Confidentiality Policy

Document 6 of the Board Governance Binder

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Confidentiality Policy

Document 6 POLICY

Confidentiality Policy

I. Purpose

This policy establishes expectations for the protection of confidential information by all Directors, Officers, employees, volunteers, and contractors of PROVENIQ Foundation, Inc.

II. Definition of Confidential Information

Confidential information includes but is not limited to: personnel and compensation information, donor and fundraising data, financial records not yet public, strategic plans and negotiations, legal matters and attorney-client communications, technology specifications and proprietary platform information related to the Pet Command ecosystem, user data processed through MAYDAY, ShelterOS, LifeLog, VetOS, Guardians, ACO-Mobile, and SYSOP, board deliberations and executive session proceedings, whistleblower reports and investigations, partner and vendor negotiations, grant applications in progress, and any information designated as confidential by the Board or CEO.

III. Obligations

All covered individuals shall protect confidential information from unauthorized disclosure. Confidential information shall not be shared with any person outside the Corporation unless authorized by the CEO or Board Chair. Confidential information shall not be used for personal benefit or the benefit of any third party. Confidential information shall be stored securely, whether in physical or electronic form. Confidential information shall be returned or destroyed upon termination of the individual’s relationship with the Corporation.

IV. Technology-Specific Confidentiality

Given the Corporation’s role as operator of the Pet Command ecosystem, individuals with access to platform data, source code, specifications, or user information bear a heightened duty of confidentiality. Unauthorized access to, copying of, or disclosure of technology platform data or specifications is strictly prohibited. All technology-related confidentiality obligations are subject to the terms of the Technology License Agreement between the PROVENIQ Charitable Trust and the Corporation.

V. Duration

The obligation of confidentiality survives termination of Board service, employment, volunteer service, or contractual engagement. Confidential information remains confidential unless and until it becomes publicly available through authorized channels.

VI. Exceptions

Disclosure is permitted when required by law, court order, or regulatory authority, when necessary to report suspected illegal activity under the Whistleblower Protection Policy, or when authorized by the Board or CEO.

VII. Violations

Breach of this policy may result in discipline up to and including termination, removal from the Board, termination of contractor relationship, or legal action.

VIII. Acknowledgment

Each covered individual shall sign this acknowledgment:

I have received, read, and understand the PROVENIQ Foundation Confidentiality Policy. I agree to protect all confidential information and understand that this obligation survives my separation from the organization.

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