Bank Technology Oracle: AI Safety, Privacy, and Confidentiality Policy

Introduction

This document outlines the principles and practices of Paladin fs, LLC ("Paladin") concerning the ethical and secure use of our AI Services, including the Bank Technology Oracle (collectively, "AI Services"). Our commitment is to ensure our AI systems are developed and operated with complete confidentiality and safety to build and maintain the trust of our clients. This policy explains how we govern our AI systems, protect your data, and mitigate risks like bias, inaccuracy, and security threats.

Scope of this Policy

This policy applies to all data processed, stored, and analyzed by our AI Services as we provide financial services advisory and solutions to our prospective or current clients. It covers the entire lifecycle of our AI systems, from their development and training to deployment and ongoing monitoring.

Mutual Confidentiality

All services provided by Paladin, including our AI Services, are completely confidential. We will not share your data with other institutions, vendors, or outside parties without your explicit written permission. By using our AI services, your company agrees not to disclose any information we provide to you to outside parties or vendors without our explicit written permission.

Upon written notice from your institution to Paladin we will be destroyed and deleted from our systems.

How We Process Information

Our AI Services process information to provide insights, recommendations, and risk analysis related to financial contracts and vendor pricing. The primary purposes of this processing are:

To analyze complex financial documents and extract key insights.
To provide data-driven pricing estimations and vendor recommendations.
To identify and flag potential risks, compliance issues, or contractual anomalies.
To continuously improve our AI models' accuracy, fairness, and security through validated feedback loops.

Human-in-the-Loop (HITL) Validation

We believe that human expertise is essential for ensuring the reliability of our AI Services. Our Human-in-the-Loop (HITL) process embeds Paladin's Subject Matter Experts (SMEs) directly into the AI review cycle.

Expert Validation: SMEs review and validate AI-generated outputs, such as contract summaries, risk alerts, and pricing recommendations, before they are delivered to you.
Continuous Improvement: Feedback and corrections from our experts are systematically used to retrain our AI models.
Risk Mitigation: This process reduces the risk of errors or "hallucinations" and prevents over-reliance on automated outputs, ensuring that final recommendations are of the highest quality and accuracy.

Responsible AI Governance and Oversight

We have established a Responsible AI Governance Committee, a cross-functional team of experts from Legal, Engineering, Compliance, and other fields, to ensure accountability. The committee's responsibilities include:

Monitoring and mitigating AI risks, including model bias, "hallucinations," and data privacy.
Ensuring our AI practices align with regulatory frameworks like the NIST AI Risk Management Framework.
Addressing any AI-related incidents or concerns.

Data Security and Confidentiality

We implement robust security measures to protect the data processed by our AI Services. Access to sensitive information is strictly controlled and handled in accordance with our contractual obligations and applicable data protection laws.

Policy Updates

We may update this policy to reflect changes in our practices or legal requirements as the field of AI and its regulations evolve. We will notify our clients of any material changes.

Contact Us

For any questions or concerns regarding this policy or our Responsible AI Initiative, please contact our Responsible AI Governance Committee at info@paladin-fs.com or by mail to: Paladin fs, LLC PO Box 660675 #17410 Dallas, TX 75266-0675.

Mutual Non-Disclosure Agreement

Effective Date: August 21, 2025

Purpose

This Agreement establishes the terms under which non-public information will be shared and protected between the parties to maintain its confidentiality during the exploration of a potential business relationship.

Definition of Confidential Information

"Confidential Information" is any non-public information, whether written, oral, or electronic, that is designated as confidential or that a reasonable person would understand to be confidential. This includes, but is not limited to:

Technical Information: Trade secrets, intellectual property, software, and algorithms.
Business Information: Financial data, business plans, and pricing details.
Third-Party Information: Confidential information belonging to a third party that we are obligated to protect.

Confidential Information does not include information that was already known to the receiving party, becomes publicly known through no fault of the receiving party, or is independently developed by the receiving party.

Non-Disclosure Obligations

Both parties agree to the following obligations:

Standard of Care: To protect the other’s Confidential Information with the same degree of care as their own similar information, but no less than a reasonable standard of care.
Limited Use: To use the Confidential Information solely for evaluating the potential business relationship.
Limited Access: To share Confidential Information only with employees, contractors, or advisors who have a need to know and are bound by similar confidentiality obligations.
Legal Compulsion: If legally required to disclose any Confidential Information, the receiving party will provide prompt written notice to the disclosing party to allow them to seek a protective order.

Intellectual Property

Each party retains full ownership of its own Confidential Information and intellectual property.

Term and Termination

The confidentiality obligations under this Agreement remain in effect for five (5) years from the date of disclosure. The duty to protect Confidential Information survives the termination of any business relationship. Upon written request, the receiving party agrees to promptly return or securely destroy all Confidential Information.

General Provisions

This Agreement is governed by the laws of the State of Texas. Any disputes will be resolved through binding arbitration in Dallas, Texas. This Agreement constitutes the entire understanding between the parties concerning the subject matter. A breach may cause irreparable harm, entitling the non-breaching party to seek injunctive relief in addition to other legal remedies.

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