Stairwell Vulnerability Disclosure Policy

Document Owner: Head of Compliance

Effective Date: December 1, 2022

1. Purpose
Stairwell, Inc. (“Stairwell,” “we,” or “us”) is committed to ensuring the security of our customers’ data. This policy is intended to give security researchers clear guidance for conducting authorized vulnerability discovery activities and to convey our preferences in how to submit discovered vulnerabilities to us.

This policy describes what systems and types of research are covered under this policy, how to send us vulnerability reports, and how long we ask security researchers to wait before publicly disclosing vulnerabilities.

Stairwell encourages security researchers to contact us to report potential vulnerabilities in our systems.

2. Authorization
If you comply with this policy during your security research, we will consider your research to be authorized, we will work with you to understand and resolve the issue quickly, and Stairwell will not recommend or pursue legal action related to your research. Should legal action be initiated by a third party against you for activities that were conducted in accordance with this policy, we will make this authorization known. By undertaking security research within the scope of this policy, you agree to be bound by the terms of Stairwell’s Nondisclosure Agreement attached hereto as Exhibit A (“NDA”). Any security research conducted in violation of the NDA or this policy is not authorized by Stairwell and Stairwell reserves the right to initiate a lawsuit or law enforcement investigation against you for any such unauthorized activities.

3. Guidelines
Under this policy, “research” means activities in which you:

• Notify us as soon as possible after you discover a real or potential security issue.
• Make every effort to avoid privacy violations, degradation of user experience, disruption to production systems, and destruction or manipulation of data. If, during your testing, you interact with or obtain access to Stairwell customer data or personal information of any person, you must stop testing immediately and cease any related activity, do not retain, copy, transfer, or disclose any such information, and alert Stairwell immediately and support our investigation and mitigation efforts.
• Only use exploits to the extent necessary to confirm a vulnerability’s presence. Do not, and do not allow any other person to, use an exploit to compromise, access, or exfiltrate data, establish persistent command line access, or use the exploit to pivot to other systems.
• Provide us a reasonable amount of time to resolve the issue before you disclose it publicly or to any third party.
• Do not submit a high volume of low-quality reports.
• By submitting your disclosure in accordance with this policy, you agree that Stairwell may take all steps needed to validate, mitigate, and disclose the vulnerability, and that you grant Stairwell any and all rights to your disclosure needed to do so.

Once you’ve established that a vulnerability exists or encounter any sensitive data (including personally identifiable information, financial information, or proprietary information or trade secrets of any party), you must stop your test, notify us immediately, and not disclose this data to anyone else.

4. Test Methods and Eligibility
The following test methods are not authorized:

• Network denial of service (DoS or DDoS) tests or other tests that impair access to or damage a system or data.
• Physical testing (e.g. office access, open doors, tailgating), social engineering (e.g. phishing, vishing), or any other non-technical vulnerability testing.

The following criteria must be met in order to be eligible to participate in security research under this policy:

• You must conduct any research or reporting in your individual capacity and not on behalf of your employer.
• You must be at least 18 years of age.
• You must not be a resident of a U.S. Government embargoed country or on a U.S. Government list of sanctioned individuals.

5. Scope
This policy applies to the following systems and services:

• *.stairwell.com

Any service not expressly listed above, such as any connected services, are excluded from scope and are not authorized for testing. Additionally, vulnerabilities found in systems from our vendors fall outside of this policy’s scope and should be reported directly to the vendor according to their disclosure policy (if any). If you aren’t sure whether a system is in scope or not, contact us at [email protected].

Though we develop and maintain other internet-accessible systems or services, we only authorize active research and testing conducted on the systems and services covered by the scope of this document. If there is a particular system not in scope that you think merits testing, please contact us to discuss it first. We may increase the scope of this policy over time.

6. Bug Bounties
Stairwell will determine eligibility for any award and award amount in Stairwell’s sole discretion. The amount of the award will be based on the potential impact of the security vulnerability, adherence to the instructions in this Policy, and any other helpful information or suggestions included in the disclosure. Stairwell will only offer an award for the first eligible disclosure of a particular vulnerability. Past rewards do not guarantee the same or similar rewards in the future. Stairwell may agree to publicly recognize a security researcher at or after the time of public disclosure of the vulnerability.

7. Reporting a Vulnerability
We accept vulnerability reports via [email protected]. Reports may be submitted anonymously. If you share contact information, we will acknowledge receipt of your report within three (3) business days.

We do not support PGP-encrypted emails for vulnerability reports. For particularly sensitive information, use this TLS-encrypted form: https://forms.gle/m1ZnpqJKC1vdYYfc7.

By submitting a vulnerability, you acknowledge that you have no expectation of payment and that you expressly waive any future pay claims against Stairwell related to your submission.

7.1. What We Would Like to See from You
In order to help us triage and prioritize submissions, we recommend that your reports:

• Describe the location the vulnerability was discovered and the potential impact of exploitation.
• Offer a detailed description of the steps needed to reproduce the vulnerability (proof of concept scripts or screenshots are helpful).
• Be in English, if possible.

7.2. What You Can Expect from Us
When you choose to share your contact information with us, we commit to coordinating with you as openly and as quickly as possible.

• Within 3 business days, we will acknowledge that your report has been received.
• To the best of our ability, we will confirm the existence of the vulnerability to you and be as transparent as possible about what steps we are taking during the remediation process, including on issues or challenges that may delay resolution.
• We will maintain an open dialogue to discuss issues.

8. Responsible Disclosure
In order to protect our customers, Stairwell expressly prohibits posting or sharing any information about a potential vulnerability in any public setting until we have researched, responded to, and addressed the reported vulnerability, and informed customers if needed.

Also, we do not authorize you to post or share any data belonging to our customers. Addressing a valid reported vulnerability will take time, and the timeline will depend upon the severity of the vulnerability and the affected systems.

Stairwell reserves the right to pursue any remedy available to it under applicable laws if you make an unauthorized disclosure of any potential vulnerability or customer data. Failure to comply with the restrictions in this Section 8 will immediately disqualify any report from bounty award eligibility.

9. Updates and Questions
Stairwell may terminate or modify this policy at any time by removing this policy from its website or posting a new version. Questions regarding this policy may be sent to [email protected]. We also invite you to contact us with suggestions for improving this policy.