Effective date: September 21st, 2026

OPEN TO CLOSE is committed to protecting your privacy. We collect, use, store, and share information only as described in this Privacy Policy and as necessary to provide, secure, maintain, and improve the Service. We do not sell your personal information or Google user data, and we do not use Google user data for advertising. Where information must be processed by service providers on our behalf — including the artificial intelligence providers described below — it is provided only as necessary to deliver the applicable functionality.

Introduction

OPEN TO CLOSE Inc. and its affiliates ("OPEN TO CLOSE") are 100% committed to protecting the privacy of all individuals who:

• Access OPEN TO CLOSE's website which is located at https://opentoclose.ai. This also includes any & all sub-domains, present and future (referred to as the "Website");
• Use the online services including OPEN TO CLOSE any other OPEN TO CLOSE products and services, including any AI-powered features (referred to as the "Service"); and

This privacy policy has been compiled to better serve those who are concerned with how their 'Personally identifiable information' (PII) is being used online. PII, as used in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information in accordance with our website.

What personal information do we collect from the people that visit our website or blog?

When registering on our site, as appropriate, you may be asked to enter your name, email address, mailing address, phone number, credit card information and/or other details to help with your overall experience.

When do we collect information?

We collect information from you when you register on our site, login to Google, subscribe to a newsletter, respond to a survey, fill out a form, or enter information on our site. We also collect information when you connect an email account, calendar, or documents to the Service so that our AI Features can process them on your behalf, as described below.

How do we use your information?

We may use the information we collect from you:

• To personalize the user's experience and to allow us to deliver the type of content and product offerings in which you are most interested.
• To improve our website in order to better serve you.
• To allow us to better service you in responding to your customer service requests.
• To administer a contest, promotion, survey or other site feature.
• To quickly process your transactions.
• To send periodic emails regarding your order or other products and services.
• To power AI Features that extract tasks, dates, and other structured information from documents and emails you connect to the Service, as described below.

AI Features and Third-Party AI Providers

The Service includes artificial intelligence features that read and process content you connect to the Service — including emails, attachments, and uploaded documents — in order to automatically generate tasks, extract dates and deadlines, identify property references, and produce summaries ("AI Features").

To provide the AI Features, the Service transmits relevant portions of your content to third-party AI model providers, including Google's Gemini API, for processing. These providers process the content to generate the structured output the Service displays to you (for example, a task list or a set of extracted dates). We do not permit these providers to use your content to train their own general-purpose models, and we do not authorize any use of your content beyond what is necessary to generate output for you.

The extracted output produced by the AI Features (for example, a generated task, date, or summary) is stored in your account so it can be displayed to you and kept in sync with your transaction. Where feasible, we minimize how long the underlying raw email or document content itself is retained by our AI processing pipeline beyond what is needed to generate that output.

You are responsible for reviewing AI-generated output for accuracy before relying on it, and you may disconnect any connected account (see "Disconnecting from the Google API" below) to stop the AI Features from processing new content from that account.

Google User Data and Google API Services

OPEN TO CLOSE allows users to connect their Google account to the Service in order to use features involving Gmail, Google Calendar, Google Drive, and Google Contacts. Access to Google user data occurs only after you authorize OPEN TO CLOSE through Google's OAuth consent process. OPEN TO CLOSE only requests access to Google user data necessary to provide the features you choose to use.

Google User Data We Access

Depending on the permissions you authorize, OPEN TO CLOSE may access the following Google user data:

• Google account information: Your Google email address and email aliases associated with your account.
• Gmail: Email messages, message content, message metadata, attachments, labels, sender and recipient information, and other information necessary to display, organize, send, reply to, forward, and process email within OPEN TO CLOSE.
• Google Calendar: Calendars, calendar events, event details, dates, attendees, and related calendar information necessary to synchronize and manage calendar events within OPEN TO CLOSE.
• Google Drive: Files, folders, file metadata, and document content that you choose to access, upload, organize, or process through OPEN TO CLOSE.
• Google Contacts: Contact information that you choose to import into OPEN TO CLOSE.

How We Use Google User Data

OPEN TO CLOSE uses Google user data only to provide or improve user-facing functionality within the Service. Depending on the features you enable, Google user data may be used to:

• Display and organize Gmail messages within the OPEN TO CLOSE inbox.
• Allow you to compose, send, reply to, reply-all, forward, and schedule email messages.
• Associate emails and email information with real estate transactions and other records within OPEN TO CLOSE.
• Apply or manage Gmail labels and message status when you specifically use features that perform those actions.
• Synchronize Google Calendar events with OPEN TO CLOSE.
• Create, modify, or delete Google Calendar events when you perform those actions through OPEN TO CLOSE.
• Import Google Contacts into OPEN TO CLOSE.
• Upload files to Google Drive and create or organize Google Drive folders when you use those features.
• Process emails, attachments, documents, and related content using OPEN TO CLOSE's AI Features when those features are enabled.
• Generate user-facing summaries, tasks, dates, deadlines, transaction information, structured data, and other results requested through OPEN TO CLOSE.

OPEN TO CLOSE does not use Google user data for advertising, personalized advertising, retargeting, determining creditworthiness, lending purposes, selling information to data brokers, or providing information to information resellers.

Artificial Intelligence and Google User Data

When you enable or use an AI-powered feature, OPEN TO CLOSE may process relevant Google user data, including email content, email attachments, and documents, to provide the specific AI-powered functionality you requested. This may include generating summaries, identifying transaction information, extracting dates and deadlines, creating tasks, identifying property references, answering questions about connected content, and producing other structured information for your account.

To provide these features, relevant portions of Google user data may be transmitted to third-party service providers that process data on behalf of OPEN TO CLOSE, including Google's Gemini API. Such processing is performed only as necessary to provide or improve the user-facing functionality requested through OPEN TO CLOSE.

OPEN TO CLOSE does not use Google Workspace API data to develop, improve, or train generalized or non-personalized artificial intelligence or machine learning models.

OPEN TO CLOSE does not permit third-party AI providers acting on its behalf to use Google user data to train generalized or non-personalized AI or machine learning models. Google user data submitted to an AI provider is transmitted only as necessary to generate the functionality or output requested by the user.

Sharing and Disclosure of Google User Data

OPEN TO CLOSE does not sell Google user data.

OPEN TO CLOSE does not share, transfer, or disclose Google user data to third parties except as necessary to provide or improve the user-facing features of the Service, when required by law, or when explicitly authorized by the user.

Where third-party service providers process Google user data on behalf of OPEN TO CLOSE, they receive only the information reasonably necessary to perform the applicable service and are not authorized by OPEN TO CLOSE to use that information for advertising, data brokerage, creditworthiness, lending, or training generalized or non-personalized artificial intelligence or machine learning models.

Storage and Retention of Google User Data

OPEN TO CLOSE stores Google user data only when necessary to provide the Service and the features requested by the user. Information created or retained as part of your OPEN TO CLOSE account may include account identifiers, OAuth credentials, transaction associations, imported information, and user-facing output generated from connected Google data.

Where OPEN TO CLOSE processes email or document content through an AI processing pipeline, we minimize retention of the underlying content within that processing pipeline beyond what is reasonably necessary to provide the requested functionality. User-facing results generated from that processing, such as summaries, tasks, dates, deadlines, or other structured information, may be retained as part of your OPEN TO CLOSE account so that the information remains available to you.

Google user data retained as part of your OPEN TO CLOSE account is retained for as long as necessary to provide the Service, fulfill the purposes described in this Privacy Policy, comply with applicable legal obligations, resolve disputes, and enforce our agreements.

Protection of Google User Data

OPEN TO CLOSE uses administrative, technical, and organizational safeguards designed to protect Google user data against unauthorized access, disclosure, alteration, or destruction. Google user data transmitted between OPEN TO CLOSE, Google, and authorized service providers is protected using encryption in transit. Access to systems containing user data is restricted to authorized personnel and systems that require access to provide and maintain the Service.

Disconnecting Your Google Account and Deleting Google User Data

You may disconnect your Google account from OPEN TO CLOSE at any time using the account connection settings provided within the Service. Disconnecting your Google account stops OPEN TO CLOSE from accessing new Google user data through that connection and disables features that depend on the connection.

When a Google account is disconnected, OPEN TO CLOSE deletes the applicable Google OAuth access tokens and refresh tokens associated with that connection. Information previously imported into OPEN TO CLOSE or user-facing information created from Google data may remain in your OPEN TO CLOSE account where necessary to preserve transactions, tasks, dates, communications, documents, or other records you have created or elected to retain.

You may request deletion of your OPEN TO CLOSE account and associated personal data by contacting us at help@opentoclose.com. We will delete or anonymize applicable data in accordance with our retention obligations, except where retention is required by law, necessary to resolve disputes, maintain security, prevent fraud or abuse, or enforce our agreements.

Google API Services User Data Policy

OPEN TO CLOSE's use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

How do we protect visitor information?

Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology. We do not store any credit card information on the Website. Content transmitted to our AI Features and third-party AI providers is encrypted in transit.

We implement a variety of security measures when a user places an order enters, submits, or accesses their information to maintain the safety of your personal information.

All transactions are processed through a gateway provider and are not stored or processed on our servers.

Do we use cookies?

Yes. Cookies are small files that a site or its service provider transfers to your computer's hard drive through your Web browser (if you allow) that enables the site's or service provider's systems to recognize your browser and capture and remember certain information. For instance, we use cookies to help us remember and process the items in your shopping cart. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

We use cookies:

• To enable you to have a persistent login.
• To understand and save user preferences for future visits.
• To compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future.

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Each browser is a little different, so look at your browser's Help menu to learn the correct way to modify your cookies.

If users disable cookies in their browser:

If you disable cookies off, some features will be disabled. It will turn off some of the features that make your site experience more efficient and some of our services will not function properly.

Information Collection And Use

We collect several different types of information for various purposes to provide and improve our Service to you.

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:

• Email address
• Cookies and Usage Data
• Content of connected emails, documents, and calendars you choose to process through the AI Features

We will not use your Personal Data for anything that is not absolutely necessary to provide the service. We will never share your data with other companies except the AI model providers described above, who process it solely to generate output for you.

Disclosure Of Data

Under certain circumstances, OPEN TO CLOSE may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Data Retention

OPEN TO CLOSE will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services, you may delete your account. We may retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Consistent with these requirements, we will try to delete your information quickly upon request. Please note, however, that there could be latency in deleting information from our servers and backed-up versions might exist after deletion.

California Online Privacy Protection Act

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law's reach stretches well beyond California to require a person or company in the United States (and conceivably the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy.

According to CalOPPA we agree to the following:

Users can visit our site anonymously. Once this privacy policy is created, we will add a link to it on our home page, or as a minimum on the first significant page after entering our website. Our Privacy Policy link includes the word 'Privacy', and can be easily be found in the footer of OPEN TO CLOSE's home page.

Users will be notified of any privacy policy changes:

• On our Privacy Policy Page

Users are able to change their personal information:

• By logging in to their account

COPPA (Children Online Privacy Protection Act)

When it comes to the collection of personal information from children under 13, the Children's Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the nation's consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children's privacy and safety online.

We do not market to children under 13.

Fair Information Practices

The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.

In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:

• We will notify the users via email
• Within 7 business days
• We will notify the users via in site notification
• Within 7 business days

We also agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.

CAN SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to:

• Send information, respond to inquiries, and/or other requests or questions.
• Process orders and to send information and updates pertaining to orders.
• We may also send you additional information related to your product and/or service.
• Market to our mailing list or continue to send emails to our clients after the original transaction has occurred

To be in accordance with CANSPAM we agree to the following:

• NOT use false, or misleading subjects or email addresses.
• Identify the message as an advertisement in some reasonable way.
• Include the physical address of our business or site headquarters.
• Monitor third party email marketing services for compliance, if one is used.
• Honor opt-out/unsubscribe requests quickly.
• Allow users to unsubscribe by using the link at the bottom of each email.

If at any time you would like to unsubscribe from receiving future emails, you can email us at help@opentoclose.com.

Contacting Us

If there are any questions regarding this privacy policy you may contact us at help@opentoclose.com