Vulnerability Disclosure
Last updated: January 15, 2026
Vulnerability Disclosure Policy
Document owner: Chief Information Security Officer Version: 3.0 Effective date: January 1, 2026 Last updated: January 15, 2026 Classification: Public — Trust Center Review cadence: Annual, and upon material security program changes Company: Acme Cloud, Inc. Address: 1200 Market Street, Suite 400, San Francisco, CA 94103, USA Primary contacts: trust@acmecloud.com | security@acmecloud.com | privacy@acmecloud.com
1. Document Purpose and Executive Summary
This Vulnerability Disclosure Policy ("Policy") establishes Acme Cloud, Inc.'s ("Company," "we," "us," or "our") formal framework for receiving, processing, triaging, remediating, and disclosing security vulnerabilities discovered in our products, services, and infrastructure. This Policy demonstrates our commitment to transparency, responsible security research, and collaborative engagement with the global security research community.
The vulnerability disclosure program is a critical component of our defense-in-depth security strategy, complementing automated security scanning, penetration testing, code reviews, and continuous security monitoring. By establishing clear guidelines for external security researchers, we create a structured channel for identifying and addressing security weaknesses before they can be exploited by malicious actors.
This Policy applies to all Acme Cloud assets within the defined scope, establishes safe harbor protections for good-faith security researchers, defines our disclosure coordination process, and outlines our recognition program for contributors to our security posture.
Key Policy Commitments:
- We will acknowledge vulnerability reports within two (2) business days
- We will provide status updates at minimum every ten (10) business days
- We will remediate critical vulnerabilities within seventy-two (72) hours target
- We will not pursue legal action against researchers acting in good faith
- We will publicly recognize researchers who report valid vulnerabilities (with consent)
2. Definitions
For purposes of this Policy, the following terms shall have the meanings set forth below:
| Term | Definition |
|---|---|
| Vulnerability | A weakness in a system, application, or process that could be exploited to compromise the confidentiality, integrity, or availability of information or systems. This includes software bugs, misconfigurations, design flaws, and process deficiencies. |
| Security Researcher | Any individual or organization conducting security testing activities to identify vulnerabilities in computer systems, networks, or applications, whether independently or under engagement. |
| Good Faith | Acting with honest intent, without malicious purpose, and in compliance with applicable law and this Policy. Good faith requires avoiding unnecessary harm, respecting privacy, and promptly reporting discovered vulnerabilities. |
| Safe Harbor | Legal protection extended by the Company to security researchers who comply with this Policy, shielding them from legal action related to authorized security research activities. |
| Coordinated Disclosure | A process whereby the discoverer of a vulnerability shares information with the affected vendor under embargo, allowing time for remediation before public disclosure. |
| CVSS | Common Vulnerability Scoring System, an industry-standard framework for assessing the severity of security vulnerabilities based on exploitability, scope, and impact metrics. |
| CVE | Common Vulnerabilities and Exposures, a publicly disclosed cybersecurity vulnerability identifier maintained by MITRE Corporation. |
| Proof of Concept (PoC) | A demonstration that a vulnerability is exploitable, typically through code, screenshots, or documentation showing the attack path and impact. |
| Triage | The process of evaluating a reported vulnerability to assess its validity, severity, scope, and appropriate remediation priority. |
| Remediation | Actions taken to fix, patch, mitigate, or otherwise address a vulnerability to eliminate or reduce associated risk. |
| Bug Bounty | A reward program offering monetary compensation to researchers who report valid security vulnerabilities (not currently offered by Acme Cloud). |
| Embargo Period | The time between initial vulnerability report and public disclosure, during which the vendor works to remediate the issue. |
| Subprocessor | A third-party service provider that processes data on behalf of Acme Cloud in connection with service delivery. |
| Zero-Day | A previously unknown vulnerability with no available patch at the time of discovery or exploitation. |
| Attack Surface | The sum of all points where an unauthorized user could attempt to enter data to or extract data from the Company's systems. |
3. Scope of Testing Authorization
3.1 In-Scope Assets
The following assets are authorized for security testing under this Policy:
| Asset Category | Specific Assets | Authorization Level | Notes |
|---|---|---|---|
| Production Web Applications | acmecloud.com, *.acmecloud.com (excluding customer subdomains) | Full testing authorized | Rate limiting applies |
| Customer-Facing SaaS Platform | app.acmecloud.com, api.acmecloud.com | Full testing on researcher-owned accounts | Do not test against other customers |
| Authentication Systems | auth.acmecloud.com, login.acmecloud.com | Limited testing authorized | No credential stuffing or account enumeration |
| Public API Endpoints | api.acmecloud.com/v1/, api.acmecloud.com/v2/ | Testing authorized per API documentation | Respect rate limits; use test credentials |
| Mobile Applications | Official iOS and Android applications from App Store/Google Play | Full testing authorized | Test against latest released version |
| Browser Extensions | Official Chrome and Firefox extensions | Full testing authorized | Test against latest released version |
| Open Source Repositories | github.com/acmecloud/* | Full testing authorized | Follow responsible disclosure for libraries |
| Documentation Sites | docs.acmecloud.com, developers.acmecloud.com | Limited testing authorized | Content injection vulnerabilities in scope |
| Status Page | status.acmecloud.com | Limited testing authorized | Availability testing not authorized |
3.2 Out-of-Scope Assets and Activities
The following are explicitly out of scope and testing is not authorized:
| Category | Examples | Rationale | Alternative Action |
|---|---|---|---|
| Third-Party Services | CDN providers, analytics platforms, payment processors | Not under Company control | Report directly to service provider |
| Customer Data and Accounts | Any customer tenant, customer-configured integrations | Privacy and legal concerns | Use only researcher-owned test accounts |
| Social Engineering | Phishing employees, pretexting, tailgating | Employee safety and privacy | Not permitted under any circumstances |
| Physical Security | Office access, hardware tampering, dumpster diving | Physical safety concerns | Requires separate written authorization |
| Denial of Service | Resource exhaustion, traffic flooding, crash testing | Service availability impact | Report theoretical DoS vulnerabilities without testing |
| Spam and Mass Messaging | Email flooding, notification abuse | User experience impact | Report vulnerability without exploitation |
| Data Destruction | Deleting data, corrupting databases | Irreversible harm | Demonstrate read-only proof of concept |
| Privacy Violations | Accessing personal data, surveillance | Legal and ethical concerns | Report vulnerability without accessing PII |
| Competitor Systems | Partner integrations, marketplace apps | Not under Company control | Report to respective vendors |
| Automated Scanning (Aggressive) | High-volume automated tools, fuzzing without coordination | Service degradation risk | Coordinate with security team before automated testing |
| Employee Personal Accounts | Social media, personal email, personal devices | Privacy violations | Not permitted under any circumstances |
| Acquired Companies Pre-Integration | Systems of recently acquired companies not yet integrated | Scope uncertainty | Contact security team for clarification |
3.3 Testing Conduct Requirements
Researchers must adhere to the following conduct requirements during testing:
| Requirement | Specification | Verification Method |
|---|---|---|
| Rate Limiting | Maximum 10 requests per second for automated testing | Monitored via WAF logs |
| Session Management | Use only researcher-controlled test accounts | Account verification during triage |
| Data Access | Access minimum data necessary to demonstrate vulnerability | Report review |
| Data Retention | Delete any inadvertently accessed data promptly | Self-attestation in report |
| Confidentiality | Do not disclose vulnerability until coordinated disclosure | Public monitoring |
| Communication | Use designated channels only (security@acmecloud.com) | Channel verification |
| Professional Conduct | No threats, extortion, or unprofessional communication | Communication review |
| Tool Usage | Avoid tools that may cause service degradation | Activity monitoring |
| Geographic Restrictions | Comply with applicable sanctions and export controls | IP verification |
| Legal Compliance | Comply with all applicable laws beyond this Policy | Self-attestation |
4. Safe Harbor Provisions
4.1 Legal Protection Commitment
Acme Cloud extends the following legal protections to security researchers who comply with this Policy:
4.1.1 Authorization Under Computer Fraud and Abuse Act (CFAA)
We consider security research conducted in accordance with this Policy to be authorized access under the Computer Fraud and Abuse Act (18 U.S.C. § 1030), to the extent such authorization is legally effective. We will not pursue civil claims or initiate criminal complaints against researchers who:
- Conduct testing only against in-scope assets
- Avoid privacy violations, data destruction, and service disruption
- Report vulnerabilities promptly through designated channels
- Do not exploit vulnerabilities beyond proof-of-concept demonstration
- Do not access, modify, or exfiltrate customer data
- Maintain confidentiality until coordinated disclosure
4.1.2 Safe Harbor Limitations
Safe harbor protection does not extend to:
| Excluded Activity | Rationale | Consequence |
|---|---|---|
| Violations of laws unrelated to security research | Legal compliance requirement | May result in law enforcement referral |
| Access to customer data without authorization | Privacy and legal obligations | Not protected; may result in prosecution |
| Testing against out-of-scope assets | Scope limitation | Not protected under this Policy |
| Disclosure in violation of embargo | Coordinated disclosure requirement | Recognition forfeited; future reports may be declined |
| Extortion or ransom demands | Criminal conduct | Not protected; will result in law enforcement referral |
| Repeated Policy violations after warning | Bad faith indicator | Safe harbor revoked for individual |
| Testing from sanctioned jurisdictions | Export control compliance | May not be legally protected |
4.2 Third-Party Safe Harbor Coordination
If your research involves third-party services integrated with Acme Cloud, we will make good-faith efforts to coordinate with those parties regarding safe harbor protections. However, we cannot guarantee third-party enforcement decisions. Researchers should review third-party vulnerability disclosure policies before testing integrated services.
4.3 Employment and Contractor Exclusions
Current employees, contractors, and their immediate family members are not eligible for public recognition under this Policy. Such individuals should report security concerns through internal channels (internal security ticketing system, direct CISO contact, or whistleblower hotline per Whistleblower Policy).
5. Vulnerability Reporting Procedures
5.1 Reporting Channels
| Channel | Contact Information | Availability | Encryption | Use Case |
|---|---|---|---|---|
| Primary Email | security@acmecloud.com | 24/7 (monitored business hours) | PGP available | All vulnerability reports |
| Encrypted Submissions | security.txt PGP key | 24/7 | Required for sensitive data | Reports containing exploit code or sensitive details |
| Web Form | acmecloud.com/security/report | 24/7 | TLS only | Structured report submission |
| HackerOne (Monitoring) | hackerone.com/acmecloud | N/A | Platform native | We monitor for reports; not primary channel |
| Emergency Line | +1-415-555-0199 | 24/7 | No | Critical vulnerabilities requiring immediate attention |
5.2 Report Content Requirements
Complete vulnerability reports should include the following information:
| Required Element | Description | Example |
|---|---|---|
| Vulnerability Type | Classification of the vulnerability (XSS, SQLi, IDOR, etc.) | "Stored Cross-Site Scripting (XSS)" |
| Affected Asset | Specific URL, endpoint, application, or component | "https://app.acmecloud.com/dashboard/settings" |
| Affected Versions | Application version, API version, or date observed | "API v2.3.1, observed January 15, 2026" |
| Reproduction Steps | Detailed, numbered steps to reproduce the vulnerability | "1. Log in as standard user\n2. Navigate to settings\n3. Enter payload in name field" |
| Proof of Concept | Code, screenshots, video, or HTTP requests demonstrating the issue | HTTP request/response, screenshot with redactions |
| Impact Assessment | Your assessment of potential impact to confidentiality, integrity, or availability | "Allows session hijacking of logged-in users" |
| Severity Estimate | Your CVSS score estimate if possible | "CVSS 3.1 Base Score: 8.1 (High)" |
| Discovery Context | How you discovered the vulnerability | "Manual testing during API integration review" |
| Recommended Fix | If known, suggest remediation approach | "Implement output encoding for user-supplied content" |
| Contact Information | Email or secure contact method for follow-up | "researcher@example.com, Signal: +1-xxx-xxx-xxxx" |
| Recognition Preference | Whether you wish to be publicly credited | "Yes, credit as 'Jane Doe'" |
5.3 Optional but Helpful Information
- Environment details (browser, OS, network configuration)
- Traffic captures (sanitized of personal information)
- Automated tool output (if applicable)
- References to similar vulnerabilities (CVE numbers, prior art)
- Proposed timeline for coordinated disclosure
6. Vulnerability Handling Process
6.1 Response Timeline Commitments
| Phase | Target Timeline | Maximum Timeline | Escalation Trigger |
|---|---|---|---|
| Acknowledgment | 1 business day | 2 business days | Auto-escalation if not acknowledged |
| Initial Triage | 3 business days | 5 business days | Manager escalation at day 4 |
| Severity Assignment | 5 business days | 7 business days | CISO notification for High/Critical |
| Remediation Plan | 7 business days | 14 business days | Executive escalation for Critical |
| Status Update Cadence | Every 7 days | Every 10 business days | Reporter may request escalation |
| Critical Remediation | 24 hours | 72 hours | Incident commander activation |
| High Remediation | 7 days | 14 days | Management review |
| Medium Remediation | 30 days | 60 days | Standard tracking |
| Low Remediation | 60 days | 90 days | Backlog prioritization |
| Reporter Notification (Resolution) | 3 business days after fix | 5 business days | Automatic on ticket closure |
6.2 Triage and Severity Classification
We use CVSS v3.1 as the baseline for severity classification, adjusted for business context and exploitability:
| Severity | CVSS Range | Definition | Remediation SLA | Examples |
|---|---|---|---|---|
| Critical | 9.0 – 10.0 | Vulnerabilities allowing unauthenticated remote code execution, mass data exfiltration, or complete system compromise | 72 hours | Unauthenticated RCE, SQL injection with full database access, authentication bypass to admin |
| High | 7.0 – 8.9 | Vulnerabilities allowing significant impact with some constraints (authentication, user interaction, or limited scope) | 14 days | Authenticated privilege escalation, stored XSS in admin panel, SSRF with internal network access |
| Medium | 4.0 – 6.9 | Vulnerabilities with moderate impact requiring specific conditions or limited exploitability | 60 days | CSRF on non-critical actions, reflected XSS requiring social engineering, information disclosure of non-sensitive data |
| Low | 0.1 – 3.9 | Vulnerabilities with minimal impact or requiring unlikely conditions | 90 days | Missing security headers, verbose error messages, clickjacking on non-sensitive pages |
| Informational | 0.0 | Observations that may indicate security improvements but do not represent exploitable vulnerabilities | No SLA | Best practice recommendations, defense-in-depth suggestions |
6.3 Internal Escalation Matrix
| Severity | Immediate Notification | Executive Briefing | Board Notification |
|---|---|---|---|
| Critical | CISO (4 hours), VP Engineering | CEO (24 hours) | Audit Committee (if customer data affected) |
| High | Security Engineering Manager | CISO (weekly summary) | N/A |
| Medium | Security Engineer on-call | Monthly metrics | N/A |
| Low | Standard ticket workflow | Quarterly summary | N/A |
7. Coordinated Disclosure Framework
7.1 Disclosure Timeline
Acme Cloud requests a standard ninety (90) day embargo period from report acknowledgment to public disclosure. This timeline allows for:
- Thorough investigation and root cause analysis
- Development and testing of remediation
- Deployment to production environments
- Customer notification where appropriate
- Coordination with affected third parties
7.2 Timeline Modifications
| Scenario | Adjustment | Approval Required |
|---|---|---|
| Simple fix, low risk | May reduce to 30-60 days | Mutual agreement |
| Complex remediation | May extend to 120 days | Researcher agreement, written explanation |
| Active exploitation observed | Accelerated disclosure (7-14 days) | CISO approval |
| Third-party dependencies | Extension based on vendor timeline | Documented coordination |
| Researcher request for extension | Considered on case-by-case basis | CISO approval |
| Holiday or resource constraints | Up to 30 additional days | Mutual agreement |
7.3 Disclosure Publication Process
Upon remediation and embargo completion:
| Step | Action | Timeline | Responsible Party |
|---|---|---|---|
| 1 | Verify fix deployed to all production environments | Before disclosure | Engineering |
| 2 | Notify researcher of resolution and disclosure readiness | 5 days before disclosure | Security Team |
| 3 | Prepare security advisory (internal review) | 3 days before disclosure | Security Team + Legal |
| 4 | Request CVE identifier (if applicable) | 5 days before disclosure | Security Team |
| 5 | Publish advisory to acmecloud.com/security/advisories | Disclosure date | Security Team |
| 6 | Update Hall of Fame (if researcher consents) | Within 5 days of disclosure | Security Team |
| 7 | Notify affected customers (if applicable) | Per customer notification SLA | Customer Success |
8. Recognition Program
8.1 Security Hall of Fame
Acme Cloud maintains a Security Hall of Fame at acmecloud.com/security/hall-of-fame to recognize researchers who report valid in-scope vulnerabilities.
| Recognition Element | Options | Timing |
|---|---|---|
| Name/Handle | Real name, pseudonym, or "Anonymous" | At disclosure |
| Affiliation | Company or independent researcher | At disclosure |
| Vulnerability Category | General category (XSS, SQLi, etc.) | At disclosure |
| Recognition Date | Month and year of acknowledgment | At disclosure |
| Social Link | Twitter/X, LinkedIn, or personal website (optional) | At disclosure |
8.2 Recognition Eligibility Criteria
| Requirement | Description |
|---|---|
| Valid in-scope vulnerability | Confirmed security issue within Policy scope |
| Policy compliance | Researcher followed all Policy requirements |
| First reporter | First to report unique vulnerability (see duplicate policy) |
| Not employee or contractor | Current Acme Cloud personnel ineligible |
| No extortion attempts | No demands for payment as condition of report |
| Consent to recognition | Researcher affirmatively requests recognition |
8.3 Swag and Appreciation
While Acme Cloud does not currently operate a paid bug bounty program, we provide appreciation tokens to recognized researchers:
| Item | Eligibility | Notes |
|---|---|---|
| Acme Cloud security t-shirt | All recognized researchers | Shipped within 30 days of recognition |
| Security sticker pack | All recognized researchers | Included with t-shirt shipment |
| Handwritten thank-you note | Critical/High findings | From CISO |
| Reference letter | Exceptional contributions | Upon request |
| LinkedIn recommendation | Outstanding researchers | Upon request |
8.4 Bug Bounty Program Evaluation
Acme Cloud evaluates transition to a paid bug bounty program annually based on:
| Factor | Current Status | Target for Bounty Consideration |
|---|---|---|
| Annual report volume | 47 reports (FY2025) | 100+ reports |
| Remediation capacity | 12 valid findings remediated | Sustained capacity for 50+ annually |
| Program maturity | 2 years operating | 3+ years established |
| Budget allocation | Not currently budgeted | Executive approval required |
| Platform evaluation | HackerOne, Bugcrowd, Intigriti assessed | Platform selection complete |
9. Duplicate and Invalid Report Handling
9.1 Duplicate Reports
| Scenario | Outcome | Recognition |
|---|---|---|
| Vulnerability previously reported by external researcher | First reporter receives recognition | Subsequent reporters notified, no recognition |
| Vulnerability discovered by internal team | External reporter still eligible for recognition | Recognition notes parallel discovery |
| Vulnerability reported via multiple channels simultaneously | First received report takes precedence | Timestamp comparison |
| Vulnerability known but not yet remediated | Reporter notified of status | May receive recognition if not previously credited |
9.2 Invalid Report Categories
| Category | Examples | Response |
|---|---|---|
| Out of scope | Third-party services, customer integrations | Redirect to appropriate vendor |
| Not a vulnerability | Feature request, usability issue | Redirect to product feedback |
| Theoretical without PoC | "I think there might be XSS" without demonstration | Request proof of concept |
| Already public | CVE already published, vulnerability in dependency with known patch | Thank and close |
| Scanner noise | Automated tool false positives | Close with explanation |
| Policy violations | Tested customer accounts, caused service disruption | Warning or safe harbor revocation |
10. Security Advisory Publication
10.1 Advisory Content
Security advisories published at acmecloud.com/security/advisories include:
| Element | Description | Inclusion Criteria |
|---|---|---|
| Advisory identifier | Unique ACME-YYYY-NNN format | All advisories |
| CVE identifier | Where assigned by MITRE or CNA | Critical and High severity |
| Title | Brief description of vulnerability | All advisories |
| Severity | CVSS score and qualitative rating | All advisories |
| Affected versions | Specific versions or date ranges | All advisories |
| Description | Technical details appropriate for defenders | All advisories |
| Impact | Potential consequences of exploitation | All advisories |
| Remediation | Actions customers should take | All advisories |
| Workarounds | Temporary mitigations if available | Where applicable |
| Timeline | Discovery, report, fix, disclosure dates | All advisories |
| Credit | Researcher acknowledgment (with consent) | Where researcher consents |
| References | Related CVEs, vendor advisories | Where applicable |
10.2 Advisory Distribution
| Channel | Audience | Timing |
|---|---|---|
| Security advisories page | Public | At disclosure |
| RSS feed | Subscribers | At disclosure |
| Email notification | Enterprise customers (Critical/High) | 24-48 hours before public disclosure |
| In-app notification | Affected customers | At disclosure |
| Status page | All users (if service impact) | As appropriate |
11. Metrics and Program Transparency
11.1 FY2025 Program Metrics
| Metric | Value | Trend |
|---|---|---|
| Total reports received | 47 | +23% YoY |
| Valid vulnerabilities confirmed | 12 | +20% YoY |
| Critical severity | 1 | Stable |
| High severity | 2 | -1 YoY |
| Medium severity | 6 | +2 YoY |
| Low severity | 3 | Stable |
| Average acknowledgment time | 1.2 business days | Improved from 1.8 days |
| Average time to remediate (Critical) | 58 hours | Within SLA |
| Average time to remediate (High) | 9 days | Within SLA |
| Average time to remediate (Medium) | 34 days | Within SLA |
| Researchers recognized in Hall of Fame | 8 | +3 YoY |
| Reports rejected (out of scope/invalid) | 35 | Expected ratio |
| Safe harbor invocations | 0 | No disputes |
11.2 Continuous Improvement Initiatives
| Initiative | Status | Target Completion |
|---|---|---|
| Implement structured intake form | Completed Q4 2025 | Done |
| Automate acknowledgment emails | Completed Q3 2025 | Done |
| Integrate with GRC vulnerability tracker | Completed Q2 2025 | Done |
| Launch test account provisioning program | Planned Q2 2026 | In progress |
| Evaluate bug bounty platform | Planned Q4 2026 | Not started |
| Publish metrics dashboard | Planned Q3 2026 | Not started |
12. SOC 2 and ISO 27001 Control Mapping
12.1 SOC 2 Trust Services Criteria Mapping
| Control ID | Control Description | Policy Implementation |
|---|---|---|
| CC1.1 | COSO Principle 1: Demonstrates commitment to integrity and ethical values | Safe harbor provisions, ethical treatment of researchers |
| CC2.2 | Internal and external communication | Defined reporting channels, response timelines |
| CC3.1 | Risk identification | Vulnerability intake and triage process |
| CC3.2 | Risk assessment | CVSS-based severity classification |
| CC3.3 | Risk management | Remediation SLAs and escalation procedures |
| CC4.1 | Monitoring controls | Vulnerability metrics, program effectiveness review |
| CC4.2 | Deficiency evaluation and remediation | Vulnerability remediation tracking |
| CC5.1 | Control selection and development | Vulnerability disclosure program as preventive control |
| CC6.1 | Logical and physical access controls | Scope limitations, authorized testing requirements |
| CC6.8 | Vulnerability management | Core purpose of this Policy |
| CC7.1 | Detection of security events | External researcher reports as detection mechanism |
| CC7.2 | Incident response monitoring | Integration with incident response plan |
| CC7.3 | Incident response procedures | Escalation matrix, remediation SLAs |
| CC7.4 | Incident response communication | Reporter notification, advisory publication |
12.2 ISO 27001:2022 Annex A Control Mapping
| Control | Control Title | Policy Implementation |
|---|---|---|
| A.5.7 | Threat intelligence | External researcher reports as threat intelligence source |
| A.5.24 | Information security incident management planning | Vulnerability handling process |
| A.5.25 | Assessment and decision on information security events | Triage and severity classification |
| A.5.26 | Response to information security incidents | Remediation process and SLAs |
| A.5.27 | Learning from information security incidents | Metrics tracking, continuous improvement |
| A.5.28 | Collection of evidence | Report documentation requirements |
| A.6.8 | Information security event reporting | Reporting channels and procedures |
| A.8.8 | Management of technical vulnerabilities | Core vulnerability management process |
| A.8.12 | Data leakage prevention | Scope restrictions, researcher conduct requirements |
| A.8.16 | Monitoring activities | Researcher activity monitoring |
13. Legal and Regulatory Compliance
13.1 Applicable Legal Frameworks
| Framework | Applicability | Policy Alignment |
|---|---|---|
| Computer Fraud and Abuse Act (CFAA) | US federal law | Safe harbor provisions align with DOJ good-faith research guidance |
| California Comprehensive Computer Data Access and Fraud Act | California state law | Safe harbor extends to state law equivalent |
| EU Directive 2013/40/EU | EU operations | Coordinated disclosure process |
| UK Computer Misuse Act 1990 | UK operations | Good-faith research protections |
| GDPR Article 32 | EU data subjects | Vulnerability management as security measure |
| CCPA/CPRA | California residents | Security program component |
| NIST Cybersecurity Framework | Voluntary adoption | Aligned with Identify, Protect, Detect functions |
| DOJ Cybersecurity Unit Guidance | US federal guidance | Safe harbor language aligned with 2022 guidance |
13.2 Export Control Considerations
Researchers must comply with US export control regulations (EAR, OFAC sanctions). Acme Cloud cannot provide safe harbor protections for research conducted from comprehensively sanctioned jurisdictions or by individuals on restricted party lists. Researchers are responsible for their own export control compliance.
14. Program Governance and Oversight
14.1 Roles and Responsibilities
| Role | Responsibilities | Escalation Authority |
|---|---|---|
| CISO | Policy ownership, program oversight, Critical/High approval | Executive team, Board |
| Security Engineering Manager | Day-to-day operations, triage oversight | CISO |
| Security Engineer (On-Call) | Initial triage, researcher communication | Security Engineering Manager |
| Engineering Team Leads | Vulnerability remediation implementation | VP Engineering |
| Legal Counsel | Safe harbor review, regulatory compliance | General Counsel |
| Communications | Advisory publication, external communications | VP Marketing |
| Customer Success | Customer notification for affecting vulnerabilities | VP Customer Success |
14.2 Policy Review and Updates
| Review Type | Frequency | Trigger | Approver |
|---|---|---|---|
| Scheduled review | Annual | Calendar | CISO |
| Material change review | As needed | Program changes, regulations | CISO + Legal |
| Post-incident review | After significant findings | Critical vulnerability, process failure | CISO |
| Metrics review | Quarterly | Standard reporting | Security Engineering Manager |
| Benchmark review | Annual | Industry comparison | CISO |
15. Test Account Provisioning
15.1 Researcher Account Program
Qualified security researchers may request dedicated test accounts to facilitate in-scope testing:
| Account Type | Provisioning Time | Eligibility | Limitations |
|---|---|---|---|
| Standard test tenant | 3 business days | Validated researchers with research scope | 30-day validity, renewable |
| API test credentials | 2 business days | Validated researchers | Rate-limited, test environment |
| Enterprise feature access | 5 business days | Researchers testing enterprise features | Requires scope approval |
15.2 Account Request Process
- Email security@acmecloud.com with subject "Test Account Request"
- Include: researcher identity verification, research scope description, expected testing duration
- Security team validates request and provisions account
- Account credentials delivered via secure channel (PGP or Signal)
- Researcher acknowledges Policy compliance
- Account deprovisioned automatically at expiration or upon request
16. Relationship to Other Security Programs
16.1 Program Integration
| Program | Relationship | Cross-Reference |
|---|---|---|
| Penetration Testing | Complement community disclosure with annual professional testing | Penetration Testing Program |
| Incident Response | Critical vulnerabilities trigger incident response procedures | Incident Response Plan |
| Third-Party Risk | Vulnerabilities in vendor systems coordinated through TPRM | Third-Party Risk Management |
| Security Overview | Vulnerability management as component of security program | Security Overview |
| Change Management | Remediation changes follow standard change management | Internal change management policy |
16.2 Vulnerability Source Integration
All vulnerability sources feed unified tracking:
| Source | Integration Point | Deduplication |
|---|---|---|
| External researcher reports | This Policy | Manual triage |
| Penetration test findings | Pen test program | Automated matching |
| Automated scanning (SAST/DAST) | CI/CD pipeline | Automated deduplication |
| Dependency scanning (SCA) | Build process | Automated deduplication |
| Bug bounty platform monitoring | Monitoring dashboard | Manual review |
| Customer reports | Support ticketing | Manual triage |
| Internal security testing | Security team testing | Manual matching |
Related Trust Center documents
penetration testing, incident response, security overview, third party risk, access control, compliance frameworks
Document revision history
| Version | Date | Author | Summary of changes |
|---|---|---|---|
| 1.0 | 2024-06-01 | Legal & Compliance | Initial Trust Center publication |
| 2.0 | 2025-03-15 | GRC Program | SOC 2 Type II alignment refresh; expanded subprocessors |
| 2.5 | 2025-09-01 | Security Engineering | Encryption standards update; ISO 27001 mapping |
| 3.0 | 2026-01-15 | Trust Center Program | Full procurement-grade expansion; 34-document set |
Contact
Acme Cloud, Inc. 1200 Market Street, Suite 400 San Francisco, CA 94103, USA
| Channel | Use case | |
|---|---|---|
| Trust & procurement | trust@acmecloud.com | Security questionnaires, trust reviews |
| Security | security@acmecloud.com | Incidents, vulnerabilities, control questions |
| Privacy | privacy@acmecloud.com | DSRs, privacy assessments |
| Legal | legal@acmecloud.com | Contractual, DPA, legal notices |
17. Security.txt and Contact Information
Acme Cloud publishes machine-readable security contact information at:
security.txt Location: https://acmecloud.com/.well-known/security.txt
| Field | Value |
|---|---|
| Contact | mailto:security@acmecloud.com |
| Encryption | PGP key URL |
| Acknowledgments | https://acmecloud.com/security/hall-of-fame |
| Policy | https://acmecloud.com/trust-center/vulnerability-disclosure |
| Preferred-Languages | en |
| Canonical | https://acmecloud.com/.well-known/security.txt |
| Expires | Updated annually |
PGP Key Fingerprint: Available at security.txt, rotated annually with 30-day overlap period.
18. Acknowledgments
Acme Cloud thanks the global security research community for their contributions to our security posture. Your responsible disclosure helps protect our customers and the broader ecosystem. We are committed to treating all good-faith researchers with respect, transparency, and appreciation.
Report vulnerabilities: security@acmecloud.com
Trust inquiries: trust@acmecloud.com
PGP encryption: Available via security.txt
Hall of Fame: acmecloud.com/security/hall-of-fame
This Policy is not a contract and may be updated at any time. The "Last updated" date indicates the current version. Material changes will be communicated via security.txt and Trust Center notification.