SIGNAL PRIVACY POLICY

This Privacy Policy describes how CloseMode AI LLC ("CloseMode AI," "we," "us," or "our"), founded and operated by Rhett Hale of Summerfield, Florida, collects, uses, discloses, and protects information in connection with Signal, our AI-assisted customer relationship management and agency management platform for independent life insurance producers and agency owners (the "Platform" or "Signal"), accessible at signalcrm.dev.

This Policy applies specifically to Signal and is separate from any general privacy policy CloseMode AI publishes for its other products or services. Signal is designed exclusively for use in connection with life insurance products and does not process health insurance claims, health plan data, or protected health information as defined under the Health Insurance Portability and Accountability Act ("HIPAA"). HIPAA does not apply to Signal or to the data processed through it.

If you access Signal as a producer, team lead, agency administrator, or agency owner (each, a "Member," and collectively, "Members"), this Policy governs our handling of your information and, where applicable, information about the insurance leads, prospects, and clients ("Consumers") whose data Members and Signal's connected integrations process through the Platform.

Signal is made available to Members through a sponsoring insurance agency that has entered into a separate services agreement with CloseMode AI (a "Client Agency"). This Policy describes CloseMode AI's own practices as the operator of the Platform. It does not modify or expand a Client Agency's own privacy obligations to its Consumers, which remain the Client Agency's responsibility, as described further in Section 8.

We use the information described above to: operate and provide the Platform's core features (deal and pipeline tracking, team communication, compensation tracking, analytics, and quoting support); generate and internally score AI-assisted communications intended to help Members respond to Leads more effectively; provide agency leadership with visibility into production and performance as described in Section 4; maintain the security and integrity of the Platform; and improve Signal's features using aggregated or de-identified information. We do not use Member or Consumer information to serve third-party advertising.

Signal is built so that visibility follows role, automatically:

• Producers can see their own account, deal, and production information, and information their agency designates as visible to their team.
• Team leads can see the production and activity information of the producers on their team.
• Agency administrators and the agency owner can see agency-wide information for their own Client Agency, including all Members, deals, and Leads associated with that agency.
• CloseMode AI platform administrators can access information across the Platform as necessary to operate, support, secure, and maintain Signal, and to provide the services described in the applicable Client Agency agreement.

A Member or agency cannot see another, unaffiliated agency's information through Signal.

We work with third-party service providers to operate Signal, including cloud hosting and database infrastructure, and artificial intelligence model providers used to power Signal's AI-assisted features and quality scoring. These providers process information solely on our behalf, under obligations to protect it, and are not permitted to use it for their own independent purposes. We do not sell Member, Consumer, or Client Agency information to any third party.

We retain information for as long as a Client Agency's account remains active. Following account closure or a Member's departure from a Client Agency, retention periods vary by data type: submissions, scores, Packet ledger entries, and submission audit records are retained for seven (7) years consistent with NAIC and applicable state insurance producer recordkeeping requirements; member access logs are retained for ninety (90) days; and other account data is purged within thirty (30) days of a confirmed deletion request, with affected backups aging out within sixty (60) days total. Aggregated or de-identified information may be retained indefinitely. Some information may be retained longer where required by law or by a Client Agency's own recordkeeping obligations as a licensed insurance agency.

Much of the information Signal handles on behalf of Client Agencies is NPI within the meaning of the Gramm-Leach-Bliley Act, because it is collected by or on behalf of Client Agencies in connection with providing life insurance products to Consumers. With respect to that information, CloseMode AI acts as a service provider to each Client Agency, not as the financial institution directly responsible to the Consumer under GLBA. We handle NPI consistent with the GLBA Safeguards Rule, including through the administrative, technical, and physical safeguards described in Section 9, and we do not use NPI for any purpose other than providing the Platform to the Client Agency that submitted it. Each Client Agency remains responsible for its own GLBA Privacy Rule obligations to its Consumers. Additional detail on CloseMode AI's role as a service provider is available in our Data Security Addendum, which is incorporated into each Client Agency's service agreement.

Client Agencies and their Members may use Signal, together with a separately-engaged automation vendor, to generate and send text messages, calls, or other communications to Leads. Signal's own role is limited to drafting AI-assisted message content, tracking related activity, and scoring communication quality; message delivery to a Lead's phone number occurs through the Client Agency's own connected messaging or telephony systems, not directly through Signal. Obtaining and documenting valid consent for any outbound contact, and complying with the Telephone Consumer Protection Act ("TCPA") and all other applicable law, is the sole responsibility of the Client Agency and its Members.

We use administrative, technical, and physical safeguards designed to protect information in Signal, including: encryption of NPI in transit (TLS 1.2 or higher) and at rest (AES-256 or equivalent); encryption of sensitive stored credentials and access tokens; role-based access controls that limit internal access to NPI to personnel and systems with a legitimate need; logging of administrative actions; and review processes designed to identify and remove certain sensitive identifiers (such as Social Security numbers) that may appear in call or text transcripts. No system is completely secure, and we cannot guarantee the absolute security of any information.

A Member may request access to, correction of, or deletion of their own account information by contacting us using the information in Section 13, or through their Client Agency's designated administrator. We will honor deletion requests except where retention is required by law or by a Client Agency's own insurance-recordkeeping obligations. Because much of the Lead and policy information in Signal is entered and controlled by a Client Agency rather than by CloseMode AI directly, a Consumer wishing to exercise rights over their own information should generally contact the Client Agency that submitted it.

Signal is a business tool intended for use by licensed or licensing life insurance professionals and is not directed to, and does not knowingly collect information from, individuals under the age of 18.

We may update this Policy from time to time. If we make material changes, we will provide notice to Client Agencies through the Platform or by email before the changes take effect.

CloseMode AI LLC
Attn: Rhett Hale
Summerfield, Florida
rhett@closemodeai.com

This Policy is governed by the laws of the State of Florida, without regard to its conflict-of-law principles.