Bramble Responsible Disclosure Policy

SOC 2 Criteria: CC2.2, CC5.3

ISO 27001 Annex A: A.7.2.1

Purpose

To allow for the reporting and disclosure of vulnerabilities discovered by external entities, and anonymous reporting of information security policy violations by internal entities.

Scope

Bramble’s Responsible Disclosure Policy covers applies to Bramble’s core platform and its information security infrastructure, and to internal and external employees or third parties.

Background

Bramble is committed to ensuring the safety and security of our customers. and employees. We aim to foster an environment of trust, and an open partnership with the security community, and we recognize the importance of vulnerability disclosures and whistleblowers in continuing to ensure safety and security for all of our customers, employees and company. We have developed this policy to both reflect our corporate values and to uphold our legal responsibility to good-faith security researchers that are providing us with their expertise and whistleblowers who add an extra layer of security to our infrastructure.

Roles and Responsibilities

Bramble’s Security Officer is responsible for updating, reviewing, and maintaining this policy.

Legal Posture

Bramble will not engage in legal action against individuals who submit vulnerability reports through our Vulnerability Reporting inbox. We openly accept reports for the currently listed Bramble products. We agree not to pursue legal action against individuals who:

• Engage in testing of systems/research without harming Bramble or its customers.
• Engage in vulnerability testing within the scope of our vulnerability disclosure program.
• Test on products without affecting customers, or receive permission/consent from customers before engaging in vulnerability testing against their devices/software, etc.
• Adhere to the laws of their location and the location of Bramble. For example, violating laws that would only result in a claim by Bramble (and not a criminal claim) may be acceptable as Bramble is authorizing the activity (reverse engineering or circumventing protective measures) to improve its system.
• Refrain from disclosing vulnerability details to the public before a mutually agreed-upon timeframe expires.

Policy

Vulnerability Report/Disclosure

Please follow the Reporting Vulnerabilities instructions for external researchers

Whistle Blowing

How to Submit a Report

To anonymously report an information security program violation or a violation of related laws and regulations, please utilize Wickr, and send a message to brmblanon.

Preference, Prioritization, and Acceptance Criteria

We will use the following criteria to prioritize and review submissions.

What we expect from you:

• Detailed report made in good faith or based on a reasonable belief.
  • Good Faith means the truthful reporting of a company-related violation of information security policies, procedures, or regulations, as opposed to a report made with reckless disregard or willful ignorance of facts.
  • Reasonable Belief refers to the subjective belief in the truth of the disclosure AND that any reasonable person in a similar situation would objectively believe based on the facts.
• Details of the violation (i.e., what, how, why).
• Details of the reported event, with facts (i.e., who, where, when).
• You are NOT responsible for investigating the alleged violation, or for determining fault or corrective measures.

What you can expect from Bramble:

• Your report will be submitted to the Security Team for review.
• Protection of your identity and confidentiality.
  • CAVEAT: It may be necessary for your identity to be disclosed when a thorough investigation, compliance with the law, or due process of accused members is required.
• Protection against any form of retaliation and harassment, such as termination, compensation decreases, or poor work assignments and threats of physical harm.
  • If you believe that you are being retaliated against, immediately contact .
  • Any retaliation or harassment against you will result in disciplinary action.
  • CAVEAT: Your right for protection against retaliation does not include immunity for any personal wrongdoing alleged in the report and investigated
• Due process for you and for the accused member(s).
• Corrective actions taken to resolve a verified violation and a review and enhancement of applicable policies and procedures, if necessary or appropriate.
• Continuous information security awareness training and understanding your rights as a whistleblower.