Harrow & Vane / Legal

Research Data Policy

Effective November 9, 2026 · Version 1.0

01. Purpose and scope

Harrow & Vane AES Limited Liability Company may undertake research in medical technology, life sciences, assistive communication, cognition and longevity. This policy covers research data handled by authorized staff and collaborators, subject to study protocols, consent forms and applicable law.

02. Data categories

Approved studies may involve participant identifiers, health histories, physiological observations, psychological or cognitive assessments, interviews, autobiographical accounts, authorized communications and recordings, behavioral records, software outputs and experimental measurements.

03. Consent and participant information

Where required, participants receive appropriate information about study purpose, procedures, risks, possible benefits, data categories, AI-related uses, sharing, retention, withdrawal, and any post-mortem processing. Participation is voluntary where required, and consent does not waive non-waivable legal rights.

04. Ethical and regulatory oversight

Research requiring IRB review or other oversight must receive the necessary approval, exemption determination or authorization before starting. Other high-risk work may warrant independent ethical review. Applicable rules depend on study design, funding, institutions, data types and intended use.

05. Minimization and classification

Only information reasonably needed for authorized study objectives should be collected. Data should be classified by sensitivity, including general, internal, confidential and restricted research categories. Identifiable medical, psychological, biometric and cognitive records merit heightened restrictions.

06. Security and access

Access is limited to authorized personnel with a need to know. Appropriate controls may include encryption, multifactor authentication, role-based access, audit logs, restricted exports, secure backups, incident response and periodic access reviews.

07. De-identification and disclosure

Where feasible, records should be de-identified or pseudonymized before analysis, sharing or publication. Re-identification keys should be separated when practical. Pseudonymized information may still be personal data. Publications should avoid identifying participants without proper authorization.

08. AI and computational research

Sensitive participant data is not automatically available for unrelated AI model training. Model development requires an appropriate legal basis, relevant consent or authorization, approved protocol and safeguards. Third-party AI services must be assessed for confidentiality and secondary-use restrictions.

09. Cognitive and memory reconstruction

Research that simulates memories, communication patterns or personality must distinguish demonstrated findings from hypotheses. Computational models do not establish transfer of consciousness or continued personal identity. Protocols should address fabricated memories, impersonation, third-party information, public distribution and participant instructions.

10. Post-mortem information

Research involving use after death requires documented instructions and lawful authority concerning access, preservation and permissible uses. Ordinary research consent does not imply unrestricted post-mortem rights. Family or estate access depends on applicable law and valid authorization.

11. Retention and withdrawal

Study-specific retention schedules should reflect protocol needs, legal duties and participant authorization. Indefinite retention is not the default. Withdrawal may restrict future participation or processing but may not permit removal of completed analyses, legally retained records or appropriately de-identified data.

12. Integrity and incidents

Fabrication, falsification and misleading presentation of results are prohibited. Security incidents are investigated and notified as required. Research-stage systems must not be represented as clinically validated or regulator-approved without support.

13. Governance and contact

The Company should designate responsible research data governance personnel. Participant requests and concerns may be directed to the research contact published on the official website; this contact must be confirmed before the policy is published.

Harrow & Vane AES Limited Liability Company · End of policy