Confidentiality

Confidentiality is foundational to how Axiovantage operates. This Statement describes the principles and practices we apply to client information, engagement relationships, and the work we perform.

1. Scope

This Statement applies to information we receive from clients, prospective clients, counterparties, and third parties in connection with an actual or potential engagement (collectively, “Confidential Information”). It supplements, and does not replace, any separate non-disclosure or engagement agreement.

2. What We Treat as Confidential

Confidential Information includes, without limitation:

• Business plans, financial information, and commercial strategy;
• Payment volumes, cost structures, and vendor relationships;
• Technical architecture, source code, and cryptographic material;
• Regulatory correspondence and legal matters;
• Psrsonnel information, internal communications, and meeting content;
• Any information marked or identified as confidential, or that a reasonable person would understand to be confidential from its nature or circumstances of disclosure.

3. Exclusions

Confidential Information does not include information that:

• Is or becomes publicly known through no fault of Axiovantage;
• Was rightfully in our possession before disclosure without confidentiality obligation;
• Is independently developed by Axiovantage without reference to client information;
• Is rightfully received from a third party not bound by confidentiality.

4. How We Handle Confidential Information

We apply the following practices:

• Need-to-know access. Confidential Information is shared only with personnel and advisors who require it to perform the engagement.
• Reasonable safeguards. We use administrative, technical, and physical measures appropriate to the sensitivity of the information.
• Purpose limitation. We use Confidential Information only to perform the engagement and discharge our professional obligations.
• No personal use. Personnel may not use Confidential Information for personal benefit, including securities trading or investment decisions.

5. Permitted Disclosure

We may disclose Confidential Information only:

• With the client’s written consent;
• To our professional advisors bound by confidentiality;
• To subcontractors and service providers under written confidentiality obligations;
• Where required by law, subpoena, court order, or regulatory process, and then only after providing the client prompt notice where legally permitted so they may seek a protective order.

6. Conflicts of Interest

We maintain processes to identify, disclose, and manage potential conflicts of interest. We do not simultaneously advise directly competing parties on the same matter without informed written consent.

7. Public References

We do not disclose the identity of, or our work for, any client publicly — including in marketing, publications, or case studies — without prior written consent. This restraint survives termination of the engagement.

8. Client Ownership

As between the parties, the client owns its Confidential Information. We claim no right in it beyond the limited right to use it to perform the engagement.

9. Return or Destruction

Upon completion of the engagement, or at the client’s written request, we will return or destroy Confidential Information in our possession, subject to legal and professional retention requirements and backup retention in the ordinary course of business.

10. Duration

Confidentiality obligations survive termination of the engagement. They apply indefinitely to trade secrets and cryptographic material, and for a period not less than five (5) years for other Confidential Information, unless a signed engagement letter provides otherwise.

11. Not Legal Advice

This Statement describes our policy and does not itself create an advisory relationship or confer legal privilege. Contractual confidentiality obligations are established in our engagement letters and non-disclosure agreements.

12. Contact

Too request a mutual non-disclosure agreement or to raise a confidentiality concern, write to hello@axiovantage.com.