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Data Management Policy

Purpose

To ensure that information is classified, protected, retained and securely disposed of in accordance with its importance to the organization.

Scope

All AlignAI Labs, Inc. data, information and information systems.

Policy

AlignAI Labs, Inc. classifies data and information systems in accordance with legal requirements, sensitivity, and business criticality in order to ensure that information is given the appropriate level of protection. Data owners are responsible for identifying any additional requirements for specific data or exceptions to standard handling requirements.

Information systems and applications shall be classified according to the highest classification of data that they store or process.

Data Classification

To help AlignAI Labs, Inc. and its employees easily understand requirements associated with different kinds of information, the company has created three classes of data.

Confidential

Highly sensitive data requiring the highest levels of protection; access is restricted to specific employees or departments, and these records can only be passed to others with approval from the data owner, or a company executive. Example include:

  • Customer Data Personally identifiable information PII Company financial and banking data Salary, compensation and payroll information Strategic plans Incident reports

Risk assessment reports Technical vulnerability reports Authentication credentials Secrets and private keys Source code Litigation data

Restricted

AlignAI Labs, Inc. proprietary information requiring thorough protection; access is restricted to employees with a “need-to-know” based on business requirements. This data can only be distributed outside the company with approval. This is default for all company information unless stated otherwise. Examples include:

  • Internal policies Legal documents Meeting minutes and internal presentations Contracts Internal reports Slack messages Email

Public

Documents intended for public consumption which can be freely distributed outside AlignAI Labs, Inc. Examples include:

  • Marketing materials Product descriptions Release notes External facing policies

Labeling

Confidential data should be labeled “confidential” whenever paper copies are produced for distribution.

Data Handling

Confidential Data Handling

Confidential data is subject to the following protection and handling requirements:

  • Access for non-preapproved roles requires documented approval from the data owner Access is restricted to specific employees, roles and/or departments
  • Confidential systems shall not allow unauthenticated or anonymous access
  • Confidential Customer Data shall not be used or stored in non-production systems/environments
  • Confidential data shall be encrypted at rest and in transit over public networks in accordance with the Cryptography Policy Mobile device hard drives containing confidential data, including laptops, shall be encrypted Mobile devices storing or accessing confidential data shall be protected by a log-on password(or equivalent, such as biometric) or pass code and shall be configured to lock the screen after

five 5) minutes of non-use Backups shall be encrypted Confidential data shall not be stored on personal phones or devices or removable media including USB drives, CD’s, or DVD’s Paper records shall be labeled “confidential” and securely stored and disposed of in a secure, approved manner in accordance with data handling and destruction policies and procedures Hard copy paper records shall only be created based on a business need and shall be avoided whenever possible Hard drives and mobile devices used to store confidential information must be securely wiped prior to disposal or physically destroyed Transfer of confidential data to people or entities outside the company shall only be done in accordance with a legal contract or arrangement, and the explicit written permission of management or the data owner

Restricted Data Handling

Restricted data is subject to the following protection and handling requirements:

  • Access is restricted to users with a need-to-know based on business requirements
  • Restricted systems shall not allow unauthenticated or anonymous access
  • Transfer of restricted data to people or entities outside the company or authorized users shall require management approval and shall only be done in accordance with a legal contract or arrangement, or the permission of the data owner Paper records shall be securely stored and disposed of in a secure, approved manner in accordance with data handling and destruction policies and procedures
  • Hard drives and mobile devices used to store restricted information must be securely wiped prior to disposal or physically destroyed

Public Data Handling

No special protection or handling controls are required for public data. Public data may be freely distributed.

Data Retention

AlignAI Labs, Inc. shall retain data as long as the company has a need for its use, or to meet regulatory or contractual requirements. Once data is no longer needed, it shall be securely disposed of or archived. Data owners, in consultation with legal counsel, may determine retention periods for their data.

Personally identifiable information PII) shall be deleted or de-identified as soon as it no longer has abusiness use.

Retention periods shall be documented in the Data Retention Matrix in Appendix B to this policy.

Data & Device Disposal

Data classified as restricted or confidential shall be securely deleted when no longer needed. AlignAI Labs, Inc. shall assess the data and disposal practices of third-party vendors in accordance with the Third-Party Management Policy. Only third-parties who meet AlignAI Labs, Inc. requirements for secure data disposal shall be used for storage and processing of restricted or confidential data.

AlignAI Labs, Inc. shall ensure that all restricted and confidential data is securely deleted from company devices prior to, or at the time of, disposal.

Confidential and Restricted hard copy materials shall be shredded or otherwise disposed of using asecure method.

Personally identifiable information PII) shall be collected, used and retained only for as long as the company has a legitimate business purpose. PII shall be securely deleted and disposed of following contract termination in accordance with company policy, contractual commitments and all relevant laws and regulations. PII shall also be deleted in response to a verified request from a consumer or data subject, where the company does not have a legitimate business interest or other legal obligation to retain the data.

Annual Data Review

Management shall review data retention requirements during the annual review of this policy. Data shall be disposed of in accordance with this policy.

Under certain circumstances, AlignAI Labs, Inc. may become subject to legal proceedings requiring retention of data associated with legal holds, lawsuits, or other matters as stipulated by AlignAI Labs, Inc. legal counsel. Such records and information are exempt from any other requirements specified within this Data Management Policy and are to be retained in accordance with requirements identified by the Legal department. All such holds and special retention requirements are subject to annual review with AlignAI Labs, Inc.’s legal counsel to evaluate continuing requirements and scope.

Policy Compliance

AlignAI Labs, Inc. will measure and verify compliance to this policy through various methods, including but not limited to, business tool reports, and both internal and external audits.

Exceptions

Requests for an exception to this policy must be submitted to the IT Manager for approval.

Violations & Enforcement

Any known violations of this policy should be reported to the IT Manager. Violations of this policy can result in immediate withdrawal or suspension of system and network privileges and/or disciplinary action in accordance with company procedures up to and including termination of employment.

APPENDIX A Internal Retention and Disposal Procedure

AlignAI Labs, Inc.’s Engineering Team is responsible for setting and enforcing the data retention and disposal procedures for AlignAI Labs, Inc. managed accounts and devices.

Customer Accounts:

  • Customer accounts and data shall be deleted within 60 days of contract termination through manual data deletion processes.

Devices:

  • Employee devices will be collected promptly upon an employee’s termination. Remote employees will be sent a shipping label and the return of their device shall be monitored.

  • Collected devices will be cleared to be re-provisioned—or removed from inventory;, AlignAI Labs, Inc. will securely erase the device when repro visioning.

  • Device images may be retained at the discretion of management for business purposes

Destroying devices or electronic media

In cases where a device is damaged in a way that AlignAI Labs, Inc. cannot access the Recovery Partition to erase the drive, AlignAI Labs, Inc. may optionally decide to use an E Waste service that includes data destruction with a certificate. AlignAI Labs, Inc. will keep certificates of destruction on record for one year. Physical destruction can be optional if it is verified that the device is encrypted with Full Disk Encryption, which would negate the risk of data recovery.

Management will review this procedure at least annually

APPENDIX B Data Retention Matrix

System or Application Data Description Retention Period

AlignAI Labs, Inc. Saa S Products AWS Customer Data Up to 60 days after contract termination

AlignAI Labs, Inc. Auto Support Customer instance and metadata, debugging data Indefinite

AlignAI Labs, Inc. Customer Support Tickets Salesforce) Support Tickets and Cases Indefinite

AlignAI Labs, Inc. Customer Support Phone Conversations Talk Desk) Support Phone Conversations Indefinite

AlignAI Labs, Inc. Security Event Data Splunk Security and system event and log data, network data flow logs

On-Premise - Indefinite

AWS Instance - 1 year

AlignAI Labs, Inc. Vulnerability Scan Data Qualys Vulnerability scan results and detection data

6 months

host (asset) data is retained until removed and purged from Qualys

AlignAI Labs, Inc. Customer Sales Salesforce) Opportunity and Sales Data Indefinite

AlignAI Labs, Inc. QA and Testing Data Test Rail) QA, testing scenarios and results data Indefinite

Security Policies Security Policies 1 year after archive

Temporary Files AWS /tmp ephemeral storage automatically when process finishes

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