🧭 Privacy Program Management

1. Purpose

This document outlines Nemu Inc.’s privacy or data protection program, including roles, structures, and key activities.

2. Governance and Structure

• Privacy responsibilities are owned by the Security/Privacy Lead, with support from:
  • Engineering (for technical controls).
  • Operations/Support (for user-facing processes).
  • Leadership (for risk and resource decisions).

3. Key Program Elements

• Maintenance of privacy-related policies and notices.
• Integration of privacy considerations into product design.
• Vendor and Nth party management focusing on data protection commitments.
• Handling of data subject requests and privacy inquiries.

4. Policies and Procedures

The privacy program references:

• Data classification and handling policies.
• Incident management procedures, including privacy incidents.
• Contracting standards including DPAs and confidentiality clauses.

5. Monitoring and Improvement

• Periodic reviews of privacy risks and controls.
• Updates to policies in response to regulatory or business changes.
• Consideration of customer feedback and inquiries.

6. Audit Evidence

• Organizational role description for privacy responsibilities.
• Privacy-related policy documents.
• Records of privacy program or risk reviews.

7. Compliance Mapping

• SOC 2: P3.1, P4.1
• ISO 27001:2013: A.18.1

Contact: support@mynemu.com
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