1. Technical safeguards
Encryption and transport
- TLS 1.2+ enforced for all public endpoints. TLS 1.0/1.1 disabled.
- HSTS preload with
max-age=31536000, includeSubDomains, preload. - Encryption at rest for customer databases (AES-256). Backups encrypted.
- Cloudflare in front of every public application — DDoS shield, WAF, edge encryption.
Network architecture
- Customer environments are physically separated (VLAN/VPC + firewall rules)
- VPN-only access (WireGuard / IPsec) to admin panels and SSH
- Public access only through a load balancer / reverse proxy
- No direct traffic from the internet to databases
System hardening
- Security patches — Oracle CPU (Critical Patch Update) quarterly, IBM Security Bulletin on an ongoing basis
- CIS Benchmarks alignment for Linux and WebSphere/WebLogic systems
- Vulnerability scans every 30 days (OpenVAS / tools dedicated per technology)
- Production hosts without unnecessary services, minimal install
2. Access management
Authentication & authorization
- MFA required for all administrative accounts (TOTP / hardware keys)
- Strong password policy: bcrypt / Argon2 hashing on the application side
- RBAC (Role-Based Access Control) — principle of least privilege at every level
- No shared accounts — every admin has individual credentials
Audit logs
- All administrative operations are logged (who, what, when, from which IP)
- Logs retained 90 days online + 12 months in cold-storage archive
- Tamper-evident — log integrity check (hash chain)
- Access to logs restricted to the "auditor" role
3. Compliance and standards
| Area | Standard | Status |
|---|---|---|
| Personal data protection | GDPR (EU 2016/679) | Compliant — see Privacy policy |
| Information security management | ISO/IEC 27001:2022 | Aligned (processes conform, no formal 3rd-party certification) |
| Web application security | OWASP Top 10 (2021) | Full mitigation — code review + WAF + dedicated tests |
| Payment security | PCI-DSS | Hosting in SAQ-A mode (e-commerce customers — redirect to a certified processor) |
| Data jurisdiction | Poland / EU | Full — data centre in Poland, no transfers outside the EEA |
Enterprise customers (T-Mobile, PZU, BASF, Samsung) are subject to additional contractual requirements. Individual SLAs, DPAs and security questionnaires are prepared on request.
4. Operational processes
24/7 monitoring
- Dedicated on-call engineer — a phone line, not a ticket in a queue
- Uptime monitoring (Uptime Kuma + dedicated probes on customer health endpoints)
- Alerting via SMS + email + Slack/Teams (the customer chooses the channel)
- Escalation: L1 (15 min) → L2 (30 min) → CEO (60 min)
Backup and recovery
- Daily backup with 30-day rolling retention + 12-month archive
- 3-2-1 rule: 3 copies, 2 media types, 1 off-site
- RTO < 15 minutes for enterprise production environments (with a 24/7 contract)
- RPO < 1 hour with continuous DB replication
- Restore test every quarter (drill exercise)
5. Security breaches
Procedure compliant with GDPR Art. 33–34:
| Phase | Time | Actions |
|---|---|---|
| Detection | < 15 min | SOC alert, resource isolation, preserve evidence |
| Triage | < 1 h | Severity classification (P1-P4), appoint incident commander |
| Containment | < 4 h | Limit impact, stop the attack vector |
| Notification — UODO | < 72 h | Report the breach to the President of the UODO (GDPR Art. 33) |
| Notification — customer | < 24 h | Notify the customer affected by the breach |
| Notification — individuals | Without undue delay | If high risk (GDPR Art. 34) |
| Resolution | RTO target | Restore the service, verify |
| Post-mortem | + 7 days | Root cause analysis, report, action items |
6. Audits and tests
- Penetration tests — annual, by an external firm specialising in web/API application security
- Vulnerability scans — every 30 days (OpenVAS, Nessus for enterprise customers)
- Code review — peer review for every change to production code
- Tabletop exercises — incident simulations every 6 months
- Compliance audits — internal quarterly, external on customer request
7. Responsible disclosure
If you discover a vulnerability in our infrastructure or services, do not disclose it publicly before reporting it to us. We work constructively with security researchers.
Contact
- Email: [email protected] — subject
[SECURITY] - Phone: +48 606 464 264 (for critical incidents — 24/7)
- PGP key fingerprint: on request
Scope
- In scope: FlexNet infrastructure (flexnet.pl, new.flexnet.pl, dev.flexnet.pl), applications we host, customer environments (after coordination with the customer)
- Out of scope: third-party services (Cloudflare, Google Fonts), social engineering of our staff, DoS / DDoS
Rules
- Do not exploit a vulnerability beyond a proof of concept
- Do not access customers' personal data or modify data
- Give us a reasonable time to fix (typically 90 days from the report)
- After the fix — we allow publication (with prior coordination around the CVE / description)
8. Contact
ul. Grzybowska 87 · 00-844 Warsaw
Email: [email protected] (subject:
[SECURITY])Phone: +48 606 464 264 (24/7 for incidents)
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