Item 1B. Unresolved Staff Comments
Item 1B. Unresolved Staff Comments
None.
Item 1C. Cybersecurity
Cyber criminals are becoming more sophisticated and
effective every day, and they are increasingly targeting companies similar to ours operating in the technology, software and identification
space. All companies utilizing technology are subject to threats of breaches of their cybersecurity programs. To mitigate the threat to
our business, we take a comprehensive approach to cybersecurity risk management and make securing the data customers and other stakeholders
entrust to us a top priority. Our Board of directors and our management are actively involved in the oversight of our risk management
program, of which cybersecurity represents an important component. As described in more detail below, we have established policies, standards,
processes and practices for assessing, identifying, and managing material risks from cybersecurity threats. We have devoted significant
financial and personnel resources to implement and maintain security measures to meet regulatory requirements and customer expectations,
and we intend to continue to make significant investments to maintain the security of our data and cybersecurity infrastructure. There
can be no guarantee that our policies and procedures will be properly followed in every instance or that those policies and procedures
will be effective to prevent cyberattack incidents. Such incidents, whether or not successful, could result in our incurring significant
costs related to, for example, rebuilding our internal systems, implementing additional threat protection measures, providing modifications
or replacements to our products and services, defending against litigation, responding to regulatory inquiries or actions, paying damages,
providing customers with incentives to maintain a business relationship with us, or taking other remedial steps with respect to third
parties, as well as incurring significant reputational harm. In addition, these threats are constantly evolving, thereby increasing the
difficulty of successfully defending against them or implementing adequate preventative measures. We have seen an increase in cyberattack
volume, frequency, and sophistication. Although our Risk Factors include further detail about the material cybersecurity risks we face,
we believe that as of the date of this Annual Report on Form 10-K, risks from prior cybersecurity threats, have not materially affected
our business to date. We can provide no assurance that there will not be incidents in the future or that they will not materially affect
us, including our business strategy, results of operations, or financial condition.
Risk Management and Strategy
Our policies, standards, processes and practices for
assessing, identifying, and managing material risks from cybersecurity threats are based on frameworks established by the International
Organization for Standardization, specifically ISO/IEC 27001:2013 and other applicable industry standards. We have established comprehensive
Information Security Management Systems (“ISMS”) policies, which are independently reviewed and audited annually for conformity
and effectiveness under ISO/IEC 27001. Our cybersecurity program in particular focuses on the following key areas:
Collaboration
Our cybersecurity risks are identified and addressed
through a comprehensive, cross-functional approach. Key security, risk, and compliance stakeholders, including a member of the Board meet
at least monthly to develop strategies for preserving the confidentiality, integrity and availability of our company and customer information,
identifying, preventing and mitigating cybersecurity threats, and effectively responding to cybersecurity incidents. We maintain controls
and procedures that are designed to ensure prompt escalation of certain cybersecurity incidents so that decisions regarding public disclosure
and reporting of such incidents can be made by management and the Board in a timely manner.
Risk Assessment
At least annually, we conduct a cybersecurity risk
assessment that takes into account information from internal stakeholders, known information security vulnerabilities, and information
from external sources (e.g., reported security incidents that have impacted other companies, industry trends, and evaluations by third
parties and consultants). The results of the assessment are used to drive alignment on, and prioritization of, initiatives to enhance
our security controls, make recommendations to improve processes, and inform a broader enterprise-level risk assessment that is presented
to our Board and members of management. Risk assessment is integral to all engineering, business and operational decisions and in addition
to the annual reviews, is an ongoing effort, as circumstances and facts arise.
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Self Audit
At least annually we conduct a self-audit of our information
security management systems (“ISMS”), in order to identify if there is any non-conformance with our ISMS policies and procedures.
The results of the self-audit are reported to our Steering Committee and our external auditor for ISO/IEC 27001 compliance.
Technical Safeguards
We regularly assess and deploy technical safeguards
designed to protect our information systems from cybersecurity threats. Such safeguards are regularly evaluated and improved based on
vulnerability assessments, cybersecurity threat intelligence and incident response experience.
Incident Response and Recovery Planning
We have established comprehensive incident response
and recovery plans and continue to regularly test and evaluate the effectiveness of those plans. Our incident response and recovery plans
address — and guide our employees, management and the Board on — our response to a cybersecurity incident.
Third-Party Risk Management
We have implemented controls designed to identify
and mitigate cybersecurity threats associated with our use of third-party service providers. Such providers are subject to security risk
assessments at the time of onboarding and contract renewal. We use a variety of inputs in such risk assessments, including information
supplied by providers and third parties. In addition, we require our providers to meet appropriate security requirements, controls and
responsibilities.
Education and Awareness
Our policies require each of our employees to contribute
to our data security efforts. We regularly remind employees of the importance of handling and protecting customer and employee data, including
through regular privacy and security training and testing to enhance employee awareness of how to detect and respond to cybersecurity
threats.
External Assessments
Our cybersecurity policies, standards, processes and
practices are regularly assessed by consultants and external independent auditors. These assessments include a variety of activities including
information security assessments, audits and independent reviews of our ISMS, control environment and operating effectiveness. For example,
in 2023 and 2024, we conducted independent audits to assess our ISMS against the ISO/IEC 27001:2013 standard and received certification
of compliance with the standard. We also undertake regular penetration testing of our systems. The results of significant assessments
are reported to management and the Board. Cybersecurity processes are adjusted based on the information provided from these assessments.
We have also obtained industry certifications and attestations that demonstrate our dedication to protecting the data our customers entrust
to us.
Governance
Board Oversight
Our Board oversees our management of cybersecurity
risk. They receive regular reports from management about the prevention, detection, mitigation, and remediation of cybersecurity incidents,
including material security risks and information security vulnerabilities. Our Security Committee directly oversees our cybersecurity
program. The Board receives periodic updates from management on cybersecurity risk resulting from risk assessments, progress of risk reduction
initiatives, external auditor feedback, control maturity assessments, and relevant internal and industry cybersecurity incidents.
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Management’s Role
Our Chief Technology Officer (“CTO”) and Chief Operating Officer
(“COO”) have primary responsibility for assessing and managing material cybersecurity risks.
Our CTO and COO are both seasoned computer scientists and technology entrepreneurs
with over 25 years of experience.
Item 2. Properties
The Company’s registered corporate address is 300 Delaware Avenue,
Suite 210 #301, Wilmington, Delaware 19801 and its operational headquarters is located at 1063 N Spaulding Ave, West Hollywood, CA 90046.
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