Flatters (“Company” or “we”) is committed to provide transparency regarding the security measures which it has implemented in order to secure and protect Personal Data (as defined under applicable law, including the EU General Data Protection Regulation (Regulation 2016/679) (“GDPR”) and the California Consumer Privacy Act (CCPA) (collectively “Data Protection Regulation”), processed by it.

This information security policy (“Policy”) outlines the Company’s current security practices as of the “Last Updated” date indicated above.

As part of our Data Protection Regulation compliance process, we have implemented technical, organizational monitoring protections, and established an extensive information and cyber security program.

We take best efforts to ensure our employees and contractors comply with this Policy as well.

Physical Access Control
The Company ensures the protection of the physical access to the data servers which store the Personal Data processed by the Company and stores its data solely with third party hosting provider which have obligated to provide sufficient security measures. Company works with Amazon Web Services datacenter, as its main storage and web farm service providers, therefore if you need more information Company recommends that you review Amazon’s security policy available here. Further, entrance to Company’s offices is protected by electronic means. Alarm system, monitoring and protection is implemented outside the working hours.

System Control
Access protection for all Personal Data processing systems through user authentication. Access to Company’s database is highly restricted, the restrictions are through protections implemented therein in order to ensure that solely the appropriate prior approved personnel, can access the database. Safeguards related to remote access and wireless computing capabilities are implemented therein. The databases are protected and solely authorized personnel may access such database by using a designated password. Company’s personnel are assigned with a private password that allows strict access or use related to the extent such access or use is required. Company carries out regular and random security tests on the system. Further, Company’s systems include network firewalls and anti-malware software on desktops and laptops.

Data Access Control
There are restrictions in place in order to ensure that the access to the Personal Data is restricted to employees which have a requirement to access it, all in order to ensure that Personal Data shall not be accessed, modified, copied, used, transferred or deleted without specific authorization. The access to the Personal Data, as well as any action performed involving the use of the Personal Data requires a password and username, which is routinely changed, as well as blocked when applicable. Each employee is able to perform actions solely according to the permissions determined by the Company. Further, Company has ongoing review of which employees’ have authorizations, to assess whether access is still required. Company revokes access immediately upon termination of employment.

Organizational and Operational Security
The Company invests a multitude of efforts and resources in order to ensure compliance with the Company’s security practices, as well as provides employees training. The Company strives to raise awareness to the risk involved in the processing of Personal Data. In addition, the Company implemented applicable safeguards for its hardware and software, including firewalls and anti-virus software on applicable Company hardware and software, in order to protect against malicious software.

Transfer Control
All transfer of Personal Data is protected using applicable safeguards. Company’s database is protected by industry best standards.

Availability Control
The Company’s servers include an automated backup procedure.

Data Retention
Personal Data is deleted as soon as such data is no longer required in order for the Company to provide or operate its Services.

Job Control
All of Company’s personnel are required to execute an agreement which includes confidentiality provisions as well as applicable provisions binding them to comply with applicable data security practices.