Privacy Policy

Effective date: July 22, 2026

Last updated: July 22, 2026

Pages By David ("Closing Intel," "we," "us," or "our") operates the Closing Intel platform (the "Service"), a tool that lets brokerage businesses ("Brokers") publish a listing and let prospective buyers ("Buyers") ask questions that are answered by AI strictly from the documents the Broker uploaded for that listing.

This Privacy Policy explains what information we collect, how we use it, whom we share it with, and the choices you have. It applies to both Brokers who hold accounts and Buyers who use a listing's Q&A.

1. A note on our two types of users

• Brokers are our customers. They create accounts, upload listing documents, and configure listings. For most Broker-uploaded content (including the listing documents and Buyer information collected through a listing), the Broker determines how that information is used, and we act as a service provider / processor handling it on the Broker's behalf. This Policy describes our own practices; a Broker's own privacy notice also governs how that Broker treats Buyer information.
• Buyers are people who open a listing link, verify their email, and ask questions. We collect limited information from Buyers to operate the Q&A and to pass qualified-lead information to the relevant Broker.

If you are a Buyer and have questions about how a specific Broker uses your information, please contact that Broker directly.

2. Information we collect

2.1 Information Brokers provide

• Account and organization details: name, email address, and login credentials (managed by our authentication provider), organization/firm name, role, branding (logo, colors), and the contact name, email, and phone number the Broker chooses to display to Buyers.
• Listing documents and content: the files a Broker uploads for a listing (which may include confidential offering materials, financial statements, leases, and similar documents) and listing details such as title, type, location, and asking price.

2.2 Information Buyers provide

• Identity and verification: the name and email address a Buyer enters to open a listing's Q&A, and the fact and time of email verification.
• Questions and conversations: the questions a Buyer asks and the transcript of the Q&A conversation for that listing.

2.3 Information we collect automatically

• Technical and security data: IP address, approximate request metadata, and usage counters. We use these to operate the Service, enforce rate limits, prevent abuse, and protect against fraud.
• Cookies. We use a small number of strictly necessary cookies — for example, a signed session cookie that remembers a Buyer verified their email for a specific listing, and authentication cookies for Broker logins. These are required for the Service to function. See Section 8.

We do not intentionally collect special categories of sensitive personal information, and we ask Brokers not to upload documents containing information they are not authorized to share.

3. How we use information

We use the information above to:

• Provide the Service — verify Buyer emails, generate answers only from a listing's own documents, display listings with Broker branding, and maintain conversation history.
• Notify Brokers of leads and activity — tell the relevant Broker when a Buyer verifies, when a Buyer asks their first question on a listing, and via a daily summary of listing activity (new leads, questions asked, questions awaiting a Broker answer).
• Secure and maintain the Service — enforce rate limits and per-listing usage caps, detect and prevent abuse, debug, and keep the Service reliable.
• Operate and improve the Service (operator access) — authorized Closing Intel personnel may access account data and customer content — including listing documents and Buyer conversation transcripts — for support, troubleshooting, quality assurance (for example, reviewing whether AI answers stayed grounded in the listing's documents), safety, and abuse prevention. Such access is limited to legitimate operational purposes, is logged in an audit trail, and is never used to market to Buyers or to share one Broker's content with another.
• Communicate — send transactional messages such as verification links, lead notifications, and — when a Broker answers a question a Buyer asked that the documents couldn't — a one-time email to that Buyer with the Broker's answer. (We do not send Buyers marketing email.)
• Comply with law and enforce our Terms.

We do not sell your personal information, and we do not share it for cross-context behavioral advertising.

4. How the AI processes information (and training)

Answers are generated by third-party AI providers (see Section 5) using only the Broker's listing documents plus the Buyer's question as context. The AI is designed not to use outside knowledge and to decline questions it cannot answer from those documents.

We use these providers through their business/enterprise APIs. Under those providers' terms as of the effective date, content sent through the API is not used to train their general models.

5. Who we share information with (subprocessors)

We share information with vendors who help us run the Service, under contracts that require them to protect it and use it only to provide their services to us:

We may also disclose information (a) to comply with law or valid legal process; (b) to protect the rights, safety, and security of Closing Intel, our users, or the public; and (c) in connection with a merger, acquisition, or sale of assets, in which case we will require the recipient to honor this Policy or notify you.

The table above is our current list of subprocessors. We will update it here when it changes; you may also request a copy at the contact address below.

6. How long we keep information

We keep information for as long as needed to provide the Service and for legitimate business or legal purposes:

• Broker account data and listing documents: for the life of the account, and deleted or de-identified within 30 days of account or listing deletion. When a listing is deleted, its documents, indexed text, leads, and conversations are removed.
• Buyer leads and conversations: retained for the Broker's use for the life of the Broker's account or until the Broker deletes the listing, whichever comes first, then deleted or de-identified within 30 days.
• Security logs / usage counters: 12 months.

7. Your rights and choices

Depending on where you live, you may have rights to access, correct, delete, or receive a copy of your personal information, and to appeal a denial of a request.

• California residents (CCPA/CPRA): you have the right to know, delete, correct, and to limit certain uses, and the right not to be discriminated against for exercising them. We do not sell or "share" (as defined by the CPRA) personal information.
• Other U.S. state privacy laws (including Virginia, Colorado, Connecticut, Utah, and other states with comprehensive privacy statutes) may give similar rights.

To exercise a right, contact us at david@pagesbydavid.com. Buyers: because Brokers control much of the Buyer information collected through their listings, we may refer your request to the relevant Broker or act on that Broker's instructions. We will verify your identity before acting on a request.

8. Cookies

We use only strictly necessary cookies required to operate the Service (a signed Buyer session cookie and Broker authentication cookies). We do not use advertising or cross-site tracking cookies. Because these are essential, they are not subject to opt-out, but you can block cookies in your browser (the Service may not function without them).

9. Security

We protect information using measures that include encryption in transit, hashing of verification tokens (we store a hash, never the raw token), signed and expiring Buyer sessions, per-tenant access controls that isolate each organization's data, and private storage for uploaded documents. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

10. Confidential documents

Listing documents are stored privately and are not made publicly downloadable. Buyers receive only text answers drawn from those documents for the listing they verified for; Buyers are never given the underlying files or access to another listing's documents. Brokers are responsible for ensuring they have the right to upload each document and to share its contents with verified Buyers.

11. Children's privacy

The Service is intended for business use by adults and is not directed to children under 18. We do not knowingly collect information from children.

12. International users

The Service is operated in the United States and intended for U.S. users. If you access it from outside the U.S., you understand your information will be processed in the U.S.

13. Changes to this Policy

We may update this Policy from time to time. We will post the updated version with a new "Last updated" date and, where required, provide additional notice.

14. Contact us

Pages By David

david@pagesbydavid.com

A postal address is available on request at the email above.