Exabeam Data Security Policy

In connection with the Product, SaaS and/or Support Services (“Solutions”), the parties anticipate that EXABEAM and where applicable its subcontractors, may from time to time process certain personal data in respect of which CUSTOMER, its Affiliates, or clients of CUSTOMER or its Affiliates may be a data controller under the Data Protection Legislation (as defined below). EXABEAM and CUSTOMER agree to the terms of this Data Security Policy (“Policy”) in order to ensure that adequate safeguards are put in place with respect to the protection of such personal data as required by the Data Protection Legislation.

1. DEFINITIONS.

Unless otherwise defined herein, capitalized terms used in this Policy shall have the same meaning as set forth in the Agreement.

1.1 “Adequate Country” means a country or territory that is recognized under Data Protection Legislation from time to time as providing adequate protection for personal data.

1.2 “Affiliate” means an entity directly or indirectly controlling, controlled by or under common control with a party. For purposes of this Policy, “control” means the ownership or control, directly or indirectly, of at least fifty percent (50%) or more of all the voting shares (or other securities or rights) entitled to vote for the election of directors or other governing authority.

1.3 “CCPA” means the California Consumer Privacy Act of 2018.

1.4 “Data Protection Legislation” means all privacy laws and regulations applicable to any Personal Data processed under or in connection with this Agreement, including without limitation, the Data Protection Directive 95/46/EC (as the same may be superseded by the GDPR, the Privacy and Electronic Communications Directive 2002/58/EC, CCPA, UK Data Protection Act 2018, and all national legislation implementing or supplementing the foregoing.

1.5 “GDPR” means the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

1.6 “Personal Data” means all data which is defined as ‘Personal Data’ in the Data Protection Legislation and that is provided directly or indirectly by CUSTOMER to EXABEAM, or accessed, stored or otherwise processed by EXABEAM or its sub-processors (as applicable) for the purposes of delivering the Solution to CUSTOMER.

1.7 “Processing”, “Data Controller”, “Data Processor”, “Data Subject” and “Supervisory Authority” shall have the meanings ascribed to them in the Data Protection Legislation.

1.8 “Standard Contractual Clauses / SCC” means the Commission Implementing Decision (EU) 2021/914 of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council available at https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?uri=CELEX%3A32021D0914&locale=en.

1.9 “UK Addendum” means the International Data Transfer Addendum to the SCCs issued by the Commissioner under S119A(1) Data Protection Act 2018, Version B1.0, in force 21 March 2022 and available at https://ico.org.uk/media/for-organisations/documents/4019539/international-data-transfer-addendum.pdf.

2. DATA PROCESSING.

2.1 Scope and Roles of the Parties. The parties acknowledge and agree that with regard to the Processing of Personal Data, CUSTOMER is the Data Controller, EXABEAM is the Data Processor, and that EXABEAM may engage sub-processors pursuant to the requirements set forth in Section 7 below.

2.2 Compliance with Laws. Each party will comply with all laws, rules and regulations applicable to it and binding on it in the performance of its obligations under this Policy, including the Data Protection Legislation.

2.3 Processing Instructions. EXABEAM will process Personal Data in accordance with the agreement then in effect between EXABEAM and CUSTOMER (“Agreement”) and with CUSTOMER’s reasonable written instructions, where such instructions are consistent with the terms of the Agreement and this Policy. EXABEAM may also use Customer Data during the Subscription Term in support of product offerings, for bug fixes, and validation of data modeling. As between the parties, CUSTOMER shall have sole responsibility for the accuracy, quality, and legality of Personal Data and the means by which CUSTOMER acquired Personal Data.

2.4 California Consumer Privacy Act. The Solutions may include EXABEAM processing information on behalf of CUSTOMER, and/or CUSTOMER may disclose Personal Information, as defined in CCPA, to EXABEAM as a Service Provider for the purpose of performing the Solution under the Agreement. To the extent EXABEAM processes Personal Information of California residents on CUSTOMER’s behalf as set forth in the Agreement, EXABEAM shall comply with the applicable provisions of the CCPA. EXABEAM agrees that it will not:

(1) retain, use, or disclose such Personal Information for any purpose other than the specific purpose of performing the rights and obligations specified in the Agreement, or as otherwise permitted by CCPA;

(2) retain, use, or disclose such Personal Information for a commercial purpose other than providing the Solution or as otherwise set forth in the Agreement;

(3) Sell such Personal Information; or

(4) retain, use, or disclose the Personal Information outside the direct business relationship between EXABEAM and CUSTOMER.

EXABEAM understands the requirements of the CCPA and will comply with them. EXABEAM shall implement reasonable security measures to safeguard Personal Information in its possession. Further, EXABEAM will reasonably assist CUSTOMER with meeting CUSTOMER’s CCPA obligations, which may include fulfilling verifiable deletion requests and assisting with verifiable access requests by providing access to Personal Information that EXABEAM holds in a mutually agreed upon format. The parties agree that nothing about this Agreement or the Solution involves a “selling” or a “sale” of Personal Information under Cal. Civ. Code §1798.140(t)(1). All terms in this Section not otherwise defined in this Agreement will have the meaning ascribed to such terms under the CCPA. For the avoidance of doubt, this section shall not apply to information exempt from the application of CCPA.

3. DATA TRANSFERS.

3.1 CUSTOMER acknowledges that the provision of the Solution under the Agreement may require the Processing of Personal Data by sub-processors in countries outside the European Economic Area (EEA) from time to time.

3.2 To the extent any processing of Personal Data by EXABEAM or its applicable sub-processor (which may include, without limitation, any affiliates), without prejudice to Section 7, takes place in any country outside the EEA the parties agree that it will ensure that a mechanism to achieve adequacy in respect of that processing is in place such as: (i) the country will be an Adequate Country: (ii) the Standard Contractual Clauses will apply in respect of that processing and EXABEAM will comply with the obligations of the ‘data importer’ in the Standard Contractual Clauses and CUSTOMER will comply with the obligations of ‘data exporter’, or, for its sub-processors, EXABEAM shall execute Standard Contractual Clauses approved by the EU authorities under Data Protection Legislation, which may include, as applicable, the UK Addendum; or (ii) any other specifically approved safeguard for data transfers (as recognized under the Data Protection Legislation) and/or a European Commission finding of adequacy.

3.3 To the extent the Standard Contractual Clauses are used as the applicable mechanism for processing as described in Section 3.2:

3.3.1 The Controller to Processor Modules (Module 2) will apply to the processing of Personal Data by EXABEAM on behalf of CUSTOMER, and the Controller to Controller Modules (Module 1) will apply to the processing of Personal Data by EXABEAM as otherwise provided in the Agreement, whereby:

3.3.1.1 Clause 7 (“Docking Clause”) shall not apply;

3.3.1.2 Clause 9, as pertaining to Module 2, (a) Option 2 (“General Written Authorization”) shall apply with a 30-day notice period to object to the sub-processor;

3.3.1.3 Clause 11 (a) (“Redress”) shall not include the mentioned OPTION;

3.3.1.4 Clause 17 (“Governing Law”) shall include OPTION 1, with the Republic of Ireland to be included as the Member State;

3.3.1.5 Clause 18 (“Choice of forum and jurisdiction”) shall include the Republic of Ireland as the Member State; and

3.3.1.6 The Annexes attached hereto shall serve as the respective Annexes I, II, and III of the Standard Contractual Clauses between the Parties.

3.4 To the extent the UK Addendum is used as the applicable mechanism for processing as described in Section 3.2:

3.4.1 CUSTOMER shall be the “Exporter,” and EXABEAM shall be the “Importer”; and

3.4.2 “Neither Party” shall be the selected option for Table 4.

4. SECURITY; AUDITS.

4.1 Security. EXABEAM will maintain appropriate technical and organizational safeguards against the unauthorized and unlawful Processing of Personal Data, and against accidental loss or destruction of, and damage to CUSTOMER data. EXABEAM shall provide commercially reasonable assistance as CUSTOMER reasonably requests (taking into account the nature of processing and the information available to EXABEAM) to CUSTOMER in relation to: (i) CUSTOMER’s obligations under Data Protection Legislation with respect to data protection impact assessments (as such term is defined in the GDPR); (ii) notifications to the Supervisory Authority and/or communications to Data Subjects by CUSTOMER in response to any Data Breach (as defined below); and (iii) CUSTOMER’s compliance with its obligations under the GDPR with respect to the security of processing. CUSTOMER agrees to pay EXABEAM’s charges for providing such assistance, at EXABEAM’s standard rates provided to CUSTOMER.

4.2 Certifications. EXABEAM uses external auditors to verify the adequacy of its security measures. This audit will be performed: (i) at least annually; (ii) in accordance with industry standards, which may include SOC 2 or ISO or such other comparable standards; and (iii) by an independent third party at EXABEAM’s selection and expense.

4.3 Audit Procedure. EXABEAM shall provide reasonable cooperation and assistance to CUSTOMER and/or its auditors to allow CUSTOMER to meet applicable requirements under the Data Protection Legislation. In order for CUSTOMER to exercise its right of audit under the Data Protection Legislation, EXABEAM will provide, upon request: (i) an audit report not older than 18 months by an accredited and independent external auditor demonstrating that EXABEAM’s technical and organizational measures are sufficient and in accordance with an accepted industry audit standard such as ISO 27001 or SOC2); and (ii) additional information in EXABEAM’s possession or control which relates to the data processing activities carried out by EXABEAM under this Policy, as required and requested by an EU supervisory authority. Except as otherwise ordered by a Supervisory Authority, any audits required by the SCC shall be limited to no more than once annually, and the scope and timing of such audit shall be mutually agreed upon by the parties.

4.4. Records. EXABEAM shall, as required by Data Protection Legislation, make available to CUSTOMER such information in EXABEAM’s possession or control as CUSTOMER may reasonably request in order to demonstrate EXABEAM’s compliance with the obligations of data processors under the Data Protection Legislation in relation to its processing of Personal Data.

4.5 Deletion. As soon as reasonably practicable following, and in any event within ninety (90) days of, termination or expiration of the Agreement or any applicable subscription term thereunder, EXABEAM will delete all Customer Data (including copies thereof) processed pursuant to this Policy.

5. BREACH NOTIFICATION.

EXABEAM maintains security incident response policies and procedures and shall, to the extent permitted by law: (i) promptly, and without undue delay upon becoming aware, notify CUSTOMER of any breach of security leading to the destruction, loss, alteration, or unauthorized disclosure of Personal Data transmitted, stored or otherwise processed by EXABEAM, (a “Data Breach”); (ii) taking into account the nature of processing and the information available to EXABEAM at the time it became aware of the Data Breach, take reasonable steps to mitigate the effects and to minimize any damage resulting from the Data Breach; and (iii) provide commercially reasonable cooperation and assistance during such investigation to remediate such occurrence.

6. EXABEAM PERSONNEL.

6.1 EXABEAM shall ensure its personnel involved in the processing of Personal Data are informed of the confidential nature of the Personal Data, have received appropriate training regarding their responsibilities, and have executed written confidentiality agreements.

6.2 EXABEAM shall ensure that access to Personal Data is limited to personnel involved in the provision of the Solution and in accordance with Exabeam’s information security policy.

6.3 EXABEAM shall take commercially reasonable steps to ensure the reliability of any EXABEAM personnel engaged in the Processing of Personal Data.

6.4 EXABEAM has appointed a data protection officer and governance team that can be reached at: [email protected]

7. SUBPROCESSORS.

7.1 Subcontracting. CUSTOMER grants a general authorization to EXABEAM to appoint sub-processors, third party data center operators, and outsourced support and service providers to fulfill its contractual obligations under this Policy.

7.2 Sub-processor Obligations. EXABEAM will ensure that any sub-processor it engages to provide the Solution on its behalf in connection with the Agreement: (i) accesses CUSTOMER data only to the extent necessary to fulfill EXABEAM’s rights and obligations set forth in the Agreement or this Policy and not for any other purpose; and (ii) enters into a written contract which imposes upon such sub-processor appropriate and relevant contractual obligations, including those regarding confidentiality, data protection, data security, and audit rights; such obligations shall be substantially as protective of Personal Data as those imposed on EXABEAM in this Policy. EXABEAM shall be responsible for its compliance with this Policy and for any acts or omissions of the sub-processor that cause EXABEAM to breach any of EXABEAM’s obligations under this Policy.

7.3 Objection to New Sub-Processors. EXABEAM will maintain a list of current sub-processors available at https://mycommunity.exabeam.com/kb//helplegal/legal-exabeam-subprocessors/666339. If, after the effective date of the Agreement, Exabeam engages new or replacement sub-processors, these sub-processors will be added to the list prior to them starting sub-processing of Personal Data. If CUSTOMER has a reasonable objection to any new or replacement sub-processor, it shall notify EXABEAM of such objections in writing within thirty (30) days of such sub-processor being added to the list and the parties will seek to resolve the matter in good faith. If EXABEAM is able to provide the Solution to CUSTOMER in accordance with the Agreement without using the sub-processor and decides in its discretion to do so, then CUSTOMER will have no further rights under this Section 7.3 in respect of the proposed use of the sub-processor. If EXABEAM cannot reasonably avoid using the sub-processor and is unable to satisfy CUSTOMER as to the suitability of the sub-processor or the documentation and protections in place between EXABEAM and the sub-processor, then either party may pursue alternatives for resolution.

8. DATA SUBJECT REQUESTS; DELETION.

Where required under Data Protection Legislation, EXABEAM shall promptly notify CUSTOMER if it receives a request from a Data Subject to access, rectify or erase that person’s Personal Data or if a Data subject objects to the processing of, or makes a data portability request in respect of, such Personal Data (together, “Data Subject Request”). EXABEAM shall provide commercially reasonable efforts to assist CUSTOMER in responding to a Data Subject Request, provided that CUSTOMER has instructed EXABEAM to do so. EXABEAM will not independently respond to requests from CUSTOMER’s end users without CUSTOMER’s prior written consent, except to confirm that the request relates to CUSTOMER. To the extent CUSTOMER does not have the ability to address a Data Subject Request, EXABEAM shall, upon CUSTOMER’S request, provide reasonable assistance to facilitate a response to such Data Subject Request. CUSTOMER agrees to pay EXABEAM the applicable fees for providing such assistance, at EXABEAM’s standard rates provided by EXABEAM to CUSTOMER.

9. GENERAL.

9.1 Interpretation. Except as amended by this Policy, the Agreement will remain in full force and effect. If there is a conflict between the Agreement and this Policy, this Policy shall apply so far as the subject matter concerns the processing of Personal Data.

9.2 Severability. If any provision of this Policy is determined to be unenforceable by a court of competent jurisdiction, that provision will be severed, and the remainder of terms will remain in full effect.

9.3 Governing law and jurisdiction. This Policy is governed by the law of the Agreement.

ANNEX 1 – STANDARD CONTRACTUAL CLAUSES

A. LIST OF PARTIES

Data exporter(s): The data exporter is the entity identified in the Agreement as the licensee of the Solution.

Data importer(s): The data importer is EXABEAM Inc. (“EXABEAM”)

B. DESCRIPTION OF TRANSFER

EXABEAM is a provider of enterprise software and offers Software as a Service (SaaS) solutions. EXABEAM also offers on premise software solutions and technical support in relation to all its products and services.

Categories of data subjects whose personal data is transferred:

The categories of data subjects are in the discretion of the data exporter and may include employees of the data exporter, members of Customer’s active directory, which may be internal or external, or other individuals Customer elects to monitor through the use of the Products.

Categories of personal data transferred:

The personal data transferred may concern the following categories of data (only applicable if the data subjects are natural persons):

• First and last name
• Contact Information (including postal address, email address, phone)
• Company and/or employer
• Title and/or position
• Additional data as entered in the discretion of the data exporter

Sensitive data transferred:

Processing of Sensitive data is not required. Sensitive data shall only be entered at the discretion of the data exporter.

The frequency of the transfer:

Continuous or in the discretion of the data exporter

Nature of the processing:

With respect to Module 1, Personal Data uploaded to the SaaS environment may be used by Exabeam in support of product offerings, for bug fixes, and validation of data modeling. With respect to Module 2, Exabeam processes the data in providing the Solution, including in generating output of the CUSTOMER’s use of SaaS. EXABEAM may further process Personal Data to enable Exabeam to provide Support Services, such as Technical Support and Deployment Services.

Purpose(s) of the data transfer and further processing:

The processing will comprise of only the activities necessary to provide the Solution or as otherwise mutually agreed upon by the parties.

The period for which the personal data will be retained:

The duration of the processing will be: until the earliest of; (expiration or termination of the Agreement; or (ii) the date upon which processing is no longer necessary for the purposes of either party performing its obligations under the Agreement, unless otherwise agreed in writing.

For transfers to (sub-) processors, also specify subject matter, nature and duration of the processing:

The subject matter of the processing is identified in the list available at https://mycommunity.exabeam.com/kb/helplegal/legal-exabeam-subprocessors/666339.

Processing by subprocessors is as necessary to allow EXABEAM to fulfill its rights and obligations set forth in the Agreement or this Policy. The subject matter, nature, and duration of the processing is consistent with the duration of the data importer’s processing, as set forth above.

C. COMPETENT SUPERVISORY AUTHORITY

The competent supervisory authority shall be as set forth in Section 3.3.1 of this Policy.

ANNEX 2 – STANDARD CONTRACTUAL CLAUSES

This Annex 2 includes a list of controls, practices, and procedures implemented by the data importer(s) to ensure an appropriate level of security, taking into account the nature, scope, context, and purpose of the processing, and the risks for the rights and freedoms of natural persons. Notwithstanding anything to the contrary herein, EXABEAM shall be entitled to modify this Annex II from time to time provided the level of protection afforded to personal data hereunder is not materially reduced or altered.

Risk Assessments

As part of Exabeam’s risk management activities, Exabeam conducts annual and ongoing enterprise risk assessments, whereby the Exabeam management team draws on collective industry, enterprise, technical, and regulatory knowledge to identify key risks across all categories of business operations including strategy, operations, reporting and compliance.

• Exabeam maintains a formal risk assessment to identify risks, rankings, and mitigation strategies for the forthcoming year.
• The assessment is regularly updated to reflect changes or developments in the market, industry, or regulatory or legal risks.
• Exabeam conducts an annual penetration test by an independent third party. Each item identified by such assessment is reviewed and prioritized for mitigation, which may include a change in policy, monitoring, or more frequent evaluations.
• Internal vulnerability scans are performed periodically and critical vulnerabilities are resolved promptly. Management acts based on the results of the scans and necessary system changes are performed.

Information and Communication

Fault Tolerance and Data Backup

Exabeam’s information systems have been engineered on the principles of high availability, security and confidentiality.

• Exabeam runs many of its production systems utilizing multiple geographically dispersed availability zones within each applicable geographic region. This provides fault tolerance in the event of disaster within any single availability zone.
• In cases where system architecture does not permit utilizing multiple availability zones, data from the current availability zone of operation is backed up periodically to high-availability data storage repositories.

Communication

• Internal users learn about Exabeam systems beginning with their orientation and continuing as needed with on-the-job training and/or specific training courses, with resources available in an internal repository.
• All employees are required to conduct security training at least on an annual basis covering standard industry practices. Where applicable, employees with specialized roles are also required to conduct training specific to their job functions.

Policies and Procedures

• Exabeam maintains a formal information security management program to address identified information security risks.
• The information security policy, along with policy and procedure documents for significant processes, are published and made available to all personnel. These policy and procedure documents are updated annually by their respective owners. Changes in policies and procedures that impact internal users (employees) responsibilities regarding security, availability and confidentiality commitments are communicated via email and in-person meetings.
• Exabeam collects and retains audit logs recording privileged user access activities, authorized and unauthorized access attempts, exceptions, and information security events, in a manner that complies with Exabeam policies and applicable law. Audit logs are evaluated regularly, with measures implemented to help facilitate timely detection, investigation, and response.

Subservice Organization Controls

• Exabeam utilizes Google Cloud (“GCP”) as a subservice organization to provide SaaS services and improve operating and administrative effectiveness.
• Data center facilities are ISO 27001:2013 certified and undergo periodic SOC 1 and SOC 2 Type 2 audits. Certification status and the results of audits are reviewed periodically as part of Exabeam’s monitoring controls and the vendor management process.

Information Technology General Controls

Security Awareness Training

• Exabeam requires its personnel to complete a security awareness program on at least an annual basis.
• In addition, ad hoc training is conducted during orientation, with phishing campaigns, regular communications from Information Security management, and role-specific requirements.

Removal of Access Upon Employment Termination

• Accounts are disabled or deleted by the IT department within 48 hours of termination (typically on the same business day). This termination process includes:
• User access to all applications will be revoked or disabled.
• Access to the domain, administrator, database and critical network devices will be revoked or disabled.
• Physical assets such as equipment, and company credit cards (if applicable) are collected.

Under certain conditions, domain accounts may need to remain accessible after the termination date. In these cases, the account password is changed. When management determines that all necessary data has been preserved, the account is fully closed.

Network Security Overview

Servers and network components are secured with access control mechanisms and protected by hardened industry standard firewalls and intrusion detection systems. All security services are monitored and updated in a timely manner to address emerging vulnerabilities.

Remote Access

• Exabeam employees access production systems through secure access portals via managed devices.
• Exabeam requires two-factor authentication for all remote access activities and production system access.

Wireless Security

• Exabeam has created a virtual local area network (VLAN) with a dedicated IP range for the Exabeam office suite. This VLAN includes both dedicated ethernet ports and wireless access points which provides WPA2 security. The WPA2 wireless network uses encryption and does not allow immediate access to Exabeam systems.
• Exabeam production resources are further protected by a secure VPN tunnel which is encrypted and restricted to authorized users.

Anti-Virus, Firewalls and Encryption

• Next-Gen Antivirus is installed on all workstations and key servers. The antivirus software is configured to use a combination of artificial intelligence, behavioral detection, machine learning algorithms, and exploit mitigation, to detect and block known and unknown threats in real-time.
• Exabeam utilizes firewalls and other lines of defense such as access control and logging to protect external points of connectivity.
• Exabeam corporate endpoints, workstations and laptops are configured with full disk encryption and data backups are encrypted at rest. Customer data in production systems is encrypted at rest.
• All sensitive data transmitted within or outside the Exabeam network is encrypted using industry standard protocols to protect sensitive data against third-party disclosure in transit.

Administrator Access

• Administrative privileges within Exabeam core systems are designated on an individual basis and restricted to authorized personnel based on the least privilege concept.
• All access to such accounts requires the use of multi-factor authentication and instances of access are recorded, monitored and analyzed for anomalous and malicious access.

Access Reviews

• Access rights are assigned based on an individual’s role and job duties. Access rights are adjusted if an individual’s role or job duties change, or if the applicable business process is modified.
• The assignment and approval of access rights is documented to demonstrate who may access data.
• Access to all information environments is periodically reviewed using manual and automated procedures to ensure that access remains provisioned to only the persons who need it to perform their job duties.

System Passwords

• Users are required to enter their unique user ID and password to access any Exabeam network or application.
• Default passwords of systems and applications are changed as a matter of principle.
• Complexity standards for passwords have been established in accordance with NIST 800-63 (or comparable industry standards) to enforce control for corporate networks, systems, and applications as well as production systems and applications.
• Passwords may only be reset or changed by authorized individuals in accordance with a defined process.

System Build and Hardening

• Systems in corporate infrastructure and endpoints are based on a gold image with up-to-date patches and minimum software requirements applied.
• Security patching is scheduled monthly and out-of-cycle (emergency patches) are pushed as required to mitigate noted system vulnerabilities.
• Production system components, including user endpoints, are configured in compliance with corporate minimum security baselines, and operating system patches of Production system components and user endpoints are applied in a timely manner.

System and Performance Monitoring

Exabeam leverages various tools and techniques to proactively monitor the SaaS environment. These tools are designed to identify issues and alert responsible staff of the issue to minimize impact to Exabeam customers.

Security & Incident Management

Personnel responsible for the management of IT systems and applications are trained to recognize, classify, and report security incidents. Security incidents are reported to the information security department for evaluation and resolution. Operations and security personnel follow defined protocols for resolving and escalating reported events. This includes root cause analysis that is escalated to senior management as required. Resolutions of security events are reviewed periodically at incident response team meetings. Internal and external users (to the extent required under the Agreement) are informed of incidents in a timely manner and they are advised of any recommended measures to be taken on their part. Governing entities are notified as required by applicable law.

Security Development Life Cycle (“SDLC”) and Application Security

Exabeam performs security related evaluations during SDLC. Application designs undergo security reviews. Static Application Security Testing (SAST) scans are performed on application code. Vulnerability scans are performed on application code to identify common vulnerability enumerations (CVEs). Third party penetration tests are performed on applications. The findings from the scans are triaged for remediation according to their applicability and severity.

Change Management Policy

The Exabeam Change Management Policy monitors all changes, to both application and infrastructure, within the production data centers. Changes are recorded and approved. Automation programs and ticketing systems are used to track and monitor the status and ownership of all system changes.

Material Changes

Material changes made to systems are communicated with customers through ongoing communications mechanisms and/or mutually agreed amendments to existing contracts.

Data Backup and Redundancy

• Automated backup routines are in place to create snapshot images, database backups and configuration backup of key system components on a routine basis. These backups are stored in the redundant cloud storage environments.
• Backup transactions, including successes or failures, are written to a log file. The log management solution is configured to check this log file periodically, sending alerts for any backup failure.

Confidentiality

• Exabeam has a data classification policy in place to define roles and responsibilities, information classification guidelines, information handling requirements, and supporting procedures

Exabeam has processes in place to:

• locate and remove or redact specified confidential information as required
• regularly and systematically destroy, erase, or make anonymous confidential information that is no longer required for the purposes identified in its confidentiality commitments or system requirements
• erase or destroy records in accordance with the retention policies, regardless of the method of storage (for example, electronic, optical media, or paper based)
• dispose of original, archived, backup, and ad hoc or personal copies of records in accordance with its destruction policies
• document the disposal of confidential information.

Logical access to stored data is restricted to application and database administrators. Backup production data is stored offsite, and access is restricted to authorized users based on the concept of least privilege.

ANNEX 3 – STANDARD CONTRACTUAL CLAUSES

A. LIST OF SUB-PROCESSORS

EXABEAM will maintain a list of current sub-processors available at https://mycommunity.exabeam.com/kb/helplegal/legal-exabeam-subprocessors/666339.

B. OBJECTIONS TO CHANGES IN THE SUB-PROCESSOR LIST

CUSTOMER shall subscribe to receive notifications of changes to the sub-processor list at https://community.exabeam.com/s/subprocessors. CUSTOMER shall have the opportunity to object as set forth in Section 7.3 of this Policy.

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