Responsible AI & Privacy Policy

Effective Date: April 14, 2026

At Spencer & Associates, trust is the foundation of our work. We partner with leaders, organizations, and institutions at moments that often require clarity, discretion, and thoughtful stewardship. As part of that commitment, we use technology responsibly and handle personal information with care.

This policy explains how we may use artificial intelligence (“AI”) tools in our work, how we manage personally identifiable information (“PII”) and other personal information, and the principles that guide our approach to confidentiality, privacy, and responsible innovation.

Spencer & Associates is committed to using technology in a way that aligns with our values: integrity, discretion, excellence, and human-centered leadership.

We may use AI-enabled tools to support internal efficiency, research, drafting, workflow organization, and strategic development. However, we do not use AI as a substitute for professional judgment, trusted advisory relationships, or ethical responsibility.

Our approach is grounded in five core commitments:

Human Oversight

Important decisions, recommendations, and deliverables remain subject to human review and judgment.

Respect for Privacy

We seek to protect the personal and confidential information entrusted to us.

Purpose-Driven Use

We use information only for legitimate, defined business or service-related purposes.

Confidentiality

We handle client and stakeholder information with care, restraint, and professionalism.

Integrity

We aim to be transparent and responsible in how we use digital tools.

Spencer & Associates may use AI tools to support certain business and client-service functions, including:

• Drafting or refining written materials
• Organizing notes, ideas, and working documents
• Summarizing non-sensitive information
• Supporting brainstorming and concept development
• Enhancing internal workflow efficiency
• Assisting with research, synthesis, and pattern recognition

AI is used as a support tool only. Final client-facing recommendations, strategic guidance, and deliverables are reviewed through human judgment before they are shared or relied upon.

We do not use AI to replace trusted advisory judgment or confidential discernment.

We do not knowingly use AI to:

• Make fully automated decisions about individuals in high-impact matters
• Override confidentiality obligations
• Process highly sensitive personal information without a clear need and appropriate safeguards
• Present unreviewed AI output as final professional advice
• Misrepresent AI-generated content as unquestioned fact
• Use client information beyond the purpose for which it was provided

We recognize that AI-generated content may be incomplete, inaccurate, biased, or outdated. For that reason, meaningful outputs require human review.

For purposes of this policy, “personally identifiable information” or “personal information” refers to information that identifies, relates to, describes, or can reasonably be linked to an individual.

This may include:

• Full name
• Email address
• Phone number
• Mailing address
• Business or employment information
• Financial or billing information
• Online identifiers
• Project materials or correspondence linked to an individual
• Client intake or engagement-related information

We may also handle confidential business information shared with us in the course of consulting, strategy, advisory, or client-development work.

Some categories of information require heightened care. These may include:

• Government identification numbers
• Financial account details
• Health-related information
• Precise location data
• Other highly personal or legally sensitive information

As a general practice, Spencer & Associates seeks to avoid entering highly sensitive personal information into AI-enabled systems unless there is a legitimate business need and an appropriate level of protection.

We aim to collect, use, and retain only the information reasonably necessary to support our services, business operations, and client relationships.

Whenever possible, we limit the use of direct identifiers and avoid unnecessary sharing or processing of personal information. We believe thoughtful restraint is part of responsible leadership and ethical stewardship.

Confidentiality is central to the work we do. Clients often engage Spencer & Associates during periods of transition, growth, complexity, or strategic sensitivity. We honor that trust by treating client information with seriousness and discretion.

Depending on the nature of the engagement, we may take steps such as:

• Limiting access to authorized individuals
• Reducing or removing direct identifiers where appropriate
• Separating internal working materials from final approved deliverables
• Using tools and service providers selected with care
• Restricting data use to legitimate business and service-delivery needs

We do not sell client confidential information.

Spencer & Associates maintains reasonable administrative, technical, and operational safeguards designed to protect personal and confidential information from unauthorized access, misuse, disclosure, or loss.

These practices may include:

• Secure password and account practices
• Access controls and need-to-know limitations
• Thoughtful vendor selection
• Document and communication management practices
• Periodic review of internal workflows and digital tools

While no system can guarantee absolute security, we are committed to taking reasonable and appropriate steps to protect the information entrusted to us.

We may use trusted third-party platforms and service providers to support communications, scheduling, document creation, payments, hosting, and workflow efficiency. Some of these tools may include AI-enabled features.

When we work with third-party providers, we seek to do so in a manner consistent with our professional standards, confidentiality expectations, and business values.

We strive to keep information reasonably accurate and to communicate honestly about our practices.

Where AI supports part of our workflow, we apply review, discernment, and judgment before using outputs in client work or business decisions. We do not treat machine-generated content as inherently correct.

Accuracy, nuance, and context still require human care.

We retain personal information and client-related records only for as long as reasonably necessary for business, contractual, legal, compliance, or recordkeeping purposes.

After that, information may be deleted, de-identified, archived as appropriate, or securely disposed of.

We do not seek to retain personal information indefinitely without purpose.

Depending on applicable law and the nature of your relationship with us, you may have the right to request access to, correction of, or deletion of certain personal information, subject to legal and operational limitations.

If you have questions about how Spencer & Associates handles personal information, confidentiality, or responsible technology use, please contact us directly.

Spencer & Associates LLC

Website: spencerpogue.com

Email: info@spencerpogue.com

Phone: (202) 556-1495

We may update this policy from time to time to reflect changes in business practices, service offerings, technology use, or legal obligations. When updates are made, the revised version will be posted with a new effective date.