To allow for the reporting and disclosure of vulnerabilities discovered by external entities, and anonymous reporting of information security policy violations by internal entities.



FLNT’s Responsible Disclosure Policy covers applies to FLNT’s core platform and its information security infrastructure, and to internal and external employees or third parties.



FLNT is committed to ensuring the safety and security of our customers and employees. We aim to foster an environment of trust, and an open partnership with the security community, and we recognize the importance of vulnerability disclosures and whistleblowers in continuing to ensure safety and security for all of our customers, employees and company. We have developed this policy to both reflect our corporate values and to uphold our legal responsibility to good-faith security researchers that are providing us with their expertise and whistleblowers who add an extra layer of security to our infrastructure.


Roles and Responsibilities

Head of Information technology – Create a channel that allows external entities to report vulnerabilities. Also, this channel can be used anonymously by internal staff to report information security policy violations.



Vulnerability Report/Disclosure

How to Submit a Vulnerability

To submit a vulnerability report to FLNT’s Technology Team, please utilize the following email security@flnt.io.

Preference, Prioritization, and Acceptance Criteria

We will use the criteria from the next sections to prioritise and triage submissions.

What we would like to see from you:

  • Well-written reports in English will have a higher probability of resolution.
  • Reports that include proof-of-concept code equip us to better triage.
  • Reports that include only crash dumps or other automated tool output may receive lower priority.
  • Reports that include products not on the initial scope list may receive lower priority.
  • Please include how you found the bug, the impact, and any potential remediation.
  • Please include any plans or intentions for public disclosure.

What you can expect from FLNT:

  • A timely response to your email (within 2 weeks).
  • After triage, we will send an expected timeline and commit to being as transparent as possible about the remediation timeline as well as on issues or challenges that may extend it.
  • An open dialog to discuss issues.
  • Notification when the vulnerability analysis has completed each stage of our review.

If we are unable to resolve communication issues or other problems, FLNT may bring in a neutral third party to assist in determining how best to handle the vulnerability.

FLNT does not offer financial incentives for vulnerability disclosure. If we triage your findings to be legitimate, you will receive an acknowledgment letter from the company.



How to Submit a Report

To anonymously report an information security program violation or a violation of related laws and regulations, please utilise this email address: security@flnt.io

Preference, Prioritisation, and Acceptance Criteria
We will use the criteria from the following sections to prioritise and review submissions.

What we expect from you:

  • Detailed report made in good faith or based on a reasonable belief
    • Good Faith means the truthful reporting of a company-related violation of information security policies, procedures, or regulations, as opposed to a report made with reckless disregard or willful ignorance of facts.
    • Reasonable Belief refers to the subjective belief in the truth of the disclosure AND that any reasonable person in a similar situation would objectively believe based on the facts.
  • Details of the violation (i.e., what, how, why).
  • Details of the reported event, with facts (i.e., who, where, when).
  • You are NOT responsible for investigating the alleged violation, or for determining fault or corrective measures.

What you can expect from FLNT:

  • Your report will be submitted to the Technology committee for review.
  • Protection of your identity and confidentiality.
    • CAVEAT: It may be necessary for your identity to be disclosed when a thorough investigation, compliance with the law, or due process of accused members is required.
  • Protection against any form of retaliation and harassment, such as termination, compensation decreases, or poor work assignments and threats of physical harm.
    • If you believe that you are being retaliated against, immediately contact HR
    • Any retaliation or harassment against you will result in disciplinary action.
    • CAVEAT: Your right for protection against retaliation does not include immunity for any personal wrongdoing alleged in the report and investigated
  • Due process for you and for the accused member(s).
  • Corrective actions taken to resolve a verified violation and a review and enhancement of applicable policies and procedures, if necessary or appropriate.
  • Continuous information security awareness training and understanding your rights as a whistleblower.