At FileFree, we understand that you're entrusting us with sensitive financial data. This Security Policy outlines the comprehensive measures we take to protect your information and maintain the highest standards of security.

Infrastructure Security

Our application infrastructure is hosted on the Base44 platform, which provides enterprise-grade security managed by security professionals:

• Server Security: All production servers undergo automated vulnerability scanning and patching
• Database Protection: Encrypted databases with automated backups and replication
• Network Security: Firewalls, intrusion detection systems, and DDoS protection
• Infrastructure Updates: Operating systems and server software are kept current with security patches
• Uptime Monitoring: 24/7 system monitoring with automated alerts for anomalies
• Redundancy: Multi-region deployment ensures high availability and disaster recovery

Data Encryption

Your data is encrypted at every stage to prevent unauthorized access:

• In Transit: 256-bit SSL/TLS encryption for all data transmission between your device and our servers
• At Rest: AES-256 encryption for all stored data, including databases and file storage
• Bank Connections: OAuth 2.0 authentication with encrypted tokens (Plaid integration)
• Payment Data: PCI DSS compliant handling through Stripe (we never store credit card details)
• Backup Encryption: All backup files are encrypted before storage
• Key Management: Encryption keys are rotated regularly and stored securely

Application Security

Authentication & Authorization

• Secure Authentication: Industry-standard authentication protocols with secure session management
• Password Security: Passwords are hashed using bcrypt with individual salts (never stored in plain text)
• Multi-Factor Authentication: Available for added account protection
• Role-Based Access: User and admin roles with appropriate permission levels
• Session Timeout: Automatic logout after inactivity to prevent unauthorized access
• Account Lockout: Protection against brute-force attacks with rate limiting

Code Security

• Secure Development: Following OWASP Top 10 security best practices
• Input Validation: All user inputs are validated and sanitized to prevent injection attacks
• Dependency Management: Regular updates of third-party libraries to patch known vulnerabilities
• Security Headers: HTTP security headers (CSP, HSTS, X-Frame-Options) implemented
• API Security: Rate limiting, request validation, and secure API endpoints
• Error Handling: Secure error messages that don't expose system information

Vulnerability Management

We maintain a comprehensive vulnerability management program:

• Automated Scanning: Production infrastructure undergoes continuous vulnerability scanning
• Dependency Audits: Monthly reviews of all application dependencies (NPM packages) for known vulnerabilities
• Patch Management: Critical security patches are applied within 24 hours of release
• Security Updates: Regular updates to maintain current security standards
• Penetration Testing: Annual third-party security assessments
• Bug Bounty: Responsible disclosure program for security researchers

Patch Deployment Schedule

• Critical: Deployed within 24 hours
• High Priority: Deployed within 7 days
• Medium Priority: Deployed within 30 days
• Low Priority: Deployed during regular maintenance windows

Third-Party Security & Federal Compliance

All third-party services undergo rigorous vetting to ensure they meet or exceed federal security requirements:

Payment Processing (Stripe)

• PCI DSS Level 1 Certified: Highest level of payment card security certification
• SOC 1 Type II & SOC 2 Type II Certified: Annual audits verify security controls
• Zero Data Storage: Your credit card information never touches our servers - Stripe processes all payment data directly
• Federal Compliance: Compliant with all federal payment processing regulations including GLBA and FTC Safeguards Rule
• 3D Secure & Fraud Detection: Advanced fraud prevention using machine learning
• Data Residency: Payment data stored in secure US-based data centers

Bank Connections (Plaid)

• SOC 2 Type II Certified: Independently audited security controls
• GLBA Compliant: Full compliance with Gramm-Leach-Bliley Act for financial data protection
• Zero Credential Storage: Your bank login credentials are NEVER stored - authentication uses OAuth 2.0 tokens
• Read-Only Access: Cannot move money or modify accounts - transaction viewing only
• Bank-Level Encryption: 256-bit encryption for all data transmission
• Major Bank Trust: Trusted by JP Morgan Chase, Bank of America, Wells Fargo, and 11,000+ financial institutions
• Federal Reserve Certified: Plaid is a certified FedACH Participant

Cloud Infrastructure (Base44)

• SOC 2 Type II Certified: Annual independent security audits
• US-Based Data Centers: All data stored in secure, geographically redundant US facilities
• 24/7 Security Monitoring: Continuous threat detection and incident response
• Encryption: AES-256 encryption at rest, TLS 1.3 in transit
• DDoS Protection: Enterprise-grade protection against distributed denial of service attacks
• Automated Backups: Daily encrypted backups with 90-day retention
• Disaster Recovery: 4-hour Recovery Time Objective (RTO) with tested failover procedures

Vendor Management Program

• Annual Security Reviews: All vendors undergo comprehensive security assessments annually
• Data Processing Agreements: All vendors sign DPAs ensuring GDPR, CCPA, and GLBA compliance
• Vendor Monitoring: Continuous monitoring of third-party security incidents and compliance status
• Right to Audit: Contractual rights to audit vendor security practices
• Incident Notification: Vendors must notify us of security incidents within 24 hours
• Minimum Standards: All vendors must maintain SOC 2 or equivalent certification
• Data Prohibition: Vendors contractually prohibited from selling, sharing, or using customer data for their own purposes

CRITICAL: What We Never Store

Access Controls & Data Segregation

User Data Access Restrictions

Internal Data Access Management

• Principle of Least Privilege: Staff access is limited strictly to what's necessary for their specific role - most employees have zero access to user data
• Support Access Only: Customer data is only accessible by support staff when explicitly requested by the account holder for troubleshooting
• Admin Separation: Administrative functions require multi-factor authentication and elevated credentials
• Access Logging & Auditing: Every data access is logged with timestamp, user, purpose, and IP address - logs are immutable and retained for 7 years
• Quarterly Access Reviews: All access permissions reviewed and verified quarterly with automatic revocation of unused privileges
• Immediate Offboarding: Access is revoked within 1 hour when team members leave or change roles
• No Production Access: Developers do not have access to production user data - all development uses anonymized test data

Employee Security

• Background Checks: All employees undergo security screening
• Security Training: Mandatory annual security awareness training
• Device Security: Company devices require encryption, antivirus, and OS updates
• NDAs & Agreements: All team members sign confidentiality agreements
• Remote Work Security: VPN requirements and secure remote access protocols

Incident Response

We maintain a comprehensive incident response plan to quickly address security events:

• 24/7 Monitoring: Continuous security monitoring and alerting
• Incident Response Team: Dedicated team trained to handle security incidents
• Response Time: Critical incidents acknowledged within 1 hour
• Communication: Affected users notified within 72 hours as required by law
• Forensics: Detailed investigation and root cause analysis for all incidents
• Post-Mortem: Lessons learned documented and security measures improved
• Recovery Plan: Tested backup and recovery procedures to minimize downtime

Reporting Security Issues

If you discover a security vulnerability, please report it responsibly:

Business Continuity

• Automated Backups: Daily encrypted backups with 90-day retention
• Disaster Recovery: Tested recovery procedures with 4-hour RTO (Recovery Time Objective)
• High Availability: 99.9% uptime SLA with redundant systems
• Geographic Redundancy: Multi-region data replication
• Failover Testing: Quarterly disaster recovery drills
• Communication Plan: Status page and email notifications for service disruptions

Federal & Regulatory Compliance

FileFree maintains strict compliance with U.S. federal regulations and industry standards:

Federal Financial Regulations

• Gramm-Leach-Bliley Act (GLBA): Full compliance with federal requirements for protecting consumer financial information. We maintain comprehensive written information security programs with administrative, technical, and physical safeguards.
• SEC Regulations: Compliance with Securities and Exchange Commission requirements for electronic record-keeping, audit trails, and data integrity (17 CFR § 240.17a-4 for broker-dealers, if applicable).
• Sarbanes-Oxley Act (SOX): Adherence to financial data integrity requirements, including tamper-proof audit trails and data retention policies.
• IRS Publication 1075: Compliance with federal tax information security guidelines, including 7-year retention of financial records as required by IRS regulations.
• Electronic Fund Transfer Act (EFTA): Compliance with Regulation E for electronic transactions and consumer protection.
• Bank Secrecy Act (BSA): Adherence to anti-money laundering (AML) record-keeping requirements where applicable.
• FINRA Rules: Compliance with Financial Industry Regulatory Authority data protection and record-keeping standards (if applicable to broker-dealer activities).

Federal Trade Commission (FTC) Standards

• FTC Safeguards Rule: Full adherence to updated 2023 Safeguards Rule requirements for financial institutions, including:
• Designated security personnel and information security program oversight
• Risk assessments and comprehensive security controls
• Multi-factor authentication for all accounts
• Encryption of customer information at rest and in transit
• Secure development practices and regular penetration testing
• Incident response planning and breach notification procedures
• FTC Privacy Rule: Compliance with privacy notice requirements and opt-out mechanisms

Data Privacy & Security Certifications

• GDPR: General Data Protection Regulation (EU) compliance for international users
• CCPA/CPRA: California Consumer Privacy Act and California Privacy Rights Act compliance
• SOC 2 Type II: Infrastructure hosted on SOC 2 Type II certified platform with annual audits
• PCI DSS Level 1: Payment Card Industry Data Security Standard compliance through Stripe (highest certification level)
• COPPA: Children's Online Privacy Protection Act compliance (18+ age requirement strictly enforced)
• HIPAA-Ready: While not a healthcare application, infrastructure supports HIPAA-compliant data handling if needed

State-Level Compliance

• Compliance with all 50 states' data breach notification laws
• New York DFS Cybersecurity Requirements (23 NYCRR 500) for financial services
• Massachusetts Standards for the Protection of Personal Information (201 CMR 17.00)
• State-specific financial privacy regulations and consumer protection laws

Security Audits & Reviews

We maintain rigorous security review processes:

• Annual Policy Review: All security policies reviewed and updated each January
• Monthly Dependency Audits: Review of all code dependencies for vulnerabilities
• Quarterly Access Reviews: Verification of user permissions and access rights
• Annual Penetration Testing: Third-party security assessment by certified professionals
• Continuous Monitoring: 24/7 automated security monitoring and alerting
• Security Metrics: Regular reporting on security posture and incident statistics

User Security Best Practices

While we implement strong security measures, we recommend users follow these best practices:

• Strong Passwords: Use unique, complex passwords for your FileFree account
• Enable MFA: Add multi-factor authentication for extra protection
• Secure Devices: Keep your devices updated with the latest security patches
• Public Wi-Fi: Avoid accessing financial data on unsecured networks
• Phishing Awareness: We will never ask for your password via email
• Regular Reviews: Monitor your account regularly for unauthorized activity
• Logout: Always log out when using shared or public computers

Security Roadmap

We continuously improve our security posture. Upcoming enhancements include:

• Enhanced anomaly detection with machine learning
• Advanced threat intelligence integration
• Additional SOC 2 audit completion
• Enhanced audit logging and retention
• Biometric authentication options

Policy Updates

This Security Policy is reviewed annually (each January) and updated as needed to reflect changes in our security practices or regulatory requirements. Significant changes will be communicated via email and through the application. The "Last Updated" date at the top indicates when changes were made.

Contact Security Team

For security questions, vulnerability reports, or security-related support: