Privacy Policy

Effective Date: November 8, 2025 | Last Updated: November 8, 2025

1. INTRODUCTION

StellarClose LLC ("we," "our," "us") operates Mrs. Nudgely, a transaction coordination software platform accessible at mrsnudgely.ai (the "Service"). This Privacy Policy explains how we collect, use, disclose, and protect information when you use our Service.

By using Mrs. Nudgely, you agree to the collection and use of information in accordance with this Privacy Policy.

2. INFORMATION WE COLLECT

2.1 Information You Provide

When you register for and use our Service, we collect:

• Account Information: Name, email address, phone number, business name
• Payment Information: Billing address (payment card details are processed and stored securely by our payment processor, Stripe, and are not stored on our servers)
• Transaction Data: Property addresses, transaction details, dates, and related information you provide or that we extract from documents
• Document Storage: You may upload documents to The Vault, our secure document storage system. Documents uploaded to The Vault are encrypted using AES-256 encryption and stored securely on AWS infrastructure. You may also grant us access to transaction documents through integrated transaction management platforms
• Communications: Messages you send to us or through the Service, including chat conversations, phone calls, and text messages
• Voice Data: When you call our toll-free number (833-659-9191), we may record calls for quality assurance, training, and service improvement purposes. Call recordings are retained for 90 days.
• Chat Transcripts: Conversations with Mrs. Nudgely through our chat interface are stored temporarily to provide continuity of service. You may request a copy of your chat transcript before ending the conversation.

2.2 Information We Collect Automatically

• Usage Data: Information about how you access and use the Service, including IP address, browser type, pages visited, and time spent on pages
• Device Information: Device type, operating system, and unique device identifiers
• Cookies and Similar Technologies: We use cookies to maintain your session and improve user experience. These include:
  • Essential Cookies: Required for basic site functionality and user authentication
  • Analytics Cookies: Help us understand how visitors interact with our Service
  • Performance Cookies: Measure and improve Service performance
• Communication Logs: Phone numbers, call duration, SMS message metadata (not content unless part of transaction coordination)

2.3 Information from Third-Party Services

Mrs. Nudgely is designed to integrate with transaction management platforms to provide seamless coordination services. We are currently developing API partnerships with leading platforms including DotLoop. When these integrations are available and you authorize Mrs. Nudgely to access your transaction data through these platforms:

• We will access transaction documents and data you authorize us to access
• We will collect contact information of transaction participants
• We will receive notifications about transaction updates
• We will use industry-standard OAuth authentication when available
• We will not store your platform passwords
• You can revoke our access at any time through the platform's settings

3. HOW WE USE YOUR INFORMATION

We use the information we collect to:

• Provide the Service: Monitor transactions, analyze documents, track deadlines, generate status reports, send deadline reminders, and answer questions about transaction details
• Automated Communications: Send reminders about upcoming deadlines, contingency expirations, and required actions based on transaction documents via email, SMS, or phone calls
• Transaction Coordination: Provide intelligent responses to questions about transaction status, document requirements, and key dates through our AI-powered chat and phone systems
• Process Payments: Bill you for transaction services through our payment processor
• Communicate with You: Send service-related notifications, updates, and support responses via email, SMS, or phone
• Improve the Service: Analyze usage patterns, call quality, and chat interactions to enhance functionality and user experience
• Ensure Security: Detect and prevent fraud, abuse, and security incidents
• Comply with Legal Obligations: Respond to legal requests and enforce our Terms of Service
• Business Verification: Provide business information to telecommunications providers (such as Twilio) for toll-free number verification and compliance purposes

4. ARTIFICIAL INTELLIGENCE AND DATA PROCESSING

Mrs. Nudgely uses artificial intelligence to provide transaction coordination services. Here's how we handle your data in relation to AI:

4.1 AI Service Provider

We use Anthropic's Claude API to power Mrs. Nudgely's intelligent features, including document analysis, deadline tracking, and conversational assistance. When you interact with Mrs. Nudgely:

• Your queries and transaction data are sent to Anthropic's API for processing
• Anthropic processes this data to generate responses and insights
• We operate under Anthropic's Commercial Terms, which provide enhanced privacy protections

4.2 Zero Data Retention with AI Provider

IMPORTANT: StellarClose LLC maintains a zero data retention agreement with Anthropic (our AI service provider) under Commercial Terms. This means:

• Real-time inference only: Any data sent to Anthropic's Claude API occurs only for real-time inference to answer your questions and coordinate your transactions
• Never stored or logged: Your data is never stored, logged, or retained by Anthropic beyond the immediate processing needed to generate responses
• Never used for training: Your data is never used to train, develop, or improve Anthropic's AI models or any other models
• Enterprise-grade security: All data exchanged with the AI service is encrypted in transit and processed in compliance with enterprise-grade security standards
• Highest privacy protection: This zero data retention policy provides the highest level of privacy protection available from AI services, distinct from consumer accounts where data may be used for training

Your transaction information remains completely confidential and is never shared with other users or used to improve models for other customers.

Important Distinction: While Anthropic does not retain your data, StellarClose LLC does retain account information, transaction data, and conversation logs as described in Section 7 (Data Retention) below. We retain this information to provide you with our Service, maintain transaction records, and comply with legal requirements. You have the right to request deletion of your data at any time, subject to legal retention requirements.

4.3 How We Use AI Interactions

We may analyze your interactions with Mrs. Nudgely to:

• Improve our prompt engineering and Service functionality
• Identify common issues or questions to enhance user experience
• Ensure quality and accuracy of responses
• Debug technical issues

This analysis is conducted by StellarClose LLC only and does not involve sharing your data with Anthropic for training purposes.

4.4 Data Minimization

We practice data minimization when using AI services:

• We only send data to the AI service that is necessary to answer your query or perform the requested task
• Personal information is anonymized or excluded when possible
• Sensitive financial information is never sent to the AI service unless explicitly required for the transaction coordination task

4.5 Data Controller and Data Processor Responsibilities

For clarity regarding data protection responsibilities:

• You as Data Controller: For transaction content and client information you input into Mrs. Nudgely, you are the "data controller" responsible for obtaining necessary consents and ensuring lawful use of that data
• We as Data Processor: StellarClose LLC acts as a "data processor" for transaction content, safeguarding it according to your instructions and this Privacy Policy
• We as Data Controller: For account information, usage data, and service-related data, we act as the "data controller" with responsibilities outlined in this Privacy Policy

5. HOW WE PROTECT YOUR INFORMATION

We implement appropriate technical and organizational security measures to protect your information:

• Encryption: All data transmitted to and from our Service is encrypted using SSL/TLS
• Secure Storage: Data at rest is encrypted and stored on secure servers (AWS)
• Access Controls: Access to personal information is restricted to authorized personnel only
• Database Security: Our PostgreSQL database uses encryption at rest, SSL/TLS in transit, and restricted user permissions
• Payment Security: Payment card information is handled exclusively by our PCI-compliant payment processor (Stripe) and never touches our servers
• Regular Security Audits: We regularly review and update our security practices
• AWS Security Infrastructure: We utilize AWS IAM roles, VPC, Security Groups, and CloudTrail for comprehensive security monitoring
• AI Processing Security: Communications with our AI service provider (Anthropic) are encrypted and subject to their enterprise-grade security standards

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

6. HOW WE SHARE YOUR INFORMATION

We do not sell your personal information. We may share your information only in the following circumstances:

6.1 With Your Consent

We may share information with third parties when you explicitly authorize us to do so.

6.2 Team Accounts

If you are part of a brokerage team account:

• Your team administrator can see your name, email, and transaction usage statistics
• Other team members can see your name and email address
• Transaction details remain private unless explicitly shared by you
• You can request removal from a team account at any time

6.3 Service Providers

We work with third-party service providers who perform services on our behalf:

• Payment processors: Stripe (for payment processing)
• Cloud hosting providers: Amazon Web Services (AWS) for hosting and data storage
• AI processing services: Anthropic/Claude API for intelligent transaction coordination (under Commercial Terms with enhanced privacy protections - your data is NOT used for AI training)
• Voice services: ElevenLabs for voice AI capabilities
• Telecommunications providers: Twilio for phone and SMS communications
• Email service providers: SendGrid for transactional and notification emails
• Analytics providers: For understanding service usage and improving functionality

These providers have access only to information necessary to perform their functions and are contractually obligated to protect your information.

6.4 Legal Requirements

We may disclose your information if required to do so by law or in response to:

• Valid legal requests (subpoenas, court orders)
• Protection of our legal rights
• Investigation of potential violations of our Terms of Service
• Protection of the safety and security of any person
• Telecommunications compliance and regulatory requirements

6.5 Business Transfers

If StellarClose LLC is involved in a merger, acquisition, or sale of assets, your information may be transferred. We will notify you before your information becomes subject to a different privacy policy.

7. DATA RETENTION

We retain your information for as long as necessary to provide the Service and comply with legal obligations:

• Account Information: Retained while your account is active and for 3 years after closure
• Transaction Data: Transaction analysis data (property addresses, key dates, identified issues, action items, transaction participants) is retained for 7 years after transaction completion to comply with standard real estate record retention requirements
• Documents in The Vault: Documents you upload to The Vault are retained for 7 years from the date of upload, encrypted using AES-256 bank-level encryption. You may delete your documents at any time. After 7 years, documents are permanently and securely deleted
• Payment Information: Billing addresses retained for accounting purposes. Payment card details are stored by Stripe (our payment processor) and are not stored on our servers
• Usage Logs: Retained for 90 days
• Call Recordings: Retained for 90 days for quality assurance purposes
• Chat Transcripts: Stored for 30 days unless you request deletion or a copy during your conversation
• SMS/Text Messages: Transaction-related messages retained for 7 years; general service messages retained for 90 days
• AI Processing Data: Under our Commercial Terms with Anthropic, your data sent to the AI service is not retained by Anthropic beyond the time needed to generate responses. StellarClose LLC retains conversation logs as specified above.

You may request deletion of your data at any time, subject to legal retention requirements.

8. YOUR RIGHTS AND CHOICES

8.1 Access and Correction

You have the right to:

• Access the personal information we hold about you
• Request correction of inaccurate information
• Request a copy of your data in a portable format
• Request a copy of your chat transcript during or after a conversation with Mrs. Nudgely

8.2 Deletion

You may request deletion of your account and associated data. We will delete your information within 30 days, except where retention is required by law (such as real estate transaction records which must be retained for 7 years).

8.3 Opt-Out

You may opt out of:

• Marketing communications: Use unsubscribe links in emails
• SMS messages: Reply STOP to any SMS message from our toll-free number
• Non-essential cookies: Adjust browser settings
• Call recordings: Request that your calls not be recorded (though this may limit service quality)

You cannot opt out of service-related communications necessary to provide the Service, such as transaction deadline reminders and critical notifications.

8.4 Third-Party Access

You may revoke Mrs. Nudgely's access to third-party platforms at any time through those platforms' settings.

9. CALIFORNIA PRIVACY RIGHTS (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

• Right to know: What personal information we collect, use, and disclose
• Right to delete: Request deletion of personal information
• Right to opt out: We do not sell personal information
• Right to non-discrimination: You will not be discriminated against for exercising your privacy rights
• Right to correct: Request correction of inaccurate personal information

9.1 Exercising Your Rights

To exercise these rights, contact us at [email protected] with "CCPA Request" in the subject line.

9.2 Authorized Agents

You may submit a request through an authorized agent. If you do so, the agent must present signed written permission to act on your behalf, and you may be required to independently verify your identity with us.

9.3 Verification

To protect your personal information from unauthorized access or deletion, we may require you to verify your identity before processing your request. If we cannot verify your identity, we cannot provide or delete your personal information.

10. NEVADA PRIVACY RIGHTS

Nevada residents have the right to opt out of the sale of their personal information. We do not sell personal information. If you are a Nevada resident and have questions about your privacy rights, contact us at [email protected] with "Nevada Privacy Request" in the subject line.

11. EUROPEAN DATA PROTECTION RIGHTS (GDPR)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you have additional rights under the General Data Protection Regulation (GDPR):

11.1 Legal Basis for Processing

We process your personal data based on:

• Contractual Necessity: To provide the Service you've subscribed to
• Legitimate Interests: To improve our Service and prevent fraud
• Consent: When you authorize us to access third-party platforms or record calls
• Legal Obligations: When required by law or telecommunications regulations

11.2 Your GDPR Rights

You have the right to:

• Access: Request a copy of your personal data
• Rectification: Correct inaccurate or incomplete data
• Erasure: Request deletion of your data ("right to be forgotten")
• Restriction: Limit how we process your data
• Data Portability: Receive your data in a machine-readable format
• Object: Object to processing based on legitimate interests
• Withdraw Consent: Revoke previously given consent at any time

11.3 Exercising Your Rights

To exercise these rights, contact [email protected] with "GDPR Request" in the subject line. We will respond within 30 days.

11.4 Data Transfers

When we transfer your data from the EEA to the United States, we ensure appropriate safeguards are in place through standard contractual clauses approved by the European Commission.

11.5 Supervisory Authority

You have the right to lodge a complaint with your local data protection authority if you believe we have not complied with GDPR requirements.

12. TELECOMMUNICATIONS COMPLIANCE

Mrs. Nudgely uses toll-free phone number (833-659-9191) and SMS messaging to provide transaction coordination services. We comply with all applicable telecommunications regulations:

• TCPA Compliance: We obtain consent before sending automated calls or text messages
• Opt-Out Mechanisms: You can reply STOP to any SMS message or request call removal
• Carrier Verification: Our business information has been verified through Trust Hub and toll-free verification processes
• Message Content: We only send transaction-related messages, appointment reminders, and service notifications - never promotional spam
• Legitimate Business Use: All communications support active real estate transactions and professional coordination services

13. CHILDREN'S PRIVACY

Mrs. Nudgely is not intended for use by individuals under 18 years of age. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child, we will delete it immediately.

14. INTERNATIONAL DATA TRANSFERS

Your information may be transferred to and processed in countries other than your country of residence. These countries may have data protection laws different from your country. We ensure appropriate safeguards are in place to protect your information in accordance with this Privacy Policy.

15. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. We will notify you of material changes by:

• Posting the updated policy on this page
• Updating the "Last Updated" date
• Sending email notification for significant changes

Your continued use of the Service after changes constitutes acceptance of the updated Privacy Policy.