DATA SHARING & NON-IDENTIFICATION AGREEMENT

Provider: Nebula Genesis Tech, LLC (“Nebula”)
Recipient: [Full Legal Name of Partner/Institution] (“Partner”)

1. Purpose

The purpose of this Agreement is to enable animal public health surveillance, disease trend monitoring, and veterinary research consistent with the disclosures in Nebula’s Privacy Policy.

2. Nature of Data

Nebula will provide data solely in aggregated and de-identified form. All data has been processed in accordance with the HIPAA Safe Harbor standard (45 CFR 164.514(b)) or an equivalent methodology. Nebula applies a minimum 5-record threshold to all geographic, breed, or temporal clusters to prevent re-identification.

3. Strict No Re-Identification Clause (The “Moat”)

Partner expressly agrees and warrants:

• Partner shall not attempt, directly or indirectly, to re-identify any individual user, pet, or veterinary professional from the data.
• Partner shall not link, cross-reference, or combine Nebula data with any other dataset (public or private) that could reasonably lead to re-identification.
• Partner acknowledges that re-identification attempts using “adversarial external data” (including social media scraping, public records, or any other external source) constitute a material breach and a violation of Nebula’s trade-secret protections.

4. Security & Governance

Partner must maintain administrative, technical, and physical safeguards at least as stringent as those described in Nebula’s Non-Binding Technical Overview. Partner shall notify Nebula within 72 hours of any actual or suspected unauthorized access, breach, or potential re-identification event. Nebula retains the right to audit Partner’s data-handling practices upon reasonable notice.

5. Data Destruction & Termination

Upon termination of the partnership, completion of the research project, or Nebula’s written request, Partner shall permanently destroy all Nebula-provided data and certify such destruction in writing within 30 days. No rights to the data survive termination except for de-identified summary results already published in peer-reviewed journals.

6. Indemnification

Partner shall indemnify, defend, and hold Nebula Genesis Tech, LLC, its affiliates, officers, directors, employees, and agents harmless from any claims, fines (including GDPR or CCPA penalties), losses, or damages arising from Partner’s breach of the re-identification prohibition or any other obligation under this Agreement.

7. Governing Law & Dispute Resolution

This Agreement is governed by Illinois law. Any dispute shall be resolved in accordance with the arbitration and class-action waiver provisions set forth in Nebula’s Terms of Service (Section 11). The prevailing party shall be entitled to recover reasonable attorneys’ fees and costs.

8. General Provisions

This Agreement constitutes the entire understanding between the parties regarding the subject matter and supersedes all prior agreements. If any provision is held invalid, the remainder shall continue in full force. This Agreement may be executed electronically and in counterparts.

Version 1.0 • February 21, 2026