Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how [Insert Legal Company Name], LLC, a company organized under the laws of the State of Florida, United States, operator of the Track.bi.ai platform ("Track.bi.ai", "we", "our platform"), a software-as-a-service (SaaS) platform focused on real estate data intelligence and analytics, collects, uses, stores, shares, and protects the personal data of its users ("you", "data subject").

As a company registered in the United States that serves users in multiple countries, this Policy seeks to observe applicable United States privacy legislation (including, where applicable, state privacy laws such as the California Consumer Privacy Act — CCPA/CPRA), as well as, by reason of its extraterritorial application, Brazil's General Data Protection Law (Law No. 13,709/2018 — LGPD) for data subjects located in Brazil, and the European Union General Data Protection Regulation (GDPR), where applicable to data subjects located in the European Economic Area.

By creating an account, accessing, or using the Track.bi.ai platform, you represent that you have read, understood, and agreed to the terms described herein.

2. Collection of Personal Data

Track.bi.ai collects personal data at different points in the relationship with the user, always limited to what is necessary for the provision of the service. The principal data collected include:

a) Data provided upon registration

• Full name;
• Email address;
• Telephone number (when provided);
• Company name and job title (where applicable);
• Access password (stored in encrypted form).

b) Billing and payment data

• Billing data, such as tax address and tax identification document applicable to the user's country (e.g., CPF/CNPJ for users in Brazil, EIN/SSN where applicable to users in the United States);
• History of subscriptions, contracted plans, and invoices issued.

Important: Track.bi.ai does not store complete credit card data or sensitive financial information on its own servers. Payment processing is performed entirely by Lemon Squeezy, our payment processor and Merchant of Record, which maintains its own privacy policy and security certifications (such as PCI-DSS).

c) Browsing and platform usage data

• IP address;
• Browser type and version and operating system;
• Access logs, date and time of login;
• Pages and features accessed within the platform;
• Session identifiers and cookies (see Section 5).

d) Support and communication data

• Records of interactions with our technical support team (emails, chats, tickets);
• Feedback and satisfaction surveys;
• Telephone number (WhatsApp), when voluntarily provided for receipt of product news and updates, subject to explicit consent and opt-out available at any time.

3. Purpose of Collection

The personal data collected are used exclusively for the following purposes:

• Service provision:to enable the operation of the user's account, access to real estate analytics tools, and the contracted features;
• Subscription billing: to process payments, issue invoices, and manage plan renewals or cancellations;
• Technical support: to identify, diagnose, and resolve issues reported by users;
• Account security: to prevent unauthorized access, detect suspicious activity, and protect the integrity of the platform and the data stored therein;
• Operational communications: sending essential notices regarding the service, such as contractual changes, scheduled maintenance, security updates, and payment confirmations;
• Marketing communications (subject to consent): sending product news and market insights by email or WhatsApp, only when the user provides explicit consent therefor;
• Continuous product improvement: aggregated and statistical analysis of platform usage to improve features (whenever possible, in anonymized form).

Track.bi.ai does not use personal data for purposes incompatible with those described above without the prior consent of the data subject, except where required by legal or regulatory obligation.

4. Distinction Between Personal Data and Public Real Estate Data

It is essential to clarify the distinct nature of the information processed by Track.bi.ai:

4.1.The personal data processed under this Policy refer exclusively to information related to the identification and use of the user's platform account (name, email, billing data, access logs, etc.), as described in Section 2.

4.2.The real estate data made available and processed by the tool — such as tax deeds records, tax assessments ("assessments"), zoning information, emergency/flood management data (FEMA), property history, cadastral real estate data, and other public records — currently relate to properties located in the State of Florida, United States(coverage of the state's 67 counties, with planned expansion to other U.S. states), and are obtained exclusively from U.S. governmental public sources (Property Appraiser's Office, Tax Collector, Clerk of Court, municipal/county zoning authorities, and other official U.S. public repositories).

4.3. Such real estate data do not constitute confidential personal data of Track.bi.ai users, nor are they owned by the users. They are public-domain information relating to third-party property owners, processed by Track.bi.ai solely for the purposes of aggregation, organization, and provision of real estate market intelligence.

4.4. Track.bi.ai acts as an organizer and processor of pre-existing public data and is not responsible for the accuracy, currency, or original veracity of the information contained in the governmental databases consulted, although it makes reasonable efforts to keep the data updated and intact.

5. Sharing of Data with Third Parties

Track.bi.ai does not sell, rent, or commercialize its users' personal data to third parties for marketing purposes or any other purpose unrelated to the provision of the service.

Personal data may be shared, on a limited and strictly necessary basis, with the following types of partners:

• Lemon Squeezy, our payment processor and Merchant of Record, to enable subscription billing and invoice issuance;
• Cloud infrastructure and hosting providers (e.g., VPS servers, transactional email providers), for secure data storage and operational continuity of the platform;
• Traffic and performance analytics tools (e.g., Google Analytics or similar), for usage monitoring and improvement of the user experience;
• Support and communication service providers (e.g., transactional email platforms, WhatsApp Business, customer service systems), strictly for users who consent to that communication channel;
• Public or judicial authorities, when required by law, court order, or request of a competent authority, whether in the United States or in another applicable jurisdiction.

All of the aforementioned third parties are contractually obligated to treat the data with the same level of confidentiality and security required by Track.bi.ai, using the information exclusively for the purpose for which it was shared.

6. Use of Cookies and Tracking Technologies

Track.bi.ai uses cookies and similar technologies to ensure the proper and secure operation of the platform. The principal types used are:

• Session cookies: essential to keep the user authenticated during use of the platform, and automatically removed at the end of the session;
• Security cookies:used to detect suspicious behavior, prevent fraud, and protect the user's account against unauthorized access;
• Performance and analytics cookies: collect statistical and anonymous information about use of the platform, enabling identification of usability and performance improvements.

The user may manage or disable cookies directly in their browser settings. However, disabling certain essential cookies may impair the proper operation of the platform.

7. Storage and Information Security

Track.bi.ai adopts technical and organizational measures consistent with industry best practices to protect personal data against unauthorized access, loss, alteration, or breach, including, among others:

• Encryption of data in transit (TLS/SSL) and, where applicable, at rest;
• Role-based access control (RBAC), restricting internal access only to authorized personnel and on a need-to-know basis;
• Storage of passwords by means of secure hashing algorithms, without access to the password in plain text;
• Continuous security monitoring and audit records (logs);
• Periodic backups and business continuity plans;
• Regular vulnerability assessments and testing of the infrastructure.

In the event of a security incident that may entail a relevant risk to data subjects, Track.bi.ai undertakes to notify affected users and the competent authorities in accordance with the timeframes and criteria established by law — including, where applicable, Brazil's National Data Protection Authority (ANPD), for data subjects located in the country, and the competent U.S. state authorities.

8. Rights of the Data Subject

Depending on your location, the data subject has rights that may include, under applicable law (LGPD, CCPA/CPRA, GDPR, or another pertinent state/national privacy law):

• Confirmation and access: to obtain confirmation of the existence of processing and access to their personal data;
• Correction: to request correction of incomplete, inaccurate, or outdated data;
• Deletion and withdrawal of consent: to request deletion of personal data processed on the basis of consent, as well as to withdraw previously given consent, without prejudice to the lawfulness of processing carried out beforehand;
• Portability: to request portability of account data to another service provider, upon express request;
• Objection: to object to processing carried out in nonconformity with applicable law;
• Non-discrimination: not to suffer discriminatory treatment for exercising any of the rights above (a right expressly provided by CCPA/CPRA);
• Information regarding sharing: to obtain information about the public and private entities with which Track.bi.ai has shared their data.

To exercise any of these rights, the user may contact us through the official channel:

✉ [email protected]

Requests will be reviewed and responded to within the timeframes established by the legislation applicable to the data subject's location, and Track.bi.ai may request additional information to confirm the requester's identity before processing the request.

9. Updates to this Privacy Policy

Track.bi.ai may update this Policy periodically in order to reflect changes in its data processing practices, applicable law, or its features.

In the event of material changes, users will be notified by means of:

• A prominent notice within the platform itself; and/or
• Communication by email to the address registered on the account.

The "last updated" date indicated at the beginning of this document will always be revised with each newly published version. Users are encouraged to review this Policy periodically. Continued use of the platform after the changes take effect constitutes tacit acceptance of the new terms.

10. Contact

For questions regarding this Privacy Policy or the processing of personal data carried out by Track.bi.ai, please contact:

✉ Email: [email protected]

⌂ Legal Name: [Insert Legal Company Name], LLC

⚑ Address: [Insert Registered Address, Orlando, FL, United States]