We designed our company confidentiality policy to explain how we expect our employees to treat confidential information. Employees will unavoidably receive and handle personal and private information about clients, partners, and our company. We want to make sure that this information is well-protected.

We must protect this information for two reasons. It may:

• Be legally binding, such as sensitive customer data.
• Constitute the backbone of our business, giving us a competitive advantage, such as business processes.

Scope

This policy affects all employees, including board members, investors, contractors, and volunteers, who may have access to confidential information.

Policy Elements

Confidential and proprietary information is secret, valuable, expensive and/or easily replicated. Common examples of confidential information are:

• Patient and provider health records
• Unpublished financial information
• Data of customers, partners, and vendors
• Patents, formulas, or new technologies
• Customer lists, existing and prospective
• Data entrusted to our company by external parties
• Pricing, marketing, and other undisclosed strategies
• Documents and processes explicitly marked as confidential
• Unpublished goals, forecasts, and initiatives marked as confidential

Employees may have various levels of authorized access to confidential information.

What Employees Should Do

• Lock or secure confidential information at all times.
• Shred confidential documents when they are no longer needed.
• Make sure they only view confidential information on secure devices.
• Only disclose information to other employees when it is necessary and authorized.
• Keep confidential documents inside our company’s premises unless it is necessary to move them.

What Employees Should Not Do

• Use confidential information for any personal benefit or profit.
• Disclose confidential information to anyone outside of our company.
• Replicate confidential documents and files and store them on insecure devices.

When employees stop working for our company, they are obliged to return any confidential files and delete them from their personal devices.

Confidentiality Measures

We will take measures to ensure that confidential information is well protected. We will:

• Store and lock paper documents.
• Encrypt electronic information and safeguard databases.
• Ask employees to sign non-compete and/or non-disclosure agreements.
• Ask for authorization by senior management to allow employees to access certain confidential information.

Exceptions

Confidential information may occasionally have to be disclosed for legitimate reasons. Examples are:

• If a regulatory body requests it as part of an investigation or audit.
• If our company examines a venture or partnership that requires disclosing some information within legal boundaries.

In such cases, employees involved should document their disclosure procedure and collect all needed authorizations. We are bound to avoid disclosing more information than needed.

Disciplinary Consequences

Employees who do not respect our confidentiality policy will face disciplinary and, possibly, legal action.

We will investigate every breach of this policy. We will terminate any employee who willfully or regularly breaches our confidentiality guidelines for personal profit. We may also have to punish any unintentional breach of this policy depending on its frequency and seriousness. We will terminate employees who repeatedly disregard this policy, even when they do so unintentionally.

This policy is binding even after separation of employment.