Effective Date: August 12, 2025
Last Updated: August 12, 2025

1. Purpose and Scope

This Cyber Security Policy (hereinafter — the “Policy”) sets out the principles, responsibilities, and measures adopted by Jarteppa Consulting SL (NIF: B75510297, Address: Moll de Barcelona s/n, edifici Est, 1ª planta, Barcelona, Spain, 08039, trading as Usmon. International IT & Consulting Solutions) to protect the confidentiality, integrity, and availability of its information systems, digital products, and customer data.

This Policy applies to:

• All employees, contractors, partners, and service providers;
• All IT systems, websites, mobile applications, and cloud services operated by the Company;
• All personal and business data processed by the Company.

2. Objectives

The Company’s cybersecurity objectives are to:

1. Prevent unauthorized access to data and systems;
2. Detect, respond to, and recover from cybersecurity incidents;
3. Ensure compliance with applicable data protection and cybersecurity regulations;
4. Promote security awareness among all users and stakeholders.

3. Security Principles

The Company implements the following security principles:

• Confidentiality — ensuring that data is only accessible to authorized parties;
• Integrity — safeguarding the accuracy and completeness of data;
• Availability — ensuring that systems and data are accessible when needed;
• Accountability — documenting and monitoring all security-related activities.

4. Security Measures

We apply a combination of technical, organizational, and procedural measures, including but not limited to:

4.1. Technical Measures

• Use of TLS/SSL encryption for data in transit;
• Encryption of sensitive data at rest;
• Firewalls, intrusion detection/prevention systems;
• Multi-factor authentication (MFA) for system access;
• Regular software updates and patch management;
• Secure cloud infrastructure with redundancy and backup systems.

4.2. Organizational Measures

• Access control based on the principle of least privilege;
• Background checks for employees in sensitive positions;
• Security policies and procedures for all staff;
• Data classification and handling guidelines.

4.3. Monitoring and Detection

• Continuous system monitoring for suspicious activity;
• Automated alerts for potential security breaches;
• Regular vulnerability scanning and penetration testing.

5. User Responsibilities

All users (employees, contractors, partners, and customers) must:

• Use strong, unique passwords and change them regularly;
• Report suspicious activities or potential incidents immediately to security@usmon.com;
• Avoid sharing login credentials with unauthorized persons;
• Use only authorized devices and networks when accessing Company systems;
• Follow Company security guidelines when handling data.

6. Incident Response

The Company maintains a Cybersecurity Incident Response Plan, which includes:

1. Detection — identifying unusual or suspicious activities;
2. Containment — isolating affected systems to prevent further damage;
3. Eradication — removing malicious elements and vulnerabilities;
4. Recovery — restoring systems and data from backups;
5. Post-Incident Review — analyzing the incident and updating security measures.

7. Third-Party and Vendor Security

• All third-party service providers must comply with our security requirements;
• Contracts with vendors include cybersecurity and data protection clauses;
• Regular security assessments are conducted for critical partners.

8. Compliance

The Company’s cybersecurity practices comply with:

• ISO/IEC 27001 (Information Security Management Systems);
• NIST Cybersecurity Framework;
• GDPR and CCPA data protection requirements;
• Applicable Spanish and EU cybersecurity regulations.

9. Policy Review

This Policy is reviewed annually or upon significant changes in technology, threats, or regulatory requirements. Updates are published on our website.

10. Contact Information

For questions or reports regarding cybersecurity, please contact:

Jarteppa Consulting SL
NIF: B75510297
Moll de Barcelona s/n, edifici Est, 1ª planta, Barcelona, Spain, 08039
Phone: +34 655 304002
Email: security@usmon.com