Data Breach Disclosure Policy

Incident response and notification under the Florida Information Protection Act (FIPA)

Our Commitment

Pana MIA Club maintains a breach response plan and is committed to notifying affected users per Florida law (Fla. Stat. § 501.171). We will provide timely, transparent disclosure in the event of a data breach affecting personal information.

What Constitutes a Breach

Breach definition per FIPA § 501.171(1)(g) — unauthorized access of personal information, encryption safe harbor — full legal text to be drafted.

Notification Requirements

FIPA notification timeline (30 days), AG notice (500+ residents), consumer reporting agencies (1,000+), notice content requirements — full legal text to be drafted.

Incident Response Plan

Internal incident response: detection, assessment (24h), containment, legal review, notification, remediation, transparency — full legal text to be drafted.

Reasonable Security Measures

Per FIPA § 501.171(2), we maintain reasonable measures to protect personal information, including:

  • Encryption at rest (Supabase/PostgreSQL) and in transit (TLS)
  • Password hashing via better-auth (bcrypt/scrypt)
  • OAuth tokens stored server-side, never exposed to client
  • Cloudflare WAF and DDoS protection
  • Environment variable segregation (secrets never in client bundles)
  • R2 bucket access controls
  • Regular dependency audits (Dependabot)

Report a Suspected Breach

If you believe you have discovered a security vulnerability or data breach, please contact us immediately:

hola@pana.social