Confidentiality Policy.

Confidential by default.

Wind-downs are sensitive. The conversations that surround them — board members deciding to stop following on, founders facing payroll, lenders weighing remedies, counsel scoping fiduciary exposure — are sensitive in ways that other professional engagements are not. We treat them that way.

Our default is that everything you tell us, send us, or surface in conversation with us is confidential. We do not surface our involvement to a company without authorization. We do not name clients to other clients. We do not publish case studies that identify a former engagement. The exceptions to this default are narrow, and we name them in §§ VII and VIII below.

Before you retain us.

From the moment you submit a Confidential Intake or send us a question by email, the conversation is confidential. We treat it that way before you sign anything.

What this means in practice

• The Triage AI memo runs inside a private operational workspace. The information you provide does not flow into third-party AI training pipelines or public chatbots.
• Initial conversations with VC partners, board observers, or counsel are kept confidential from the company's management team unless and until you authorize us to engage with management directly.
• Founder-initiated intakes are kept confidential from the company's investors unless and until you authorize disclosure.
• Counsel-initiated conversations are kept confidential from the parties counsel represents unless counsel authorizes the discussion.
• If we decline to take on the matter, we delete intake materials on request. The conversation remains confidential.

Pre-engagement confidentiality is policy and practice; it does not, by itself, create an attorney-client privilege. If you need privileged advice on the situation before retaining us as Assignee or as financial advisor, retain counsel — your existing counsel or new counsel — and route the conversation through them.

Mutual NDA.

Every Graveyard.vc engagement letter includes a mutual confidentiality provision covering both directions:

• We will not disclose your confidential information except as required to perform the engagement (or as required by law, regulation, or fiduciary duty)
• You will not disclose our methodology, the Buyer Graph, the Triage AI outputs, the engagement letter terms, or other confidential information about how the engagement is run, except where the underlying transaction or fiduciary record requires it

The provision continues to apply for the duration of the engagement and for a defined period afterward — typically multiple years — as set out in each engagement letter.

Founders, investors, and counsel.

A common situation: an investor reaches out to us about a portfolio company before the founder is ready to have the conversation. Or a founder reaches out before the board has been notified. Or counsel scopes a wind-down before the client is told the recommendation is to wind down.

We respect each of these dynamics. We do not surface intake conversations to other parties without explicit authorization from the person who initiated the conversation. We do not "tip off" management. We do not leak founder concerns to investors. We are scrupulous about who knows what — and at what point in the process.

Once an engagement is signed and the wind-down is underway, communication has to flow more openly among stakeholders to do the work. The engagement letter sets out who is in the loop on what.

Where the AI sits.

The Triage AI memo and other AI-assisted workstreams run inside a private operational workspace under appropriate confidentiality and data-handling terms. Your information is not used to train external models, is not sent to public chatbots, and is not sold or shared with model vendors for any purpose beyond the engagement itself.

If you have specific concerns about AI involvement on a particular engagement, raise them at intake. We can discuss what is and is not feasible given the workstreams involved, and we will document any specific carve-outs in the engagement letter.

The "may express full opinions" problem.

The standard legacy-assignee engagement letter contains a clause stating that the assignee "may express full opinions" about the assignor and the assignment. There is no reciprocal restriction on the assignee. The result is a one-way confidentiality posture that allows the firm to characterize a former client publicly.

Our engagement letter does not work that way. The confidentiality provision is mutual, narrowly scoped, and bilateral. We do not retain a right to "express opinions" about former clients, the assignment, or the underlying business. We bind ourselves to the same confidentiality posture we ask of you.

The narrow exceptions.

There are circumstances in which we are required to disclose information regardless of the confidentiality framework. We name them clearly here so they are not surprises:

• Creditor notice. California law requires the Assignee in an ABC to notify creditors and certain parties in interest of the assignment. The notice contains limited information; it is not a public characterization of the underlying business.
• Court orders, subpoenas, and regulatory process. If we are validly compelled to produce information, we comply. Where we can, we notify you in advance so you can object.
• Fiduciary obligations. Acting as Assignee, we owe duties to creditors. If continued confidentiality with one stakeholder would breach a duty to another, the duty governs.
• Bar and ethics rules. LegalForce RAPC attorneys participating in an engagement are subject to California Rules of Professional Conduct, including duties of candor and disclosure that may override otherwise-confidential treatment.
• Misconduct disclosures. If, in the course of an engagement, we discover what we believe to be active fraud, asset misappropriation, or other illegal conduct, our obligations as Assignee may require disclosure to creditors, the court, or regulators.

These exceptions are real but narrow. Day-to-day, the default of confidentiality holds.

What happens after closing.

After an engagement closes — final distribution made, ledger reconciled, records preserved — confidentiality continues. Specifically:

• Records are retained per California law and the engagement letter (typically multiple years following final distribution)
• Records remain accessible to former parties in interest as required by law
• We do not publish identifying case studies or testimonials
• We do not name former clients to current clients
• We do not characterize former engagements in marketing or press without explicit, separate authorization

Who at the firm sees what.

Within Graveyard.vc and LegalForce RAPC, access to confidential engagement information is limited to the practitioners directly involved in the matter. Engagement files are not visible firm-wide. Cross-pollination of information between matters is constrained through a combination of access controls, ethical-wall procedures, and practitioner conduct.

Where conflicts of interest could arise — for example, if a current client overlaps with a prior client's matter — we screen for them at the engagement-letter stage and apply ethical-wall procedures where appropriate.

Incident response.

If we become aware of an unauthorized disclosure of confidential information — whether through a security incident, a vendor incident, or a human error — we will notify you promptly, investigate the cause, contain the disclosure where possible, and report to any required regulators. The engagement letter sets out the specific notification timelines that apply during a live engagement.

How to reach us.

For confidentiality questions or concerns, email team@graveyard.vc. We respond personally, not from a queue.