Privacy Policy

1. Who We Are

StellarClose LLC is a Michigan limited liability company that develops and operates AI-powered software tools for real estate professionals. Our products include:

• StellarClose Transaction Coordination — AI transaction coordination for real estate (stellarclosetc.com)
• Cookie Close — our AI assistant character on voice and chat surfaces
• StellarClose.com — business hub and internal operations

When this policy refers to “we,” “us,” or “our,” it means StellarClose LLC. When it refers to “you,” it means any person or business that uses our products or visits our websites.

2. Information We Collect

A. Information You Provide Directly

• Name, email address, phone number
• Billing information. We do not currently process payments. When we begin, payment will be handled by a third-party payment processor, which we will name here before any payment is taken. We will not store full card numbers.
• Real estate license information
• Business name and address
• Transaction and client data you enter into our products
• Account credentials you create

B. Automatically Collected Information

• Device information (browser type, operating system)
• IP address and approximate location
• Usage data and analytics
• Cookies and similar tracking technologies

C. Voice and Call Data (Cookie Close)

Phone calls are recorded, and callers are notified before recording begins. Voice data is processed for AI transcription.

Calls are recorded because the record protects you. A transaction coordination service is only as good as its ability to show what was said, to whom, and when — so that an agent can demonstrate to a client, a brokerage, or a board of realtors that a specific thing was communicated on a specific date. Call logs, recordings and transcripts are stored in the vault and retained for ten years under Section 7.

3. How We Use Your Information

We use the information we collect to:

• Provide, operate, and maintain our services
• Process transactions and send related confirmations
• Coordinate real estate transactions, track deadlines, and communicate with parties
• Track usage for billing purposes
• Send service notifications, updates, and administrative information
• Respond to your inquiries and provide customer support
• Improve our products and develop new features
• Monitor system health and detect fraud or abuse
• Comply with legal obligations

4. AI Processing of Your Data

Our products use AI to process your data on your behalf. We are explicit about how AI is used and what it sees.

Transaction coordination. We use AI to read transaction documents, populate deadlines, generate checklists, and prepare communications. This processing runs with the setting that disables training on submitted content. You remain the agent of record and retain oversight and control.

Cookie Close — voice and chat. CookieClose identifies as an AI on every channel. We will never configure the system to deceive any party into believing they are speaking with a human. Calls handled by Cookie Close are recorded, with caller notification before recording begins.

5. Information Sharing

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

Service Providers

We work with third-party vendors who help us operate our infrastructure, including:

• DigitalOcean — hosting (compute, managed PostgreSQL, networking)
• Backblaze B2 — encrypted off-site backup of database snapshots
• Anthropic — AI document parsing and coordination (Claude API)
• ElevenLabs — voice generation and language translation for Cookie Close
• SignalWire — inbound and outbound voice (Cookie Close phone)
• Namecheap — domain registration and DNS

All service providers are contractually required to use your data only to perform services for us and to protect it appropriately.

Legal Requirements

We may disclose information when required by law, court order, or government request, or when we believe disclosure is necessary to protect our rights, your safety, or the safety of others.

Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred. We will notify you before your information becomes subject to a materially different privacy policy.

What We Never Do

• We never sell your personal information to data brokers or advertisers
• We never sell or share your transaction records or any other personal information
• We never use your email content or contact data to target advertising

6. Data Security

We implement strong security measures, including:

• TLS 1.2 or higher for all data in transit; HSTS enforced with one-year max-age
• Encryption at rest for the production database (DigitalOcean managed PostgreSQL); encrypted off-site backups to Backblaze B2
• Passwordless email magic-link authentication; no customer passwords stored
• Per-tenant data isolation enforced at the SQL layer
• Per-tenant rate limiting on authentication and AI endpoints
• Application secrets in a 0600-permissioned environment file readable only by the application service account
• Daily automated security sweep that probes the live posture against documented controls and alerts on drift
• Vulnerability management with documented patching SLAs (Critical 72h, High 14d, Medium 30d)

7. Data Retention

The vault: ten years.

Everything placed in your vault — documents, correspondence, call logs, recordings and transcripts, and the record of what was sent to whom and when — is retained for ten years, immutably, date- and time-stamped on entry. Nothing in the vault is altered or deleted during that period.

The ten years run from the date of signature where a signature was required, and otherwise from the date the record was sent.

Retention survives cancellation. If you close your account, your vault contents are kept for the remainder of the ten years, because you may need them. We do not delete your record because you stopped being a customer.

Records that are not vault contents. Billing records are retained for seven years, as accounting and tax requirements demand. Aggregate usage logs, which contain no transaction content, are retained for 24 months.

8. Your Rights

You have the right to:

• Access: Request a copy of the personal information we hold about you
• Correction: Update or correct inaccurate information
• Deletion: Request deletion of your information, subject to the vault exception below and to other legal retention requirements
• Portability: Receive your data in a structured, machine-readable format
• Opt-out: Unsubscribe from marketing communications at any time
• Withdraw consent: Where we rely on consent to process your data, you may withdraw it at any time

To exercise any of these rights, contact us at privacy@stellarclose.com or 833-659-9191. Calling that number reaches Cookie, our AI assistant — she is an AI, she will tell you so, and she will take your request and route it to a person. We will respond within 30 days. We will confirm receipt of your opt-out request with a visible confirmation — not just a silent action.

9. California Privacy Rights (CCPA/CPRA)

California residents have the following rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), as updated effective January 1, 2026:

• Right to know what personal information we collect, use, share, or sell (we do not sell)
• Right to delete your personal information, subject to certain exceptions, including the vault exception described in Section 8
• Right to correct inaccurate personal information
• Right to opt-out of the sale or sharing of personal information (we do not sell or share)
• Right to limit use of sensitive personal information
• Right to non-discrimination for exercising your CCPA rights
• Right to access personal information going back to January 1, 2022, to the extent we retain it

To submit a CCPA request, contact us at privacy@stellarclose.com. We will verify your identity before processing the request. We will respond within 45 days. We will provide written confirmation when an opt-out request has been honored.

We use automated systems in our services, including AI-powered transaction coordination. Where these systems make significant decisions, we are prepared to provide information about the logic involved upon request.

10. GDPR Compliance (EU/UK Users)

If you are located in the European Union or United Kingdom, the following applies:

Legal Bases for Processing

• Contract performance: We process your data to fulfill the services you’ve contracted with us
• Legitimate interests: We process data to operate, secure, and improve our services where this does not override your rights
• Legal obligation: We process data as required by law
• Establishment and defence of legal claims: We retain vault contents for ten years on this basis, as described in Sections 7 and 8
• Consent: Where we rely on consent, you may withdraw it at any time

Your GDPR Rights

• Access, rectification, erasure, restriction of processing, data portability, and objection — subject to the vault exception in Section 8
• Right to lodge a complaint with your local data protection authority
• Response to requests within 30 days

Data Transfers

We are based in the United States. If you are in the EU or UK, your data may be transferred to and processed in the US. We take appropriate measures to protect transferred data in accordance with applicable law.

Data Protection contact: privacy@stellarclose.com

11. Automated Decision-Making

Our services use automated systems:

• StellarClose Transaction Coordination uses AI to coordinate real estate transactions, track deadlines, and communicate with parties — subject to your oversight and control as the agent
• Cookie Close uses AI for voice and chat interactions; she identifies as an AI on every channel and never claims to be human

Where automated processing produces significant outcomes (such as blocking a send or flagging an account), you will be notified with an explanation and given the opportunity to seek human review. Contact us at privacy@stellarclose.com to request review of any automated decision.

12. Cookies and Tracking

We use cookies and similar technologies to:

• Keep you logged in to your account
• Remember your preferences
• Understand how our products are used so we can improve them
• Protect against fraud and abuse

We do not use cookies to serve advertising or to track you across third-party websites. You can control cookie settings in your browser. Disabling cookies may affect the functionality of some features.

13. Children’s Privacy

Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us immediately at privacy@stellarclose.com and we will delete it.

14. Third-Party Links

Our websites and products may contain links to third-party websites and services. We are not responsible for the privacy practices of those sites. We encourage you to review the privacy policies of any third-party sites you visit.

15. Changes to This Policy

We review this Privacy Policy at least annually and update it whenever our data practices change materially. When we make significant changes, we will:

• Post the updated policy on our websites with the new effective date
• Notify registered users by email before the change takes effect
• For material changes affecting how we use your data, we will obtain fresh consent where required

16. Contact Us

For questions, requests, or concerns about this Privacy Policy or our data practices:

• Email: privacy@stellarclose.com
• Phone: 833-659-9191 — you will reach Cookie, our AI assistant. She identifies herself as an AI on every call, and she routes your request to a person.
• Mailing address: StellarClose LLC, 3588 Plymouth Road 233, Ann Arbor, MI 48105
• Company location: Dexter, Michigan
• Website: stellarclose.com

We respond to all privacy inquiries within 30 days.