PhysicalFinancial ServicesTechnologyFinanceTheftCustomer Data InvolvedIdentity (basic)Government IDMediumContained

MemberClicks, Inc.

bd_42bd500a56bff358 · schema v1 · pii pii-v1

Severity

Medium

Discovered

Oct 27, 2014

Filed

Nov 18, 2014

To disclose

22 days

Affected · nationwide

2502 in this filing

Linked

2 filings

Confidence

66%

Full breach record for MemberClicks, Inc. →

MemberClicks, Inc. (dba Moolah Payments) notified the NH AG of a data breach following the theft of an employee's company-issued laptop during an auto break-in on Oct 24, 2014. Discovered Oct 27, 2014, the incident affected <250 individuals (2 in NH). Compromised data included names, addresses, DOBs, and SSNs. Moolah engaged Kroll for credit monitoring and notified affected parties.

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Incident timeline

undetected · 3 days

discovery → filing · 22 days

Oct 24, 2014

Begins

Oct 27, 2014

Discovered

Nov 18, 2014

Filed

vs. sector median

6 wks faster

This filing is one of 2 about the same incident.View merged incident

Linked disclosures

Why this link?

Regulatory filings (1) · sorted by filing gap

Massachusetts State AGbd_588f5604c4fd862e2014-11-24 · +6dVerified

Name: Nelson Mullins Riley & Scarborough LLP
norm: nelson mullins riley scarborough

Name: MemberClicks, Inc.
norm: memberclicks
Industry: Financial ServicesllmTechnologyllm

Discovered: Oct 27, 2014
Breach occurred: Oct 24, 2014
Undetected for: 3 daysoccurrence → discovery
Materiality determined: —
Notification sent: Nov 20, 2014
Affected individuals: 250state + nationwide
Data types: Identity (basic)Government ID
Data elements: Social Security numberDate of birth
Attack vector: Unknown
MITRE ATT&CK: T1052 Exfiltration Over Physical Medium
Threat actor: ExternalFinancial
Regulator citations: Notified the Office of the Attorney General of New Hampshire

During the incident: Reported the criminal act to law enforcement authorities
Secured the services of Kroll Advisory Solutions to provide identity theft protection
Provided 1-year of free credit monitoring services to affected individuals
Established a toll-free number for recipients to call with questions
Changes made: Devoting all necessary resources to ongoing efforts to enhance information security policies and procedures
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 22 days(22 days from discovery to filing)
Compliance flags: — (clock not assessable for this source)

Status: No extraction artifact recorded for this disclosure.

Filing propagation · 2 filings · 2 states

View merged incident ↗

New Hampshire State AGNov 18 · first · this page

Massachusetts State AG+6d

Pattern: first filing Nov 18 (NH), last Nov 24 (MA) — a 6-day rolling notification. Rolling spreads often mean counsel is filing as thresholds trip per state. Why this link?

Evidence ladder

Leak-site claim

Attacker assertion only. Establishes: claim date, group, alleged victim.

Press / market report

Unlocks: incident narrative, operational impact. Still no compliance clock.

State AG / regulator filingThis record

Unlocks: discovery date, data types, affected count, compliance clock.

SEC 8-K / victim statement

Unlocks: materiality, stated response, full audit trail. Ceiling removed.

Source URL: https://mm.nh.gov/files/uploads/doj/remote-docs/memberclicks-moolah-payments-20141118.pdf
DisclosureLens links to the originating regulator URL — full filing bodies are not redistributed from public surfaces (§4.5).
Filed at: Nov 18, 2014
Raw hash: ff63e56089662ae295fa9e01df84376d2c00ce6c3088bbedc3be2856cd25c65f

Linked disclosures

Regulatory filings (1) · sorted by filing gap

Reporting entityNelson Mullins Riley & Scarborough LLP

Victim entityMemberClicks, Inc.

Incidentdiscovered Oct 27, 2014

Stated responseReported the criminal act to law enforcement authorities

Complianceclock not assessable

Extraction provenanceno artifact recorded

Source provenancemm.nh.gov