PRIVACY POLICY

N2Open Capital LLC d/b/a N2Open Digital

Effective Date: 07/28/2025

Last Updated: 07/28/2025

1. INTRODUCTION

N2Open Capital LLC, doing business as N2Open Digital ("N2Open Digital," "we," "us," or "our"), is committed to protecting the privacy and security of personal information. This Privacy Policy describes how we collect, use, disclose, and protect information when you use our services, including our LeadBROKER IO platform and related AI automation services.

Our Business Address:

3114 Ivy DR

Loveland, CO 80537

United States

Contact Information:

Email: [email protected]

Phone: 970-213-2700

2. SCOPE AND APPLICATION

This Privacy Policy applies to:

  • Our LeadBROKER IO SaaS platform

  • AI services including Voice AI, Chatbots, and Reputation Management

  • Custom process automation services

  • Digital transformation consulting services

  • Our corporate websites and marketing materials

Important Note: N2Open Digital primarily serves as a data processor for financial lending organizations. Most personal data processed through our platforms belongs to our business customers (lending organizations) who act as data controllers. This Privacy Policy addresses both our direct data collection and our role as a service provider.

3. INFORMATION WE COLLECT

3.1 Information We Collect Directly

Business Customer Information:

  • Contact details (names, email addresses, phone numbers)

  • Company information and business details

  • Account credentials and authentication data

  • Payment and billing information

  • Communication preferences and history

Platform Usage Data:

  • Log files and system activity

  • Performance metrics and analytics

  • User interaction data within our platforms

  • Technical information (IP addresses, browser types, device information)

3.2 Information Processed on Behalf of Customers

As a data processor for lending organizations, we may process:

  • Borrower personal and financial information

  • Loan application data and documentation

  • Voice recordings for compliance and quality purposes

  • Business process data and workflows

  • Document management and e-signature data

Important: We do not control how this data is collected or used. Our lending customers are responsible for obtaining appropriate consents and providing privacy notices to their customers.

3.3 Automatically Collected Information

  • Cookies and tracking technologies

  • Website analytics and usage patterns

  • System logs and error reports

  • Performance and security monitoring data

4. HOW WE USE INFORMATION

4.1 Our Business Operations

We use information we collect directly for:

  • Providing and maintaining our services

  • Processing payments and billing

  • Customer support and communication

  • Platform improvements and AI capability enhancement

  • Marketing our services (with consent)

  • Legal compliance and security

4.2 Data Processing Services

When processing data on behalf of customers:

  • We follow customer instructions and contractual obligations

  • Data is used solely to provide requested services

  • We implement appropriate security and confidentiality measures

  • We may use aggregated, de-identified data to improve our AI capabilities

5. INFORMATION SHARING AND DISCLOSURE

5.1 Third-Party Service Providers

We may share information with:

  • Cloud storage providers (Google Cloud, AWS)

  • Third-party integrations and APIs as requested by customers

  • Payment processors and billing services

  • Analytics and monitoring services

  • Professional service providers (legal, accounting)

5.2 Legal Disclosures

We may disclose information when required by:

  • Legal process or court orders

  • Government investigations or regulatory requirements

  • Protection of our rights, property, or safety

  • Prevention of fraud or illegal activities

5.3 Business Transfers

Information may be transferred in connection with mergers, acquisitions, or asset sales, subject to confidentiality protections.

6. DATA SECURITY

We implement comprehensive security measures including:

  • Encryption of data in transit and at rest

  • Access controls and authentication systems

  • Regular security assessments and monitoring

  • Employee training on data protection

  • Incident response procedures

Note: While we maintain industry-standard security practices, no system is completely secure. We cannot guarantee absolute security of information.

7. DATA RETENTION

7.1 Our Business Data

We retain business customer information for as long as necessary to provide services and comply with legal obligations.

7.2 Customer-Controlled Data

For data processed on behalf of lending customers:

  • Retention periods are determined by our customers

  • Voice recordings may be retained indefinitely for compliance purposes

  • We follow customer instructions for data deletion

  • Some data may be retained for legal compliance requirements

8. YOUR RIGHTS AND CHOICES

Depending on your location and relationship with us, you may have rights including:

  • Access to your personal information

  • Correction of inaccurate data

  • Deletion of personal information

  • Data portability

  • Opt-out of marketing communications

For Data Processed on Behalf of Customers: If you are an end-user of our customer's services, you should contact the lending organization directly regarding your data rights.

To exercise rights regarding our direct data collection, contact us at [email protected].

9. COOKIES AND TRACKING

We use cookies and similar technologies for:

  • Essential platform functionality

  • Analytics and performance monitoring

  • Personalization and user preferences

  • Marketing and advertising (with consent)

You can control cookie settings through your browser, though some features may not function properly if cookies are disabled.

10. INTERNATIONAL DATA TRANSFERS

We operate within the United States and use US-based service providers. If we transfer data internationally, we implement appropriate safeguards such as standard contractual clauses or other legally recognized mechanisms.

11. CHILDREN'S PRIVACY

Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If we become aware of such collection, we will delete the information promptly.

12. CALIFORNIA PRIVACY RIGHTS

California residents may have additional rights under the California Consumer Privacy Act (CCPA), including:

  • Right to know what personal information is collected

  • Right to delete personal information

  • Right to opt-out of sale of personal information

  • Right to non-discrimination

We do not sell personal information as defined by CCPA.

13. CHANGES TO THIS POLICY

We may update this Privacy Policy periodically. We will notify you of material changes by:

  • Posting updated policy on our website

  • Email notification to business customers

  • In-platform notifications as appropriate

Your continued use of our services after changes constitutes acceptance of the updated policy.

14. CONTACT INFORMATION

For privacy-related questions or concerns:

N2Open Digital Privacy Officer

3114 Ivy DR

Loveland, CO 80537

Email: [email protected]

Phone: 970-213-2700

For general business inquiries: [email protected]

This Privacy Policy is effective as of 07/28/2025 and governs the collection, use, and disclosure of information by N2Open Capital LLC d/b/a N2Open Digital.

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