Confidentiality Policy

2025.1

Reviewed: 9/23/2024
Updated: 9/23/2024

Purpose and Scope:

1. This policy outlines expected behavior of employees to keep confidential information about clients, partners, and IMPLAN secure.
2. This policy applies to all employees, board members, investors, and contractors, who may have access to confidential information. This policy must be made readily available to all whom it applies to.

Background:

1. IMPLAN's confidential information must be protected for two reasons:
   a. It may be legally binding (i.e. sensitive customer data)
   b. It may be fundamental to our business (i.e. business processes)
2. Common examples of confidential information in IMPLAN includes, but is not limited to:
   a. Unpublished financial information
   b. Customer/partner/vendor/external party data
   c. Patents, formulas, new technologies, and other intellectual property
   d. Existing and prospective customer lists
   e. Undisclosed business strategies including pricing & marketing
   f. Materials & processes explicitly marked as "confidential"
3. Employees will have varying levels of authorized access to confidential information.

Controls and Procedures

1. Employee procedure for handling confidential information:
   a. Lock and secure confidential information at all times
   b. Safely dispose (i.e. shred) documents when no longer needed
   c. View confidential information only on secure devices
   d. Disclose information only when authorized and necessary
   e. Do not use confidential information for personal gain, benefit, or profit
   f. Do not disclose confidential information to anyone outside IMPLAN or to anyone within IMPLAN who does not have appropriate privileges
   g. Do not store confidential information or replicates of confidential information in unsecured manners (i.e. on unsecured devices)
   h. Do not remove confidential documents from IMPLAN's premises unless approved by senior management.

2. Offboarding measures:
   a. The Hiring Manager should confirm the off-boarding procedure has been completed by the final date of employment.

3. Confidentiality measures:
   a. IMPLAN will take the following measures to ensure protection of confidential information:

   • Store and lock paper documents
   • Encrypt electronic information and implement appropriate technical measures to safeguard databases
   • Require employees to sign non-disclosure/non-compete agreements
   • Consult with senior management before granting employees access to certain confidential information

4. Exceptions:
   a. Under certain legitimate conditions, confidential information may need to be disclosed. Examples include:

   • If a regulatory agency requests information as part of an audit or investigation
   • If IMPLAN requires disclosing information (within legal bounds) as part of a venture or partnership
   • In such cases, the employee must request and receive prior written authorization from senior management before disclosing confidential information to any third parties.

5. Disciplinary consequences:
   a. Employees who violate the confidentiality policy will face disciplinary and possible legal action.
   b. A suspected breach of this policy will trigger an investigation. Intentional violations will be met with termination and repeated unintentional violations may also face termination.
   c. This policy is binding even after the termination of employment.

Privacy Policy

Current Privacy Policy is published at https://implan.com/privacy-policy/

Notice of Privacy Practice

Current Notice of Privacy Practice (NPP) is published at https://implan.com/privacy-policy/

Platform Use Terms and Consent

The Terms of Use and Consent for IMPLAN platform and applications are within the application itself.