed: threat intelligence and other information obtained from governmental, public or private sources, including external consultants engaged by us;
+Added: intelligence and other information obtained from governmental, public or private sources, including external consultants engaged by us;
and alerts and reports produced by security tools deployed in our information technology environment.
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.