Incident Response & Breach Notification Policy

1. Purpose & Scope

ReelCiety is committed to maintaining the confidentiality, integrity, and availability of user data, systems, and infrastructure. This policy establishes a formal framework for responding to security incidents and complying with applicable breach notification obligations.

2. Definition of a Security Incident

A security incident includes any event that may compromise platform operations, data security, or user trust, including but not limited to:

• Unauthorized access to systems or accounts
• Data breaches or data leakage
• Malware, ransomware, or denial-of-service attacks
• Credential compromise or mass account abuse
• Insider threats or misuse of access privileges
• Infrastructure outages caused by malicious activity

3. Incident Detection & Reporting

ReelCiety employs automated monitoring, alerting systems, and manual reporting channels to identify potential incidents. Incidents may be detected through:

• Security monitoring tools and logs
• Anomaly detection and threat intelligence feeds
• User reports and third-party disclosures
• Internal audits or penetration testing

4. Incident Classification

Identified incidents are classified based on severity, scope, and potential impact:

• Low: Limited operational impact with no user data exposure
• Medium: Localized service disruption or attempted intrusion
• High: Confirmed breach or large-scale service degradation
• Critical: Widespread compromise, sensitive data exposure, or legal risk

5. Incident Response Team

ReelCiety maintains a cross-functional Incident Response Team (IRT), which may include:

• Security Operations (SecOps)
• Engineering and Infrastructure
• Legal and Compliance
• Privacy and Data Protection Officers
• Executive and Risk Management leadership

6. Containment & Mitigation

Upon confirmation of an incident, immediate containment actions may include:

• Isolating affected systems
• Revoking compromised credentials
• Blocking malicious traffic or accounts
• Disabling vulnerable features or endpoints
• Preserving forensic evidence

7. Investigation & Forensics

ReelCiety conducts structured investigations to determine:

• Root cause and attack vector
• Scope of affected systems or users
• Types of data involved
• Duration of exposure

Investigations may involve internal teams and trusted external experts.

8. Breach Notification Obligations

Where required by law, ReelCiety will notify affected users and regulators within legally mandated timeframes. Notification decisions consider:

• Applicable data protection laws (e.g., GDPR, CCPA)
• Nature and sensitivity of affected data
• Risk of harm to individuals
• Law enforcement or regulatory guidance

9. User Notifications

When user notification is required, communications may include:

• Description of the incident
• Types of data involved
• Steps taken to contain the incident
• Recommended actions for users
• Contact information for support

10. Regulatory & Authority Coordination

ReelCiety may coordinate with data protection authorities, regulators, and law enforcement agencies where required or appropriate.

11. Service Restoration

Systems and services are restored in a controlled manner after validation that vulnerabilities have been addressed and risks mitigated.

12. Post-Incident Review

After resolution, ReelCiety conducts a post-incident review to:

• Assess response effectiveness
• Identify process or control gaps
• Implement corrective actions
• Update policies and safeguards

13. Recordkeeping & Documentation

Incident records are maintained securely for audit, legal, and compliance purposes in accordance with data retention requirements.

14. Confidentiality

Details of incidents and investigations are treated as confidential and shared only with authorized personnel and entities.

15. Limitations of Liability

To the maximum extent permitted by law, Nexa-Group disclaims liability for damages arising from security incidents beyond its reasonable control, including sophisticated third-party attacks.

16. Policy Updates

This policy may be updated to reflect evolving threats, technologies, and legal requirements.

17. Contact

Security Operations: security@reelciety.com
Incident Escalation: emergency@reelciety.com
Legal & Compliance: legal@nexa-group.org