[legal name not configured] complies with United States economic sanctions and export controls. This policy sets out the controls HopLogs applies to every customer.
Management commitment
The owners of [legal name not configured] are responsible for this program, review it at least once a year, and provide the resources it needs.
Risk assessment
We sell an online monitoring service worldwide. Our main risks are customers in sanctioned places and customers who are restricted parties. We therefore sell only in an approved list of countries and regions, and screen every customer.
Controls
- Blocked places. We do not provide the Service to anyone in Cuba, Iran, North Korea, Syria, or the Crimea, so-called Donetsk People's Republic or Luhansk People's Republic regions of Ukraine. As a business decision we also do not serve Russia or Belarus.
- Approved countries. We sell only in the countries and regions listed in our customer app at checkout. Others are not offered.
- Location checks. We check the billing address, the country that issued the payment card, the tax identification number and, where available, the IP address, at sign-in, at checkout, at renewal and whenever these details change. A signal from any of them that points to a blocked place stops the action and is reviewed.
- Restricted-party screening. We screen each customer's legal name and billing contact against the United States government's Consolidated Screening List, which combines the Treasury and Commerce Departments' lists. We screen at the first order, whenever these details change, and every customer again whenever the list changes.
- Review. A possible match pauses the order or service until a person reviews it. A false positive is cleared with a note; a confirmed match is blocked and handled as the law requires.
- Contract terms. Our terms of service require customers to confirm they are not in a sanctioned place or a restricted party and will not let such persons use the Service.
Testing and records
We test these controls regularly, and keep screening results, review decisions and the evidence behind them for ten years, as United States law requires.
Training
Everyone who reviews screening results is trained on this policy before doing so, and again each year.
Questions about this policy: [contact email not configured].