Policy

Cybersecurity Policy

Effective: April 2026 Owner: Chief Compliance Officer Applies to: All Telvo entities

Framework

Telvo maintains a cybersecurity program aligned with SOC 2 Trust Services Criteria to protect the confidentiality, integrity, and availability of platform systems and LP information.

Access Controls

All platform systems require multi-factor authentication. Role-based access provisioning limits each user's access to the minimum necessary for their function. Access reviews are conducted quarterly.

Data Protection

Sensitive data including LP information, subscription documents, and investment materials is encrypted at rest and in transit. The LP portal uses encrypted document exchange.

Incident Response

Telvo maintains a cybersecurity incident response plan including detection, containment, remediation, notification, and post-incident review. Material incidents are reported to affected LPs and, where required, regulatory authorities.

Vendor Management

Third-party vendors with access to Telvo systems or LP information are subject to due diligence including SOC 2 review, security questionnaires, and contractual security obligations.