1. INTRODUCTION

Lead Partners, LLC ("Company," "we," "us," or "our") is committed to maintaining the highest standards of information security for our services, including Connect & Close CRM, Intelligent Attraction, Lead Hunter, Video Hunter, Deal Hunter, Campaign Runner, Call Runner, Quiz Runner, and related platforms (collectively, the "Services").

This Security Policy outlines our security practices, your responsibilities, and procedures for reporting security vulnerabilities.

2. OUR SECURITY COMMITMENT

2.1 Security Principles

Our security program is built on the following principles:

- Confidentiality: Protecting information from unauthorized disclosure

- Integrity: Ensuring information accuracy and preventing unauthorized modification

- Availability: Maintaining reliable access to services and data

- Accountability: Tracking and auditing all security-relevant activities

- Compliance: Meeting industry standards and regulatory requirements

2.2 Security Framework

We implement security controls based on:

- ISO 27001: International standard for information security management

- SOC 2 Type II: Service organization controls for security and availability

- NIST Cybersecurity Framework: Comprehensive cybersecurity guidelines

- Industry Best Practices: Mortgage and financial services security standards

3. TECHNICAL SECURITY MEASURES

3.1 Data Encryption

- Data in Transit: All data transmission uses TLS 1.2 or higher encryption

- Data at Rest: All stored data is encrypted using AES-256 encryption

- Database Encryption: Database-level encryption for sensitive information

- Backup Encryption: All backups are encrypted and securely stored

- Key Management: Secure key generation, rotation, and storage practices

3.2 Network Security

- Firewalls: Multi-layered firewall protection with intrusion detection

- Network Segmentation: Isolated network zones for different service components

- DDoS Protection: Distributed denial-of-service attack mitigation

- VPN Access: Secure remote access for authorized personnel

- Network Monitoring: 24/7 network traffic analysis and threat detection

3.3 Application Security

- Secure Development: Security-by-design development practices

- Code Reviews: Regular security code reviews and static analysis

- Vulnerability Testing: Regular penetration testing and security assessments

- Input Validation: Comprehensive input sanitization and validation

- Session Management: Secure session handling and timeout controls

3.4 Infrastructure Security

- Cloud Security: Enterprise-grade cloud infrastructure with security certifications

- Server Hardening: Secure server configurations and regular updates

- Patch Management: Timely security updates and vulnerability remediation

- Monitoring: Continuous security monitoring and incident detection

- Backup Systems: Secure, redundant backup and disaster recovery systems

4. ACCESS CONTROLS AND AUTHENTICATION

4.1 User Authentication

-Multi-Factor Authentication (MFA): Required for all administrative accounts

-Strong Password Requirements: Minimum complexity and length standards

-Account Lockout: Automatic lockout after failed login attempts

-Session Security: Secure session tokens and automatic timeout

-Single Sign-On (SSO): Enterprise SSO integration where applicable

4.2 Access Management

- Role-Based Access Control (RBAC): Granular permissions based on job functions

- Principle of Least Privilege: Minimum necessary access rights

- Regular Access Reviews: Periodic review and certification of user access

- Automated Provisioning: Secure account creation and deactivation processes

- Privileged Account Management: Enhanced controls for administrative accounts

4.3 Administrative Access

- Segregation of Duties: Separation of critical administrative functions

- Approval Workflows: Multi-person approval for sensitive operations

- Audit Logging: Comprehensive logging of all administrative activities

- Secure Channels: Encrypted and monitored administrative access

- Emergency Access: Secure break-glass procedures for emergencies

5. DATA PROTECTION AND PRIVACY

5.1 Data Classification

We classify data based on sensitivity levels:

- Public: Information intended for public disclosure

- Internal: Information for internal business use

- Confidential: Sensitive business information requiring protection

- Restricted: Highly sensitive information with strict access controls

5.2 Data Handling

- Data Minimization: Collecting only necessary information

- Purpose Limitation: Using data only for stated purposes

- Retention Policies: Secure deletion when data is no longer needed

- Data Masking: Anonymization for testing and development

- Cross-Border Transfers: Secure international data transfer procedures

5.3 Privacy Protection

- Privacy by Design: Building privacy into all systems and processes

- Consent Management: Proper consent collection and management

- Data Subject Rights: Procedures for handling privacy rights requests

- Breach Notification: Timely notification of privacy incidents

- Vendor Management: Privacy requirements for all third-party vendors

6. INCIDENT RESPONSE AND MANAGEMENT

6.1 Security Incident Response Team (SIRT)

Our dedicated team includes:

- Incident Commander: Overall incident coordination

- Technical Lead: Technical analysis and remediation

- Communications Lead: Internal and external communications

- Legal Counsel: Legal and regulatory guidance

- Executive Sponsor: Senior management oversight

6.2 Incident Response Process

1. Detection: Automated monitoring and manual reporting

2. Assessment: Initial triage and impact analysis

3. Containment: Immediate steps to limit damage

4. Investigation: Detailed forensic analysis

5. Eradication: Removal of threats and vulnerabilities

6. Recovery: Restoration of normal operations

7. Lessons Learned: Post-incident review and improvements

6.3 Communication Procedures

- Internal Notifications: Immediate notification of relevant stakeholders

- Customer Communications: Timely and transparent customer updates

- Regulatory Reporting: Compliance with breach notification requirements

- Public Disclosure: Coordinated public communications when necessary

- Documentation: Comprehensive incident documentation and reporting

7. BUSINESS CONTINUITY AND DISASTER RECOVERY

7.1 Business Continuity Planning

- Risk Assessment: Regular assessment of business continuity risks

- Continuity Plans: Detailed plans for maintaining critical operations

- Alternative Procedures: Backup processes for system outages

- Vendor Dependencies: Continuity planning for critical vendors

- Regular Testing: Periodic testing and updating of continuity plans

7.2 Disaster Recovery

- Recovery Objectives: Defined recovery time and point objectives

- Backup Systems: Geographically distributed backup infrastructure

- Data Recovery: Secure and tested data recovery procedures

- Failover Procedures: Automated and manual failover capabilities

- Recovery Testing: Regular disaster recovery testing and validation

7.3 Emergency Procedures

- Emergency Contacts: 24/7 emergency contact procedures

- Crisis Management: Coordinated response to major incidents

- Communication Plans: Emergency communication procedures

- Resource Allocation: Emergency resource mobilization

- Recovery Coordination: Coordinated recovery efforts

8. COMPLIANCE AND AUDITING

8.1 Regulatory Compliance

We maintain compliance with applicable regulations including:

- GLBA: Gramm-Leach-Bliley Act for financial services

- GDPR: General Data Protection Regulation for EU data

- CCPA: California Consumer Privacy Act for California residents

- SOX: Sarbanes-Oxley Act for financial reporting

- State Regulations: Applicable state privacy and security laws

8.2 Security Auditing

- Internal Audits: Regular internal security assessments

- External Audits: Independent third-party security audits

- Penetration Testing: Regular ethical hacking assessments

- Vulnerability Scanning: Continuous vulnerability identification

- Compliance Assessments: Regular compliance verification

8.3 Audit Logging

- Comprehensive Logging: Detailed logs of all security-relevant activities

- Log Protection: Secure storage and protection of audit logs

- Log Analysis: Regular analysis for security incidents and trends

- Retention Policies: Appropriate log retention periods

- Forensic Capabilities: Detailed forensic analysis capabilities

9. VENDOR AND THIRD-PARTY SECURITY

9.1 Vendor Security Requirements

All vendors must meet our security standards including:

- Security Assessments: Regular security evaluations

- Contractual Requirements: Security obligations in all contracts

- Compliance Verification: Verification of regulatory compliance

- Incident Notification: Requirements for security incident reporting

- Data Protection: Specific data protection and privacy requirements

9.2 Third-Party Risk Management

- Due Diligence: Comprehensive security due diligence for new vendors

- Ongoing Monitoring: Continuous monitoring of vendor security posture

- Risk Assessment: Regular assessment of third-party risks

- Contingency Planning: Backup plans for critical vendor dependencies

- Contract Management: Security requirements in all vendor contracts

10. EMPLOYEE SECURITY

10.1 Security Training

- Security Awareness: Regular security awareness training for all employees

- Role-Specific Training: Specialized training based on job responsibilities

- Phishing Simulation: Regular phishing awareness testing

- Incident Response Training: Training on security incident procedures

- Compliance Training: Training on regulatory and policy requirements

10.2 Background Checks

- Pre-Employment Screening: Background checks for all employees

- Ongoing Verification: Periodic re-verification for sensitive positions

- Contractor Screening: Background checks for contractors and vendors

- Access Approval: Security clearance for sensitive system access

- Termination Procedures: Secure employee termination processes

11. VULNERABILITY MANAGEMENT

11.1 Vulnerability Disclosure Program

We welcome responsible disclosure of security vulnerabilities:

Scope: Our vulnerability disclosure program covers:

- All Company-owned websites and applications

- Connect & Close CRM platform

- Intelligent Attraction services

- Lead Hunter, Video Hunter, Deal Hunter systems

- Campaign Runner, Call Runner, Quiz Runner tools

Reporting: To report a security vulnerability:

- Email: [email protected]

- Encryption: Use our PGP key for sensitive reports

- Response Time: We will acknowledge reports within 24 hours

- Investigation: We will investigate all valid reports promptly

11.2 Responsible Disclosure Guidelines

When reporting vulnerabilities, please:

- Provide Details: Include sufficient detail to reproduce the issue

- Avoid Harm: Do not access, modify, or delete data

- Respect Privacy: Do not access other users' accounts or data

- No Disruption: Do not disrupt our services or systems

- Confidentiality: Keep vulnerability details confidential until resolved

11.3 Vulnerability Response Process

1. Receipt: Acknowledge vulnerability report within 24 hours

2. Validation: Verify and assess the reported vulnerability

3. Prioritization: Assign priority based on risk and impact

4. Remediation: Develop and implement security fixes

5. Verification: Verify that the vulnerability has been resolved

6. Disclosure: Coordinate public disclosure if appropriate

7. Recognition: Acknowledge security researchers when appropriate

12. SECURITY CONTACT INFORMATION

12.1 Security Team

For security-related matters, contact:

Lead Partners, LLC Security Team

2557 Ashley Phosphate Rd

North Charleston, SC 29418

Intelligent Attraction System | More Leads, More Realtors®, More Closings

[email protected]

12.2 Emergency Security Contact

For urgent security matters requiring immediate attention: 24/7 Security Hotline: [Emergency Number]

Emergency Email: [email protected]

12.3 Vulnerability Reporting

Email: [email protected]

Encrypted Reporting: [Secure Reporting Portal]

Bug Bounty Program: [Program Details if applicable]

13. POLICY UPDATES

13.1 Review and Updates

This Security Policy is reviewed and updated:

- Annually: Comprehensive annual review

- As Needed: Updates based on threat landscape changes

- Regulatory Changes: Updates for new compliance requirements

- Incident-Driven: Updates based on security incidents or lessons learned

13.2 Notification of Changes

We will notify stakeholders of material changes through:

- Website Updates: Posted on our website with effective date

- Customer Notifications: Direct notification to customers for significant changes

- Employee Communications: Internal communications for policy updates

- Vendor Notifications: Updates to vendors regarding security requirements