Know Your Customer Limited INFRASTRUCTURE & SECURITY OVERVIEW (IS) V1

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1 Know Your Customer Limited INFRASTRUCTURE & SECURITY OVERVIEW (IS) V1 Overview of KYC basic infrastructure, security and implementation, policies and practices. Know Your Customer Limited Tel /F, Wyndham Place40-44 Wyndham St., CentralHong Kong

2 Table of Contents Contents General 1 Definitions 2 Azure and KYC 3 KYC Infrastructure 4 Infrastructure details 5 Security 7 Monitor, Automation and Maintenance 9 Company Information 12

3 Pg. 01 General This Infrastructure and Security Overview for Know Your Customer Limited (this IS ) forms a part of your SaaS agreement (the Agreement ), entered into with Know Your Customer Limited. Capitalized terms used but not defined in this IS will have the meaning assigned to them in the Agreement. This IS applies to the Know Your Customer Online Services listed herein (a Service or the Services ), but does not apply to separately branded services made available with or connected to the Services or to any on-premises software that is part of any Service.

4 Pg. 02 Definitions "KYC" Know Your Customer Limited "IaaS" an instant computing infrastructure, provisioned and managed over the Internet. "Azure" Microsoft's public cloud computing platform, KYC elected IaaS "API" application programming interface, or a set of clearly defined methods of communication between various software. "Incident" an circumstance which causes or may cause a Downtime. "Service Level" means the performance metric(s) set forth in this SLA that KYC agrees to meet in the delivery of the Services. "Service Resource" means an individual resource available for use within a Service. "Success Code" means an indication that an operation has succeeded, such as an HTTP status code in the 2xx range. "Support Window" refers to the period of time during which a Service feature or compatibility with a separate product or service is supported. "Customer" as defined in the SaaS Agreement.

5 Pg. 03 Azure and KYC KYC uses Azure for its IaaS architecture Azure hosts the infrastructure components traditionally present in an on-premises data center, including servers, storage and networking hardware, as well as the virtualization or hypervisor layer for all KYC operations. Azure also supplies a range of services to accompany those infrastructure components. Such as detailed billing, monitoring, log access, security, load balancing and clustering, as well as storage resiliency, such as backup, replication and recovery. These services are increasingly policy-driven, enabling us to implement greater levels of automation and orchestration for important infrastructure tasks. Azure is therefore used for all our operations mainly: Test and development. Our Teams can quickly set up and dismantle test and development environments, bringing new applications to production faster. Azure makes it quick and economical to scale up dev-test environments up and down. Website and App hosting. Running websites using IaaS can be less expensive than traditional web hosting. Storage, backup, and recovery. KYC leverages Azure by avoiding the capital outlay for storage and complexity of storage management, managing data and meeting legal and compliance requirements. Azure is also useful for handling unpredictable demand and steadily growing storage needs. It can also simplify planning and management of backup and recovery systems. Web apps. Azure provides all the infrastructure to support all our web apps, including storage, web and application servers, and networking resources. We re able to quickly deploy web apps on IaaS and easily scale infrastructure up and down when demand for the apps is unpredictable.

6 Pg. 04 KYC Infrastructure A Single customer deployment is composed of an Integrated solution made available upon customer demand, that is composed of the following items: - VCD (Virtual Compliance Desktop) - VCD Upload Portal - Integrated KYC API V2-3rd Party Integration Data Aggregator Service (For real time Company data information retrieval) - Identity Verification Checker (For Individual ID Verification) - AML Updater (twice a day data refresh) - Mobile App Integration This infrastructure is deployed OnDemand and made available to a customer for testing, demonstration purposes before deploying in production.

7 Pg. 05 Infrastructure details Auditing KYC systems are backed up and certified by Azure SOC 1, 2 and 3. Reports of audits can be provided for legal and regulatory requirements. For specific Audits, 3 types of logs can be provided: - Control/Management Logs - Data plane Logs - Processed Events Data Protection KYC rely on ISO/IEC 27001:2013 Information Security Management Standards for its Data. GDPR Compliance plan is underway and we expect to have completed and available to all our customers in the 4Q Code and Processes Certifications KYC is Underdoing implementation of CMMI (SCAMPI A Assessment) Resilience Applications, Services and APIs have auto scaling in place to scale by CPU, Service Bus and Insights. Currently auto scale is set to up to 10 instances of the original customer implementation, with a 5min cooldown. Databases aside from auto scaling have elastic pools for provisioning proper resource allocation for peaks. All these values and configurations can be optimized to customer needs.

8 Pg. 06 Code base KYC uses best practices git repository for all code base with audited access. Code repository is periodically backed up and replicated for failsafe purposes. Geographical Scalability KYC can be setup in different geographic locations. It s in the final process of Localization / Globalization to have User Interface available aside from English, in different Language. Disaster Recovery Plan Business continuity and disaster recovery (BCDR) is setup for all KYC Services using Azure Recovery Services, a specific Plan can be provided upon SaaS agreement Used Open Source in all Applications Software License Html Agility Pack (HAP) MIT PhantmomJS BSD Newtonsoft.Json MIT Log4Net Apache 2 OpenPop CC0 1.0

9 Pg. 07 Security Identity and Authentication VCD Web App Each customer has a set of parametrized groups they can assign users to. Each group as a set of configurable Permission in the application. User registration and authentication as well as password recovery is an automated encrypted process, with no human intervention. The Authentication and identity processes is done using standard OWIN Authentication. API through a pair of REST Access Tokens, for both developer and customer according to standard OpenID Mobile App Access is done through a real time generated access code. Sub Systems Client Certificates with OpenID when required. Azure Layers Native Azure Active Directory Access Transport (TLS / SSL) All Interactions between KYC subsystems, clients and partners uses SSL for communication security in all environments the systems operate. Data at Rest Storage Systems use Azure Storage Service Encryption (SSE) for Data at rest. As an additional layer of security on last quarter of 2017, AES encryption for images and customer documents will be put in place for data at rest in storage systems. Data Backups can be provided on demand from Azure Instances.

10 Pg. 08 Certifications KYC Systems as part of the Azure follows CSA STAR Certification in all 3 Levels. As part of this penetration reports can be supplied under the US Federal Risk and Authorization Management Program (FedRAMP)

11 Pg. 09 Monitor, Automation and Maintenance KYC Systems are in constant monitoring. We use several techniques and technologies to monitor not only our infrastructure but also the performance of the entire system. Azure Application Insights are used to monitor health of all Applications and Services. Splunk as well as Azure is used to Monitor Infrastructure Availability Splunk is used to monitor specific services availability like, Jurisdiction data accessibility, and SMS delivery. Specific Application Telemetry is used in Splunk to monitor Systems Exceptions. Triggers are put in place to Alert and Monitor in real time both KYC Staff and Customers when needed. Internal Realtime JIRA Monitoring System The System produces Realtime reports, exceptions and incidents to be resolved and fixed by the Team as tasks in Atlassian JIRA Systems. Production Incidents are automatically generated and prioritized in 3 Levels for immediate resolution as: System Unavailability Maximum SysOps/Dev Response Time 2hr Examples / Use Cases Apps or services are unavailable User is unable to login Level 1 - Customer is unable to continue working further and is blocked Maximum SysOps/Dev Response Time 24hr Examples / Use Cases Customer Unable to Create a Case

12 Pg. 10 Customer is unable to get Reports Level 2 - Customer has Issue but there is a workaround Maximum SysOps/Dev Response Time 48hr Examples / Use Cases Customer unable to send SMS, but if using another Role he can User is unable to login with a given user, but if given another user he can. Maintenance, Updates & hotfixes Maintenance and releases are performed outside of business hours (Monday Friday, 9AM to 5PM GMT) on a business day. A business day means any day other than a Saturday, Sunday or public holiday in the United Kingdom and Republic of Ireland. Going forward, we are moving to a no-downtime implementation of our SDLC and Continuous Integration, which will allow us for a faster and improved availability. This is expected to be implemented within the next quarter. Notice of maintenance window is communicated through several mechanisms. In-Solution alerts and notifications will give further details to all users, and major updates will be accompanied by s. If a major update includes a change to the user workflow or new feature, a document detailing the function and how to use it will be sent at least three days prior to the feature release. In App Notifications & Monitoring Real-time in-solution updates and notifications will notify users of technical issues or third-party provider outages that may impact their work. They will also be notified when the outages have ceased or been repaired. Additionally, KYC provides a status page of the health of their systems in Subscription can be done for non-users of the KYC Systems to get automatic notified of systems availability.

13 Pg. 11 Major issues or outages that are expected to take longer than 3 hours to repair will be accompanied by an to the company s point of contact detailing the issue and the steps being taken to amend it. If one of our third-party providers is experiencing technical issues or outages, status will be updated in Additional SMS Notifications can be requested

14 Pg. 12 Company Information Know Your Customer Limited 6/F, Wyndham Place40-44 Wyndham St., Central Hong Kong Tel

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