Last Updated: March 31st, 2025.
These terms and conditions (the “Terms of Use”) are entered into by and between the User (as defined below) and THENOTCOMPANY, INC., a Delaware corporation (“NotCo” or “we”). The Terms of Use govern the access to and/or use by the User of all websites controlled by NotCo (including any content, functionality, and services offered on or through such websites) where these Terms of Use are posted (the “Sites”), whether as a guest or a registered user.
From the time users access the Sites, they are subject to the following terms and conditions. By using the Sites, the User accepts and agrees, from that very moment, to be,fully and without any reservation, bound and to abide by these Terms of Use and our Privacy Policy, found at https://tech.notco.com/, incorporated herein by reference. Anyone who does not accept these Terms of Use must refrain from accessing or using the Sites, either directly or indirectly, and from using any information or service provided by the Sites.
The Sites are offered and available to Users who are 18 years of age or older only. By using the Sites, the User represents and warrants that he or she is 18 years or older and otherwise of legal age to form a binding contract with NotCo. If the User does not meet the age requirement, the User must not use or access the Sites.
Definitions. For the purpose of this Terms of Use, the following terms shall have the meaning set forth in this section.
“Related Party” means any affiliates, entities which control NotCo and/or subsidiaries of NotCo, as well as NotCo’s licensors, and service providers (e.g., those third parties that perform certain services for us, such as website hosting, order fulfillment, delivery of our promotional materials and product officers, clearing and processing credit and debit card payments, or performing other services on our behalf), and each of its and their respective officers,directors, employees, contractors, agents, licensors, suppliers, successors,and assigns.
“Third Party Websites” means other websites or locations that are operated and controlled by third parties other than NotCo or its Related Parties.
“User” or “you”means any person or persons that access and/or use the Sites.
Ownership and Operation. The Sites and their entire contents, features, and functionality (including but not limited to all information, software, text, displays, images, video, and audio, and the design, selection, and arrangement thereof) are owned by NotCo, its licensors, or other providers of such material and are protected by United States or international copyright, trademark, patent, trade secret, and other intellectual property or proprietary rights laws.
For more information on NotCo and our product brands, please visit, https://tech.notco.com/.
The User agrees and acknowledges that the Sites are available for his/her personal and non-commercial use only and that the User has no right to use the Sites except as provided in these Terms of Use. The Site and its associated applications contain material prepared by NotCo, through newsletters or in any other form, for informational purposes only. Users should be aware that such material may not reflect the most recent legislative or case law developments regarding the matters discussed. NotCo also reserves the right to modify, expand, or reduce the material offered through the Site and its associated applications at any time, notifying Users accordingly.
The material contained on the Site and its associated applications may under no circumstances be considered a substitute for legal or other professional advice. Access to this material does not intend to create, nor does it imply, any attorney-client relationship or any other type of fiduciary or professional relationship between NotCo and the User of the Site and its associated applications. Therefore, Users should not act on the basis of the information contained therein without first seeking appropriate professional advice. Likewise, Users should not send any confidential information to NotCo without first consulting with one of our attorneys and receiving authorization to submit such information. Otherwise, the information provided will be deemed public due to its disclosure without confidentiality safeguards or provisions.
In this regard, and without prejudice to the preceding paragraphs, NotCo grants Users a non-exclusive, non-sublicensable, and non-transferable license to use the Site and its associated applications and their respective features, content, and other available functionalities. This use is subject to the remaining terms included in these Terms of Use, as well as any other applicable terms of use and governing regulations.
NotCo will not be liable for any loss or damage any Users suffer in connection with any use of the Sites for commercial or other purposes not authorized under these Terms of Use. NotCo may deny or terminate any User’s access to or use of the Sites. The provision of the Sites is free of charge and thus NotCo has no maintenance or support service obligation and is not liable for any loss or damage that any User may suffer as a result of a failure to maintain or update the Sites.
The acceptance of these conditions constitutes the granting of a revocable, non-transferable and non-exclusive license to view, print and distribute the content of the Sites for personal and non-commercial purposes provided that the User does not remove or obscure the copyright notice or any other notice contained in the content of the Sites.
Additionally, the User agrees to not:
Acceptance of these Terms of Use. Your access to or use of the Sites, directly or indirectly,and/or download of information from the Sites constitute your acceptance of theTerms of Use in whole. The User’s use of the Sites and any applications,software, data, products, contests, promotions, sweepstakes and other services provided to the User by NotCo on or through the Sites (the “Services”), shall be subject at all times to these Terms of Use.
Changes to the Sites. NotCo reserves the right to update, modify or remove, in part or in whole, with or without notice, any content or information posted on the Sites as it sees fit. This right applies to any content referring to availability or stock of products or services, specifications, price, or regarding the configuration and functionalities of the Sites or information on promotional activities. Likewise, NotCo may unilaterally modify, without prior notice, whenever it considers it appropriate, the structure and design of the Sites, as well as modify or eliminate the services, contents and conditions of access and/or use of the Sites.
Notwithstanding anything to the contrary above, the Sites’ content is not necessarily complete or up-to-date. Any of the material on the Sites may be out of date at any given time, and NotCo is under no obligation to update such material.
Eligibility and Access. The access to and use of the Sites by persons under the age of 18 shall be the responsibility of their respective parents or legal guardians. Such parents and legal guardians shall be responsible hereunder and under any applicable law for any consequences of the access and/or use of the Sites by the persons under the age of 18 under their respective parenting or guardianship.
NotCo may limit the access to certain parts of the Sites and/or specific Services to users aged 18 and over. In said case, NotCo shall clearly identify those parts of the Sites or those Services where access is limited together with the applicable terms of use. Notwithstanding the foregoing, NotCo may deny access to the Sites and/or the Services without prior notice to users who breach these Terms of Use or the particular terms and conditions applicable to them.
From time to time, NotCo may also restrict access to some parts of the Sites, or the entire Sites, to any Users in general, including registered Users. You are solely responsible for both making all arrangements necessary for you to have access to the Sites and ensuring that all persons who access the Sites through your internet connection are aware of these Terms of Use and comply with them.
Registration. To have access to certain functionalities of the Sites, the user may be asked to make a specific registration. In these cases, or if the user wishes to register, even if such registration is not mandatory, the user must complete their personal information in the corresponding fields. Personal information includes, by way of example, but not limited to, full name, identity document, date of birth, and contact information (phone number, home address, and email address).
When registering on the Sites, it is important that the user provides accurate, complete and updated information and agrees to update such information, as appropriate, to keep it as accurate as possible. The user must enter an email and create a personal and non-transferable password to log into the Sites. The username, password, and other pieces of information given to you as part of NotCo’s security procedures are confidential, and the user must take the necessary precautions and measures to avoid misuse by third parties; you must not disclose such information to any other person or entity, and you also acknowledge that your account is personal to you and agree not to provide any other person with access to the Sites or portions thereof using your username, password, or other security information. NotCo has the right to disable any username, password, or other identifier, whether chosen by you or provided by NotCo, at any time in NotCo’s sole discretion for any or no reason, including if, in NotCo’s opinion, you have violated any provision of these Terms of Use.
The user is solely responsible for the access and activities carried out on the Sites and must immediately inform NotCo in case of misuse or unauthorized access and use by third parties. In case of loss or theft of the access password, the user must immediately request the change of the password on the Sites. If said request is not possible for any reason, the user must contact NotCo, subject to remain responsible for all actions on the Sites made through the registration of said user.
The user’s registration on the Sites must contain only true information. Each user is responsible for acting with caution and discernment, being responsible for all activities carried out through the Sites.
Contact. If the User wishes to contact us through the Sites, NotCo will ask for the reason for such contact, personal information such as first and last name, e-mail address and country, as well as the drafting of a message explaining the reasons for the contact. As part of the contact process, NotCo may request a username and password. The User agrees to provide accurate and complete information when contacting and using the Sites and Services. The User authorizes NotCo to store and use his or her information for the purposes set forth in these Terms of Use in order to respond to the User’s requests when accessing the Sites.
Privacy. You agree that all information and data we collect on the Sites, including without limitation all information and data you provide to NotCo through our Sites(including without limitation through registration with the Sites) are subject to our Privacy Policy, available at https://tech.notco.com/. By using the Sites, you consent to all actions we take with respect to your information in compliance with the Privacy Policy.
Ownership and Use of the Sites’ Materials, Products and Services. NotCo owns the intellectual property rights for all of the materials on the Sites. NotCo also owns or has a valid right to use all trademarks, service marks, graphics and logos used on the Sites. Unless expressly stated, no part of the Sites may be copied,reproduced, republished, uploaded, posted, transmitted, or distributed in anyway, except that you may download one copy of the materials on any single computer for your personal, non-commercial use, provided you keep intact all copyright, trademark, and other proprietary notices on the materials. Any use,reproduction, republication, upload, posting, transmission, modification of the materials or use of the materials for any other purpose is a violation ofNotCo’s intellectual property rights and proprietary rights as well as theseTerms of Use. The use of any such material(s) on any other website or computer network without NotCo’s written consent is strictly prohibited. Your use of the trademarks, service marks, graphics and logos on the Sites in any manner other than as authorized in these Terms of Use, or as authorized in writing by NotCo,is strictly prohibited.
If you download software or other digital content, including apps, from the Sites (“Products”),the Products, and all files, images and data relating thereto, will be considered as licensed unexclusively to you by NotCo for personal,non-commercial use only and at all times subject to these Terms of Use andNotCo’s other rights, interests, and titles therein and thereto. The User agrees and acknowledges that it does not and will not own the downloaded Products and that NotCo does not transfer any ownership of the Products to you.NotCo retains full ownership of and title to the downloaded Products and all intellectual property rights related thereto. You may not redistribute, sell,decompile, reverse engineer, or disassemble the Products or otherwise reduce the Products to a human-readable form.
Consent. The User grants to NotCo all consents required under any applicable law, including without limitation pursuant to Law N° 19,628 on the Protection of Personal Data and any applicable U.S. federal or state laws, that may be required for NotCo or any of its Related Parties to process the Personal Information (as defined in the Privacy Policy) in accordance with these Terms of Use and our PrivacyPolicy, both available at https://tech.notco.com/.
Geographic Scope of the Sites. NotCo controls and operates the Sites from the United States of America. Unless otherwise specified on or by the Sites, the Sites are intended to promote only those NotCo products or services that are sold or provided by NotCo in the United States of America, and therefore NotCo makes no representation or warranty that materials and contents in the Sites or the products described thereby are appropriate or available for use in other locations. Access to the Sites may not be legal by certain persons or in certain countries. If you access the Sites from outside the United States of America, you do so on your own initiative and are solely responsible for compliance with local laws.
Linking to the Sites. You may link to our homepage, provided you do so in a way that is fair, legal and does not damage our reputation or take advantage of it, but you must not establish a link in such a way as to suggest any form of association,approval, or endorsement on our part without our express written consent. Subject to the foregoing, you must not:
You agree to cooperate with us in causing any unauthorized framing or linking immediately to stop. We reserve the right to withdraw linking permission without notice.
Third Party Links.The Sites may contain links to Third Party Websites. These links are provided solely for the Users’ convenience. This includes links contained in advertisements, including banner advertisements and sponsored links. No information, material or content of third parties contained in, referenced by,included in, or linked to or from the Sites does not imply endorsement of the products, services or information of the third parties. Any information, data, opinions, recommendations, products or services provided by these third parties, whether through links to other websites or directly through their websites, are solely those of the third parties and not of NotCo. We have no control over the contents of those sites or resources and accept no responsibility for them or for any loss or damage that may arise from your use of them. If you decide to access any Third Party Websites linked to on the Sites, you do so entirely at your own risk and subject to the terms of use and privacy policies of those websites.
Exclusion of Warranties regarding the Use and Functioning of the Sites and Links visible in it. The material available on the Sites is provided as is, as available and without conditions or warranties of any kind, either express or implied. To the fullest extent permitted by applicable law, User disclaims all conditions and warranties, express or implied, including, but not limited to, all implied warranties of merchantability, fitness for a particular purpose, title and non-infringement. NotCo makes no warranty that the Sites will meet your requirements, or that access to the Sites will be uninterrupted, timely, secure or error-free, or that defects, if any, will be corrected. NotCo does not warrant or make representations regarding the use or results of the use of the material on the Sites in terms of correctness, accuracy, reliability, or otherwise. The material on the Sites may include technical inaccuracies or typographical errors and may be inaccurate or become inaccurate as a result of developments after their respective dates. NotCo undertakes no obligation to verify or maintain the currency of such information.
Regarding the functioning of the Sites, NotCo makes no warranty that (i) the operation of the website will meet the User’s requirements; (ii) access to the Sites will be uninterrupted, timely, secure, free of viruses, worms, trojan horses or other harmful components, or free of defects or errors; (iii) the results that may be obtained from the use of the Sites will be accurate or reliable; or (iv) defects will be corrected. The User understands and agrees that any material and/or data downloaded or otherwise obtained through the Sites is used at your own risk and that you will be solely responsible for any damage to your computer system or loss of data that results from the download of such material and/or data. The foregoing does not affect any warranties that cannot be excluded or limited under applicable law.
NotCo is not responsible in any way for those contents, commercial activities, products and services included that could be viewed through electronic links (links),directly or indirectly, through the Sites, especially those that could correspond to value-added content for the User, such as leisure, entertainment, curiosities, advice or others. The presence of links on the Sites, unless expressly stated otherwise, is merely for information purposes and in no case implies a suggestion, invitation or recommendation about them. These links do not represent any type of relationship between NotCo and the individuals or companies that own the websites that can be accessed through these links. NotCo reserves the right to unilaterally remove the links that appear on the Sites at any time.
Limitation of Liability. SUBJECT TO APPLICABLE LAW, UNDER NO CIRCUMSTANCES SHALL NOTCO OR ANY OF ITS RELATED PARTIES, OR EACH OF ITS AND THEIR LICENSORS OR LICENSEES, BE LIABLE BEFORE THE USER OR ANY OTHER PERSON OR ENTITY FOR ANY DIRECT, INDIRECT, SPECIAL, INCIDENTAL, CONSEQUENTIAL, PUNITIVE OR OTHER DAMAGES, INCLUDING LOST PROFITS, PERSONAL INJURY (INCLUDING DEATH) AND PROPERTY DAMAGE, THAT MAY RESULT FROM (I) THE USE OF, OR THE INABILITY TO USE, THE SITES OR ANY MATERIAL ON THE SITES; (II) THE CONDUCT OF ANY OTHER USER OR THIRD PARTY OF THE SITES; (III) THE UNAUTHORIZED ACCESS TO OR AMENDMENT OF THE PERSONAL INFORMATION OF THE USER; (IV) AND ANY OTHER MATTER RELATED TO THE SITES. NOTCO SHALL NOT BE LIABLE EVEN IF NOTCO OR AN AUTHORIZED REPRESENTATIVE OF NOTCO HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. THESE INCLUDE BUT ARE NOT LIMITED TO DAMAGES OR INJURY CAUSED BY ERROR, OMISSION, INTERRUPTION, DEFECT, FAILURE OF PERFORMANCE, DELAY IN OPERATION OR TRANSMISSION, LINE FAILURE OR COMPUTER VIRUS, WORM, TROJAN HORSE OR OTHER HARMFUL COMPONENT. TO THE FULLEST EXTENT PROVIDED BY LAW, IN NO EVENT WILL THE COLLECTIVE LIABILITY OF NOTCO AND ITS RELATED PARTIES TO ANY PARTY (REGARDLESS OF THE FORM OF ACTION, WHETHER IN CONTRACT, TORT, OR OTHERWISE) EXCEED THE AMOUNT YOU HAVE PAID TO NOTCO FOR THE APPLICABLE PRODUCT OR SERVICE OUT OF WHICH LIABILITY AROSE.
The limitation of liability set out above does not apply to liability resulting from our gross negligence or willful misconduct or death or bodily injury caused by products you purchase through the Sites. In the event that applicable law may not allow the exclusion of certain warranties or the limitation or total exclusion of liability in which case the above limitation of liability shall be construed to the maximum extent permitted by law.
Indemnification. User hereby agrees to indemnify and hold NotCo and its Related Parties harmless from and against any and all claims, judgments, actions or proceedings of any kind and from any and all damages, awards, losses, fees, liabilities, costs and expenses, including reasonable legal fees, relating to or arising out of your use of the Sites, any use of the information and data you provide to us as permitted in these Terms of Use, and/or any breach or alleged breach of any of y
our warranties, representations or agreements hereunder.
Termination. The duration of the service of the Sites and of the services is indefinite.Notwithstanding the foregoing, NotCo may interrupt, suspend or terminate the provision of the service of the Sites or any of the services that comprise it at any time at NotCo’s sole discretion, with or without cause.
Changes to the Terms of Use. NotCo may, from time to time, change or revise these Terms of Use at its sole discretion by posting the latest version of these Terms of Use on the applicable Site(s) and indicating the date of application of such new version of the Terms of Use. The date of the “Last Update” set forth at the beginning of these Terms of Use shall indicate the effective date thereof. Your use of the Sites and your participation in the application process shall constitute your continuing agreement to the then-current Terms of Use.
Applicable Law and Jurisdiction. These Terms of Use, as well as the relation between User and NotCo, shall be governed by and construed in accordance with the laws of the State of New York, United States. Any legal suit, action, or proceeding arising out of, or related to, these Terms of Use or the Sites (“Claims”) raised by you shall be instituted exclusively in the courts located in the borough and city of New York, United States. NotCo may bring any Claims against you in your country of residence or any other relevant country. You waive any and all objections to the exercise of jurisdiction over you by such courts and to venue in such courts.
Severability. If any provision of these Terms of Use shall be found to be unlawful, void, or for any reason unenforceable, then that provision shall be deemed severable from theseTerms of Use and shall not affect the validity and enforceability of any remaining provisions.
Waiver. No waiver by us of any term or condition set out in these Terms of Use shall be deemed a further or continuing waiver of such term or condition or a waiver of any other term or condition herein. No failure on the part of NotCo to enforce any part of these Terms of Use shall constitute a waiver of any of NotCo’s rights under these Terms of Use whether for past or future actions on the part of any person. Only a written waiver signed by a legal representative of NotCo will have legal effect.
Entire Agreement. The Terms of Use, our Privacy Policy and our Terms of Sales constitute the sole and entire agreement between you and NotCo regarding the Sites and supersede all prior and contemporaneous understandings, agreements,representations, and warranties, both written and oral, regarding the Sites.
If you have any questions or wish to contact NotCo, you may write to whynot@thenotcompany.com
Last Updated: July 3, 2025
ACCEPTANCE OF TERMS By accessing or using the software provided by TheNotCompany, Inc., (“NotCo”) through its web platform, you (the “User”) agree to be bound by these Terms and Conditions of Use (“T&C”). If you do not agree to these T&C, you must not use the software.
These Terms and Conditions (“Terms”) govern the access and use of the Software, as defined below, by users registered on our website. By using the Software or purchasing or receiving usage Credits, as defined below, you agree to be bound by these Terms.
“Personal Data” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. Examples of Personal Data include, but are not limited to, name, email address, phone number, IP address, and unique identifiers including cookies and mobile ad identifiers. Where the only data at issue is fully aggregated, anonymized or otherwise de-identified such that it cannot reasonably identify, relate to, describe or be capable of being associated with, or be linked, directly or indirectly, to a particular individual, and appropriate steps are taken to ensure that such identification would not occur, it will not qualify as Personal Data.
Exhibit A - Security Annex
Definitions
“AI System” means a software-based system that can generate outputs such as predictions, recommendations, or decisions, based on input data, and may operate with varying levels of autonomy to assist or influence real or virtual environments.
“Industry Recognized Framework” means an information security framework or standard commonly accepted in the technology industry, such as ISO/IEC 27001, SOC 2 Type II, or the NIST Cybersecurity Framework. References to such frameworks in these Terms are for alignment purposes only and do not imply certification or formal compliance, unless expressly stated.
“Secure Area” means any physical location where User Content is stored or processed, and to which access is restricted by the infrastructure provider or by NotCo, including secure environments managed by third-party cloud providers such as Google Cloud Platform.
1. Organizational Controls
1.1. Purpose, Scope, and Evolution
1.1.1. NotCo implements and maintains reasonable administrative, technical, and physical safeguards designed to protect the confidentiality, integrity, and availability of User Content and the systems used to deliver the Software.
1.1.2. These security practices may evolve over time due to technological improvements or operational adjustments. Any such changes will not materially reduce the level of protection offered to User Content.
1.1.3. NotCo may update its security practices from time to time. General descriptions of the applicable security measures may be made available upon request, at NotCo’s sole discretion and subject to confidentiality considerations.
1.2. Information Security Program
NotCo maintains an internal information security program consisting of policies, procedures, and technical and organizational safeguards designed to protect its systems and the User Content processed through the Software (the “Security Program”).
This Security Program is informed by principles derived from industry-recognized frameworks such as ISO/IEC 27001, SOC 2, and the NIST Cybersecurity Framework, but NotCo does not represent or warrant formal certification or compliance unless expressly stated.
The Security Program is proportionate to the nature of the Software, the types of data processed, and NotCo’s operational context. NotCo may, at its discretion, share high-level information about its Security Program upon written request and subject to confidentiality considerations.
1.3. Access Controls, Identification and Authentication
NotCo implements access control procedures and authentication mechanisms designed to restrict access to production systems and protect User Content from unauthorized access. These include measures to ensure that only authorized personnel can access the environments where the Software operates.
Access rights are granted based on the principle of least privilege and are periodically reviewed. Privileged accounts may require additional authentication measures.
Authentication for users of the Software is handled via trusted third-party providers such as Auth0, using protocols like OAuth or OpenID Connect. NotCo does not implement customized single sign-on or multi-factor authentication unless separately agreed.
NotCo may implement additional security features—such as session timeouts or multi-factor authentication—where technically feasible and aligned with the nature of the Software. These features may be updated from time to time based on operational needs and evolving best practices.
1.4. Business Continuity Management Program
NotCo maintains internal business continuity and disaster recovery procedures intended to support the continued operation of the Software and restoration of service in the event of unexpected interruptions.
These procedures are designed to mitigate the risk of significant disruptions and may include infrastructure redundancy, backup mechanisms, and recovery protocols offered through third-party providers such as Google Cloud Platform.
NotCo may update or test these procedures periodically. While reasonable efforts are made to ensure continuity of service, NotCo does not guarantee uninterrupted access or full restoration of all functionalities in every scenario.
In the event of a disruption or data incident attributable to NotCo, NotCo will make reasonable efforts to restore access and recover affected data, in accordance with its internal recovery procedures. User acknowledges that NotCo is not responsible for data loss or errors caused by third-party services, infrastructure providers, or events beyond its reasonable control.
1.5. Information Security Incident Response
1.5.1. NotCo maintains internal incident response procedures designed to detect, contain, and mitigate potential security incidents that may affect the confidentiality, integrity, or availability of User Content or the Software. In the event of a confirmed security breach involving unauthorized access to User Content, NotCo will notify affected users as soon as reasonably practicable and in accordance with applicable laws. The notification may include general information on the nature of the incident and any remediation steps taken. NotCo will investigate such incidents using its internal resources and may engage third-party service providers if needed. Any remediation efforts will be implemented based on NotCo’s assessment of the incident and in line with its internal policies and operational capabilities. NotCo does not commit to specific reporting formats, forensic reports, legal analyses, or timelines, unless required by applicable law.
1.5.2. NotCo may periodically review and test its internal incident response procedures as part of its broader security program and in accordance with its operational needs. These activities are intended to help ensure the continued effectiveness of NotCo’s ability to detect and respond to security incidents. NotCo does not commit to any specific testing frequency, methodology, or reporting obligations under these Terms, but may disclose general information about its security testing practices upon reasonable request and subject to confidentiality considerations.
2. Technological Controls
2.1. Encryption and Data Protection
NotCo uses encryption protocols and industry-standard practices to help protect User Content from unauthorized access. Data in transit is encrypted using secure communication protocols such as HTTPS/TLS. Data at rest is encrypted in accordance with standards provided by NotCo’s infrastructure partners, including Google Cloud Platform.
2.2. Monitoring and Threat Detection
NotCo monitors its systems for unauthorized access, anomalous behavior, and other potential security threats using tools and services consistent with industry practices. These include intrusion detection mechanisms, access logging, and alerting systems.
2.3. Logical Separation
2.3. Logical SeparationUser Content is stored in logically segregated environments using cloud infrastructure configurations designed to prevent unauthorized access between users. NotCo does not implement virtual private cloud (VPC) segmentation or dedicated network isolation for this Software.
2.4. Logging and Audit Trails
NotCo maintains access logs and system logs to monitor and analyze platform activity. Logs are used for troubleshooting, security incident detection, and service monitoring purposes. Passwords and other sensitive credentials are excluded from logging.
2.5. Malware Protection
NotCo applies protective measures against malicious code using commercially reasonable antivirus and anti-malware tools, and cloud-based protection layers. Uploaded files may be scanned automatically for malicious behavior or known signatures.
2.6. Backup and Recovery
User Content is backed up as part of NotCo’s infrastructure provider configurations. Backup and recovery procedures are designed to allow restoration in case of service disruption, in accordance with NotCo’s operational practices and infrastructure capabilities.
2.7. Security Testing and Vulnerability Management
NotCo performs periodic internal security assessments and applies software updates and patches as necessary. Security issues are prioritized and addressed based on severity and risk. External penetration testing may be conducted from time to time, at NotCo’s discretion.
2.8. Security Assessments and Audits
Where Concept Quant incorporates AI-based components, NotCo implements internal safeguards aligned with recognized industry principles for AI system security. These include measures intended to ensure the confidentiality and availability of data processed through the system. NotCo does not guarantee adherence to any particular certification standard unless explicitly stated.
3. Physical Controls
3.1. Physical Security
The Software operates on cloud infrastructure provided by third-party service providers such as Google Cloud Platform. These providers are responsible for implementing physical security measures at the data centers where User Content is stored or processed.
Such physical security measures may include access restrictions, environmental controls, surveillance systems, and other protections designed to prevent unauthorized physical access to infrastructure and ensure data resilience.
NotCo does not operate physical data centers for the provision of this Software and relies on the physical security standards of its infrastructure providers, which are expected to comply with industry practices and applicable regulations.
3.2. Media Disposal
NotCo and its infrastructure providers implement data disposal procedures in accordance with industry standards to ensure that retired media containing User Content is securely deleted or destroyed.
4. People Controls
4.1. Awareness
NotCo ensures that its personnel involved in the operation and maintenance of the Software are aware of relevant internal policies and procedures, including those related to data security and privacy.
4.2. Training
NotCo provides periodic security awareness training to its personnel, covering topics such as information security, data protection, and business continuity, as appropriate to their role and responsibilities.
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