HackingHospitalityHospitalityTargetedData ExfiltratedIdentity (basic)Government IDHighContained

Promontory Investments LLC

bd_fa00472beb09de25 · schema v1 · pii pii-v1

Severity

High

Discovered

Dec 16, 2024

Filed

Jan 17, 2025

To disclose

5 weeks

Affected · nationwide

1,5621 in this filing

Linked

6 filings

Confidence

65%

Full breach record for Promontory Investments LLC →

Promontory Investments LLC dba The Promontory Club reported an external system breach (hacking) occurring between Nov 11-13, 2024, discovered Dec 16, 2024. 1,562 individuals affected, including 1 Maine resident. Data involved names, contact info, DOB, and SSNs. The company engaged forensic investigators, enhanced security measures, and offered 1 year of Experian IdentityWorks credit monitoring.

J jump to incidentP pin to compareR raw source

Maine clockDiscovered Dec 16, 2024 → Filed with AG Jan 17, 202532d ⏱ ME AG >30d5 weeks discovery → filing

⚠ AG web formThe discovery date came from the AG web-form field, which is systematically later than the detection date stated in the letter. Treat the clock as indicative.

Incident timeline

undetected · 35 days

discovery → filing · 5 weeks / 32 days

Nov 11, 2024

Begins

Dec 16, 2024

Discovered

Jan 17, 2025

Filed

This filing is one of 6 about the same incident.View merged incident

Linked disclosures

Why this link?

Regulatory filings (5) · sorted by filing gap

Massachusetts State AGbd_bc0784d8ba891f312025-01-17Verified
New Hampshire State AGbd_fd871fc6fe003ae62025-01-17Verified
Nebraska State AGbd_48a6c44f2221fcda2025-01-14 · +3dCandidate
Indiana State AGbd_861fbc9cc10f27402025-01-14 · +3dVerified

Show 1 more filing ↓up to 300d gap

Maryland State AGbd_3b5e87d5e5788bef2025-11-13 · +300dVerified

Name: Polsinelli PC
norm: polsinelli

Name: Promontory Investments LLC
norm: promontory investments
Also named: Promontory Investments LLCdba oflegal entity
The Promontory Clubdba oftrade name
Industry: Hospitalityllm

Discovered: Dec 16, 2024
Breach occurred: Nov 11, 2024 – Nov 13, 2024
Undetected for: 35 daysoccurrence → discovery
Materiality determined: —
Notification sent: Jan 14, 2025
Affected individuals: 1,562state + nationwide
Data types: Identity (basic)Government ID
Data elements: Social Security numberDate of birth
Attack vector: Unauthorized Access
MITRE ATT&CK: T1190 Exploit Public-Facing ApplicationT1078 Valid Accounts
Threat actor: External
Regulator citations: Filed notice with Maine Attorney General
Initial access: exploit_public_facing

During the incident: Engaged a forensic security firm to investigate and confirm the security of our computer systems
Took steps to contain and remediate the incident
Offering a complimentary one-year membership of Experian IdentityWorks SM Credit 3B
Changes made: Enhancing our technical security measures
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 5 weeks(32 days from discovery to filing)
Compliance flags: ME AG >30d · 32d
Discovery-date grounding: AG web formThe discovery date came from the AG web-form field, which is systematically later than the detection date stated in the letter. Treat the clock as indicative.
Clock breakdown: Statute Window Elapsed Threshold Status
Maine
Discovered: Dec 16, 2024
→ Filed with AG: Jan 17, 2025
32d 30 days (soft) ME AG >30d

Statute	Window	Elapsed	Threshold	Status
Maine	Discovered: Dec 16, 2024 → Filed with AG: Jan 17, 2025	32d	30 days (soft)	ME AG >30d

Status: No extraction artifact recorded for this disclosure.

Filing propagation · 6 filings · 6 states

View merged incident ↗

Nebraska State AGJan 14 · first

Indiana State AGJan 14 · first

Massachusetts State AG+3d

New Hampshire State AG+3d

Maine State AG+3d · this page

Maryland State AG+303d

Pattern: first filing Jan 14 (NE), last Nov 13 (MD) — a 303-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://www.maine.gov/agviewer/content/ag/985235c7-cb95-4be2-8792-a1252b4f8318/6fc1c3a0-fc9e-484d-9cb9-a142b6027a41.html
DisclosureLens links to the originating regulator URL — full filing bodies are not redistributed from public surfaces (§4.5).
Filed at: Jan 17, 2025
Raw hash: 799cda555ec4242bb026d581b25e21105ac1c3180c2ffd1463333d5fcbfd4e89

Linked disclosures

Regulatory filings (5) · sorted by filing gap

Reporting entityPolsinelli PC

Victim entityPromontory Investments LLC

Incidentdiscovered Dec 16, 2024

Stated responseEngaged a forensic security firm to investigate and confirm the security of our computer systems

ComplianceME AG >30d

Extraction provenanceno artifact recorded

Source provenancewww.maine.gov