Privacy Policy

PRIVACY POLICY

VANE Intelligence LLC
Effective Date: June 26, 2026
Last Updated: June 27, 2026


This Privacy Policy describes how VANE Intelligence LLC ("VANE," "we," "us,"
or "our") collects, uses, shares, and protects information in connection with
our website, Rep dashboard, and visitor identification services
(collectively, the "Platform").

This policy applies to three categories of individuals:
   - Visitors to vaneintelligence.com or any VANE-operated site
   - Sales Representatives ("Reps") who apply for and hold seats in the VANE
     channel program
   - End consumers whose information may be identified through VANE's
     visitor-identification pixel deployed on End Client websites


1. INFORMATION WE COLLECT

1.1. From Website Visitors
We collect basic information from anyone visiting our website, including:
   - IP address and general geographic location
   - Browser type, device type, and operating system
   - Pages visited, time spent, and referral source
   - Cookies and similar tracking technologies (see Section 6)

1.2. From Rep Applicants and Account Holders
When you apply for or hold a Rep account, we collect:
   - Full legal name and date of birth
   - Email address and phone number
   - Mailing address
   - Years of sales experience and other application information
   - Government-issued ID for age and identity verification
   - Tax information (W-9 or equivalent) for tax reporting
   - Payment method information for Seat Fee billing (processed by Stripe;
     VANE does not store full card numbers)
   - Payout information (processed through Stripe Connect or equivalent;
     subject to that provider's KYC process)
   - Login credentials and authentication data
   - Activity within the dashboard, including calls logged, leads worked,
     appointments booked, and call outcomes recorded

1.3. From End Client Websites (Visitor Identification Pixel)
When an End Client deploys VANE's visitor identification pixel on their
website, the pixel may collect or receive the following from website visitors:
   - IP address and approximate geographic location
   - Browser fingerprint and device data
   - Pages visited and behavioral signals
   - Identity attributes returned by third-party data providers, including:
       * Full name
       * Business and personal email addresses
       * Business and personal phone numbers (including DNC status indicators)
       * Employer, job title, and LinkedIn profile
       * Home address
       * Demographic and financial indicators (where available and lawful)

Pixel-identified data is processed and delivered to the End Client whose
website the visitor was on. Pixel-identified data is not delivered to or
accessible by Reps. See Section 3 for further detail on data flows.

VANE acknowledges that the visitor identification process involves processing
personal information from individuals who have not directly interacted with
VANE. VANE relies on the End Client to provide lawful notice and choice to
website visitors as required by applicable law, and on upstream data
providers to source data lawfully.


2. HOW WE USE INFORMATION

2.1. From Website Visitors and Reps
   - To operate, maintain, and improve the Platform
   - To process applications and manage Rep accounts
   - To bill Seat Fees and pay commissions
   - To communicate with you about your account, the program, or service
     updates
   - To comply with legal obligations, including tax reporting
   - To detect, investigate, and prevent fraud, abuse, or violations of our
     Terms and Compliance Policy

2.2. From End Client Visitor Identification
   - To return identification data to the End Client whose website the
     individual visited
   - To enable End Clients to follow up with identified individuals in
     compliance with applicable law
   - To assemble curated outbound call lists for VANE-directed outreach
     conducted by Reps, where such lists are derived from business contact
     information only and have been scrubbed against DNC and internal
     suppression lists
   - To improve the accuracy and performance of identification services in
     aggregate, non-identifying form


3. HOW WE SHARE INFORMATION

We share information only as described below. We do not sell personal
information as "selling" is defined under applicable U.S. state privacy laws.

3.1. With End Clients
Identified visitor data is delivered to the End Client whose website the
visitor was on. End Clients are independent controllers of the data they
receive and bear independent responsibility for their use of it.

3.2. With Reps (Limited Access Tier)
Reps do not receive pixel-identified visitor data. Reps receive only the
limited lead contact information that VANE has assembled, scrubbed, and
assigned to them through the Rep dashboard for the purpose of outbound
calling on VANE's behalf. This limited dataset typically includes business
name, contact name, business phone number, and basic firmographic context.
It excludes personal phone numbers, home addresses, income or financial
indicators, social profiles, and other sensitive identifiers returned by the
pixel. Rep dashboard activity is logged for audit and compliance purposes.

3.3. With Service Providers
We share information with third-party service providers who help us operate
the Platform, including:
   - Hosting and infrastructure (AWS or equivalent)
   - Database providers (MongoDB, Supabase, or equivalent)
   - Payment processing and contractor payouts (Stripe, Stripe Connect)
   - Communications (Twilio, email delivery providers)
   - Identity verification and data providers (AudienceLab via Databtch and
     associated upstream sources)
   - E-signature and document management (Dropbox Sign or equivalent)
   - Analytics and product instrumentation

3.4. With Upstream Data Providers
The visitor identification capability is powered in part by AudienceLab's
SuperPixel technology accessed via the Databtch platform. Information about
website visitors may be processed by these providers and their data partners
in connection with identification.

3.5. For Legal Reasons
We may disclose information if required by law, subpoena, court order, or
governmental request, or where we believe disclosure is necessary to protect
the rights, property, or safety of VANE, our users, or the public.

3.6. Business Transfers
If VANE is involved in a merger, acquisition, financing, or sale of assets,
information may be transferred as part of that transaction. We will notify
affected individuals where required.


4. YOUR RIGHTS AND CHOICES

4.1. California Residents (CCPA / CPRA)
If you are a California resident, you have the right to:
   - Know what categories of personal information we collect and how we use
     it
   - Request access to or a copy of the personal information we hold about
     you
   - Request deletion of your personal information
   - Request correction of inaccurate personal information
   - Opt out of "sale" or "sharing" of personal information (we do not sell;
     we do not knowingly share for cross-context behavioral advertising)
   - Limit use of sensitive personal information
   - Non-discrimination for exercising your privacy rights

To exercise these rights, submit a request to privacy@vaneintelligence.com or
through the opt-out link in the footer of VANE-served pixel disclosures.
We will verify your identity before processing requests.

4.2. Other U.S. State Residents
Residents of states with comprehensive privacy laws (including but not
limited to Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana,
Iowa, Delaware, New Jersey, New Hampshire, and others as they take effect)
have similar rights. Submit requests to privacy@vaneintelligence.com.

4.3. Global Privacy Control (GPC)
VANE recognizes and honors the Global Privacy Control browser signal as an
opt-out request where required by applicable law.

4.4. Do Not Call Registry
VANE scrubs outbound call lists against the National Do Not Call Registry
and applicable state DNC registries before assigning them to Reps. Numbers
flagged with DNC indicators in the underlying pixel data are excluded from
Rep call assignments. Individuals who request no further contact at any
point are added to VANE's internal suppression list and excluded from future
outreach.

4.5. Marketing Communications
You may opt out of VANE marketing emails at any time using the unsubscribe
link in any email, or by emailing privacy@vaneintelligence.com.
Transactional communications (billing, account, security) cannot be opted
out of while you maintain an account.


5. GEOGRAPHIC RESTRICTIONS

VANE's visitor identification services are designed for use in the United
States and Canada only. VANE applies geofencing to suppress identification
of visitors located in the European Union, United Kingdom, and other
jurisdictions with conflicting legal requirements.

If you are accessing the Platform from outside the United States, you
understand that your information will be processed in the United States,
which may have different data protection laws than your country of
residence.


6. COOKIES AND TRACKING

VANE uses cookies and similar technologies on its own website and provides
pixel technology to End Clients for deployment on their websites.

On vaneintelligence.com, we use:
   - Essential cookies (login, session management)
   - Analytics cookies (product usage, traffic measurement)
   - Authentication tokens

On End Client websites, the VANE pixel may collect technical and behavioral
data as described in Section 1.3. The End Client is responsible for posting
notice and providing opt-out choice on their site as required by law.


7. DATA RETENTION

We retain personal information for as long as necessary to:
   - Provide the Platform and services
   - Comply with legal, accounting, and reporting obligations
   - Enforce our agreements and resolve disputes

Rep account data is generally retained for the duration of the account plus
seven (7) years after termination for tax and compliance purposes.

Visitor identification data is retained for the duration of the End Client
relationship plus a reasonable period thereafter, subject to deletion
requests made under applicable law.


8. DATA SECURITY

VANE implements reasonable technical and organizational measures to protect
personal information against loss, misuse, unauthorized access, disclosure,
alteration, and destruction, including:
   - Encryption of data in transit (TLS)
   - Encryption of sensitive data at rest
   - Access controls and authentication requirements
   - Tiered access: Reps receive only the limited lead dataset described in
     Section 3.2; pixel-identified PII is not exposed to Rep accounts
   - Audit logging of Rep dashboard activity
   - Vendor diligence on service providers

No system is perfectly secure. VANE cannot guarantee the absolute security
of information transmitted to or stored on the Platform.


9. CHILDREN'S PRIVACY

The Platform is not intended for or directed to individuals under 18 years
of age. We do not knowingly collect personal information from children. If
you believe we have collected information from a child, contact us
immediately at privacy@vaneintelligence.com and we will delete it.


10. CHANGES TO THIS POLICY

VANE may update this Privacy Policy from time to time. Material changes will
be communicated by email or by posting an updated version with a revised
"Last Updated" date. Your continued use of the Platform constitutes
acceptance.


11. CONTACT US

For privacy questions, requests, or complaints:

VANE Intelligence LLC
Attn: Privacy
322 South College Road #1193
Wilmington, NC 28403
privacy@vaneintelligence.com