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Privacy Policy

Internal privacy policy describing how personal data is collected, processed, stored, and shared by the company.

PrivacyPublished

Current version · v3.5

Effective 9/15/2025 — approved by CEO

Privacy Policy

1. Purpose

This privacy policy establishes the requirements, responsibilities, and expectations governing how AC5 Labs Demo Co protects information assets, manages risk, and meets its contractual and regulatory obligations. It applies to all employees, contractors, interns, and third parties acting on behalf of the company.

2. Scope

This policy covers all information systems, devices, networks, facilities, and data — whether owned, leased, or operated under contract — that are used to conduct company business. It applies regardless of location and includes remote work, customer environments, and bring-your-own-device arrangements.

3. Roles & Responsibilities

The General Counsel owns this policy and is accountable for its content, approval cycle, and exceptions. Department heads are responsible for operationalizing the policy within their teams and ensuring relevant personnel attest within thirty (30) days of hire and annually thereafter.

4. Policy Statements

4.1 The company shall maintain documented controls aligned with the cross-referenced framework requirements listed at the end of this policy.

4.2 Exceptions to this policy must be requested in writing, justified by a documented business need, time-bound, and approved by the policy owner. All approved exceptions shall be logged and reviewed at least annually.

4.3 Violations of this policy may result in disciplinary action up to and including termination of employment or contract, and where applicable, civil or criminal penalties.

5. Compliance & Enforcement

Compliance is verified through periodic internal audits, automated control testing where feasible, and external assessment as part of the company's overall compliance program. Non-conformities will be tracked through the corrective action process and reported to executive leadership monthly.

6. Review

This policy is reviewed at least annually, or sooner if material changes occur in the business, technology environment, or applicable regulations. The reviewer captures changes in the version history and re-attestation is required when a substantive update is published.

Document control: POL-PR-001 v3.5 · Approved per the version history below.

Version history

2 versions on record

  1. v3.5current
    9/15/2025

    Added EU-US Data Privacy Framework references and DPIA triggers.

    Approved by CEO

  2. v3.4obsolete
    9/10/2024

    CPRA harmonization.

    Approved by CEO

Status
Published
Version
v3.5
Effective
9/15/2025
Next review
9/15/2026
On track

Attestation status

Completed8/11 (73%)

Cross-references

Related framework controls

GDPR Art. 5CCPA §1798.100ISO 27701 7.2.1SOC 2 P1.1

Distribution list

Owner: General Counsel

  • All employees
    Last reminded 4/2/2026
    142
  • Marketing
    Last reminded 4/2/2026
    11
  • Customer success
    Last reminded 4/2/2026
    14