Introduction
Parabola considers protection of Customer Data a top priority. As further described in this Parabola Information Security Policy, Parabola uses commercially reasonable organizational and technical measures designed to prevent unauthorized access, use, alteration or disclosure of Customer Data stored on systems under Parabola’s control.
1. Customer Data and Management. Parabola limits its personnel’s access to Customer Data as follows:
1.1. Requires unique user access authorization through secure logins and passwords, including multi-factor authentication for Cloud Hosting administrator access and individually-assigned Secure Socket Shell (SSH) keys for external engineer access;
1.2. Limits the Customer Data available to Parabola personnel on a “need to know” basis;
1.3. Restricts access to Parabola’s production environment by Parabola personnel on the basis of business need;
1.4. Encrypts user security credentials for production access; and
1.5. Prohibits Parabola personnel from storing Customer Data on electronic portable storage devices such as computer laptops, portable drives and other similar devices.
1.6. Parabola logically separates each of its customers’ data and maintains measures designed to prevent Customer Data from being exposed to or accessed by other customers.
2. Data Encryption. Parabola provides industry-standard encryption for Customer Data as follows:
2.1. Implements encryption in transport and at rest where reasonably practicable for all HTTPS connections;
2.2. Uses strong encryption methodologies to protect Customer Data, including AES 256-bit encryption for Customer Data stored in Parabola’s production environment; and
2.3. Encrypts all Customer Data located in cloud storage while at rest.
3. Network Security, Physical Security and Environmental Controls
3.1. Parabola uses firewalls, network access controls and other techniques designed to prevent unauthorized access to systems processing Customer Data.
3.2. Parabola maintains measures designed to assess, test and apply security patches to all relevant systems and applications used to provide the Services.
3.3. Parabola monitors privileged access to applications that process Customer Data, including cloud services.
3.4. The Services operate on Amazon Web Services (“AWS”) and is protected by the security and environmental controls of Amazon. Detailed information about AWS security is available at https://aws.amazon.com/security/ and http://aws.amazon.com/security/sharing-the-security-responsibility/. For AWS SOC Reports, please see https://aws.amazon.com/compliance/soc-faqs/.
3.5. Customer Data stored within AWS is encrypted at all times. AWS does not have access to unencrypted Customer Data.
4. Independent Security Assessments. Parabola periodically assesses the security of its systems and the Services as follows:
4.1. Annual detailed security and vulnerability assessments of the Services conducted by independent third-party security experts that include a code analysis and a comprehensive security review. Parabola shall attest to Customer the date of the most recent security and vulnerability assessment at Customer’s reasonable request.
4.2. Annual penetration testing of Parabola systems and applications to test for exploits including, but not limited to, XSS, SQL injection, access controls, and CSRF.
4.4. Monthly vulnerability scanning.
5. Incident Response. If Parabola becomes aware of unauthorized access or disclosure of Customer Data under its control (a “Breach”), Parabola will:
5.1. Take reasonable measures to mitigate the harmful effects of the Breach and prevent further unauthorized access or disclosure.
5.2. Upon confirmation of the Breach, notify Customer in writing (including email) of the Breach without undue delay. Notwithstanding the foregoing, Parabola is not required to make such notice to the extent prohibited by Laws, and Parabola may delay such notice as requested by law enforcement and/or in light of Parabola’s legitimate needs to investigate or remediate the matter before providing notice.
5.3. Each notice of a Breach will include:
5.3.1. The extent to which Customer Data has been, or is reasonably believed to have been, used, accessed, acquired or disclosed during the Breach;
5.3.2. A description of what happened, including the date of the Breach and the date of discovery of the Breach, if known;
5.3.3. The scope of the Breach, to the extent known; and
5.3.4. A description of Parabola’s response to the Breach, including steps Parabola has taken to mitigate the harm caused by the Breach.
6. Business Continuity Management
6.1. Parabola maintains an appropriate business continuity and disaster recovery plan.
6.2. Parabola maintains processes to ensure failover redundancy with its systems, networks and data storage.
7. Personnel Management
7.1. Parabola performs employment verification, including proof of identity validation and criminal background checks for all new hires, in accordance with applicable law.
7.2. Parabola provides training for its personnel who are involved in the processing of the Customer Data to ensure they do not collect, process or use Customer Data without authorization and that they keep Customer Data confidential, including following the termination of any role involving the Customer Data.
7.3. Parabola conducts routine and random monitoring of employee systems activity.
7.4. Upon employee termination, whether voluntary or involuntary, Parabola immediately disables all access to Parabola systems, including Parabola’s physical facilities.