CogniFit | Trust Center
CogniFit's Trust Center
CogniFit is a digital healthcare company focused on assessing and improving cognitive health. More than 4 million people use our digital products, which are available in 18 languages. Our core technologies assess more than 23 fundamental cognitive skills and provide an automatic understanding of the particular cognitive condition of each user, followed by a personalized brain training program. The CogniFit Assessment consists of a comprehensive battery of tasks. Each of these exercises was carefully selected and categorized to measure basic brain functions. The 23 cognitive abilities that CogniFit assesses and trains are carefully chosen to represent a complete image of human cognition. Each of these evaluated functions are based on hundreds of thousand of data and scores, compared with average demographic based on the evaluation of thousands of individuals. The improvement in cognitive abilities after a period of stimulation with CogniFit are validated by many independent studies. We continuously collaborate with investigators and the scientific community to ensure that the latest discoveries are integrated into the program in a serious and professional way.
Resources

Monitoring

Continuously monitored by Secureframe
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Resources

SOC2 Type II Letter of Attestation

SOC 2 Type II

Vulnerability Report

General Security Index

ISO 27001:2022 Index

GDPR Index

HIPAA Compliance Index

SOC 2 Compliance Index

CE Marking Index

Compliance

We have SOC 2 Type I + HIPAA compliance and SOC 2 Type II compliance. We are in process to achieve as well ISO27K. This covers most of items covered in California State Compliance (California Health and Safety Codes §§119400-119402).

Subprocessors

We run our infrastructure on Amazon Web Services Global Cloud Infrastructure, one of the most secure, extensive, and reliable cloud platforms. Our servers and databases are deployed in several Availability Zones in the US East (Northern Virginia) Region. This give us the ability to operate our services with high availability, fault tolerance and scalability.

Monitoring

Change Management

Secure Development Policy
A Secure Development Policy defines the requirements for secure software and system development and maintenance.
Change Management Policy
A Change Management Policy governs the documenting, tracking, testing, and approving of system, network, security, and infrastructure changes.
Configuration and Asset Management Policy
A Configuration and Asset Management Policy governs configurations for new sensitive systems
Production Data Use is Restricted
Production data is not used in the development and testing environments, unless required for debugging customer issues.
Segregation of Environments
Development, staging, and production environments are segregated.

Availability

Testing the Business Continuity and Disaster Recovery Plan
The Business Continuity and Disaster Recovery Plan is periodically tested via tabletop exercises or equivalents. When necessary, Management makes changes to the Business Continuity and Disaster Recovery Plan based on the test results.
Backup Restoration Testing
Backed-up data is restored to a non-production environment at least annually to validate the integrity of backups.
Business Continuity and Disaster Recovery Policy
Business Continuity and Disaster Recovery Policy governs required processes for restoring the service or supporting infrastructure after suffering a disaster or disruption.

Organizational Management

Information Security Policy
An Information Security Policy establishes the security requirements for maintaining the security, confidentiality, integrity, and availability of applications, systems, infrastructure, and data.
Internal Control Monitoring
A continuous monitoring solution monitors internal controls used in the achievement of service commitments and system requirements.
Disciplinary Action
Personnel who violate information security policies are subject to disciplinary action and such disciplinary action is clearly documented in one or more policies.
Organizational Chart
Management maintains a formal organizational chart to clearly identify positions of authority and the lines of communication, and publishes the organizational chart to internal personnel.
Information Security Program Review
Management is responsible for the design, implementation, and management of the organization’s security policies and procedures. The policies and procedures are reviewed by management at least annually.
Code of Conduct
A Code of Conduct outlines ethical expectations, behavior standards, and ramifications of noncompliance.
Background Checks
Background checks or their equivalent are performed before or promptly after a new hires start date, as permitted by local laws.
Performance Review Policy
A Performance Review Policy provides personnel context and transparency into their performance and career development processes.

Confidentiality

Data Classification Policy
A Data Classification Policy details the security and handling protocols for sensitive data.
Disposal of Customer Data
Upon customer request, Company requires that data that is no longer needed from databases and other file stores is removed in accordance with agreed-upon customer requirements.

Vulnerability Management

Third-Party Penetration Test
A 3rd party is engaged to conduct a network and application penetration test of the production environment at least annually. Critical and high-risk findings are tracked through resolution.

Incident Response

Incident Response Plan
An Incident Response Plan outlines the process of identifying, prioritizing, communicating, assigning and tracking confirmed incidents through to resolution.

Risk Assessment

Vendor Due Diligence Review
Vendor SOC 2 reports (or equivalent) are collected and reviewed on at least an annual basis.
Vendor Risk Management Policy
A Vendor Risk Management Policy defines a framework for the onboarding and management of the vendor relationship lifecycle.
Risk Register
A risk register is maintained, which records the risk mitigation strategies for identified risks, and the development or modification of controls consistent with the risk mitigation strategy.
Risk Assessment and Treatment Policy
A Risk Assessment and Treatment Policy governs the process for conducting risk assessments to account for threats, vulnerabilities, likelihood, and impact with respect to assets, team members, customers, vendors, suppliers, and partners. Risk tolerance and strategies are also defined in the policy.
Risk Assessment
Formal risk assessments are performed, which includes the identification of relevant internal and external threats related to security, availability, confidentiality, and fraud, and an analysis of risks associated with those threats.

Access Security

Encryption and Key Management Policy
An Encryption and Key Management Policy supports the secure encryption and decryption of app secrets, and governs the use of cryptographic controls.
Removal of Access
Upon termination or when internal personnel no longer require access, system access is removed, as applicable.
Access to Product is Restricted
Non-console access to production infrastructure is restricted to users with a unique SSH key or access key
Unique Access IDs
Personnel are assigned unique IDs to access sensitive systems, networks, and information
Access Control and Termination Policy
An Access Control and Termination Policy governs authentication and access to applicable systems, data, and networks.
Asset Inventory
A list of system assets, components, and respective owners are maintained and reviewed at least annually
User Access Reviews
System owners conduct scheduled user access reviews of production servers, databases, and applications to validate internal user access is commensurate with job responsibilities.

Physical Security

Physical Security Policy
A Physical Security Policy that details physical security requirements for the company facilities is in place.
Physical Access Restrictions
Processes are in place to create, modify or remove physical access to facilities such as data centers, office spaces, and work areas based on the needs of such individual.

Communications

Privacy Policy
A Privacy Policy to both external users and internal personnel. This policy details the company's privacy commitments.
Terms of Service
Terms of Service or the equivalent are published or shared to external users.
Communication of Security Commitments
Security commitments and expectations are communicated to both internal personnel and external users via the company's website.