Platform Privacy Policy

At Nalepa Labs LLC (referred to as "Nalepa Labs," "Company," "us" or "we"), we recognize that your privacy is important. This Privacy Policy discloses the privacy practices for the Company's website (the "Site"), any products and services available through this Site (collectively, "Nalepa Labs Products"), and any related products, services, features, technologies, websites, documentation, and any updates related to any of the foregoing (collectively, the "Platform"). Open Mind Ledger is a Nalepa Labs Product and is part of the Open Mind series of products. This Privacy Policy also covers how personal and other information that we receive or collect about you is treated. If you are an individual acting on your company's or client's behalf, you are accepting these provisions on their behalf and the term "you" will refer to you, your company, or your client. Please read the information below to learn the following regarding your use of this Platform.

You acknowledge that this Privacy Policy is designed to be read in connection with the Platform Terms of Service, and that by accessing or using our Platform, you agree to be bound by the Platform Terms of Service, as well as this Privacy Policy.

We reserve the right to change this Privacy Policy from time to time. We will notify you about significant changes in the way we treat personal information by updating any privacy information on this page. Your continued use of the Platform after such modifications will constitute your: (a) acknowledgment of the modified Privacy Policy; and (b) your agreement to abide and be bound by that Privacy Policy.

If you have any questions about this Privacy Policy, please feel free to contact us at: info@nalepalabs.com.

IMPORTANT: BY USING THE PLATFORM, YOU GIVE YOUR CONSENT THAT ALL PERSONAL DATA THAT YOU SUBMIT MAY BE PROCESSED BY US IN THE MANNER AND FOR THE PURPOSES DESCRIBED BELOW. IF YOU DO NOT AGREE TO THESE TERMS AND CONDITIONS, DO NOT USE THE PLATFORM.

The information we collect or otherwise receive depends on how you elect to use certain products or services available on the Platform.

The types of information we collect include Personally Identifiable Information ("PII") and Aggregate Information.

Personally Identifiable Information

This refers to information that lets us know the specifics of who you are. PII includes information you provide to us either manually or via third party sources. When you engage in certain activities on this Platform, such as registering for an account, downloading or purchasing a product or service, submitting content or posting content in the user forums, submitting information into a Nalepa Labs Product, or sending us feedback, we may ask you to provide certain information about yourself.

Examples of PII may include:

• Contact data and account profile data. We collect information when you create an account, activate a subscription, or upload information to the Platform. Personal information may include your name, previous name(s) and/or nicknames, title and honorifics, professional title and company name, education, billing and mailing addresses, phone number and email address, profile photo, billing information (your payment information), purchase history, demographic information, preferences, subscription data, and your username and account credentials.
• Identity verification information. We collect information to verify your identity, including your name, date of birth, social security number, social insurance number, driver's license number, passport number, government-issued identification details, and similar information to verify your identity and to help you file your tax return.
• Communications, feedback and survey data, recordings, and related data. We may collect personal information such as your name, email address, telephone number and any other personal information you choose to share when you reach out to us for support, give us feedback, participate in optional surveys, attend our events, participate in product research or training, or otherwise interact or communicate with us. This information may include: call center recordings and call monitoring records, chat and text records, voicemails, photographs, and other audio recordings or video images, including those recorded in and around our physical locations.
• Marketing data. You may provide us with your contact information and preferences for receiving marketing communications.
• Social and community content. We may receive content you post on our social media pages and our community pages.
• Business and financial information. We may receive information about your business, your finances, expenses, invoices, financial statements, details of your financial transactions, payroll details, payment details, tax return details, details about your customers, vendors, or employees, income and wage information, and/or investment information.
• Interactions with experts. The Platform may provide opportunities for you to connect with live experts, including, for example, accountants or tax preparers. When you interact with these experts, we may receive information about the questions you ask, the details of your accounts, and the guidance provided to you.
• Interactions with chatbots. We may receive information from you through your use of chatbots, digital assistants, or other interactive bots across the Platform.
• Device and contact data. If you grant permission in your device settings, certain features may have access to your device and contacts.
• Business connection data. We may collect information about you when you interact with the Platform through our customers. If you are a customer, vendor or prospect of a Nalepa Labs customer and interact with the Platform (for example, to pay an invoice, make a purchase, interact with an email, provide contact details or complete a survey), we will use this information to make recommendations about you to our customers. Our customers may also provide business connection data directly about you to us.

Examples of PII that may come from third party sources may include:

• Linked third-party services. If you choose to sync a non-Nalepa Labs account/service/product with your Nalepa Labs account, we will receive information from that account/service/product according to your settings with that account/service/product. This may include details of your bank account information, employer information, social media information, purchase history or your business's sales records through a point of sale application.
• Supplemental information and identity verification providers. We work with certain third parties to help us verify your identity, the specifics of your business, and/or supplement the personal information you have provided and ensure the accuracy of your personal information. For example, we use third-party providers to validate your contact information (e.g., name, mailing address, email address, phone number) or to provide additional details about your business. These providers may include, for example, your financial institution, telecommunications provider, or email provider.
• Customer support providers. We receive personal information about you or your interaction with the Platform from certain third parties for troubleshooting purposes. For example, we may obtain information about your interaction(s) with customer support and information about technical issues you have raised, including call center recordings, call monitoring records, voicemails, photographs and chat records.
• Credit bureaus and related third parties. Many Platform features rely on information we receive from credit bureaus and related third parties. For example, in some countries, we may offer free credit reports and credit scores. We request these reports and credit scores on your behalf from credit bureau partners, like TransUnion, Experian and Equifax. These partners may also provide personal information such as employment or income data, social security number, vehicle or driver information, or information about special offers available based on your credit profile so we can make more personalized recommendations for you.
• Other users. As described above, we may receive personal information about you from other Platform users, such as your accountant, bookkeeper, tax preparer, spouse, employer, or other business customers using the Platform (e.g., businesses from which you buy products or services, or with which you otherwise interact). We may also collect such personal information through features like member referral programs.
• Risk management, cybersecurity & anti-fraud providers. We may receive personal information from third parties that help us assess risks associated with our offerings, including to help combat fraud and illegal activity and to help protect your personal information.
• Data providers. We may receive information from information services and data licensors that provide demographic and preference information to us.
• Content providers. We may receive personal information from companies that make user-generated content from their service available to others, such as local business reviews or public social media posts.
• Joint offering partners. We may offer co-branded services or experiences or engage in joint-marketing activities with others, including through our conferences or live events.
• Government agencies. We may receive information from government agencies, including from various tax agencies, such as your tax filing confirmation from the IRS.
• Public information. We may collect individual and household demographic information and preference information from publicly available sources, such as open government databases, social media platforms, and others.

Aggregate Information

This refers to information that does not by itself identify a specific individual. We gather certain information about you based upon where you visit on our Platform and what other sites may have directed you to us. This information, which is collected in a variety of different ways, is compiled and analyzed on both a personal and an aggregated basis. This information may include the Website's Uniform Resource Locator ("URL") that points to the site you just came from, which URL you go to after visiting our Platform, what browser you are using, and your Internet Protocol ("IP") address.

Depending on how you use our Platform, we will store cookies on your computer in order to collect certain Aggregate Information about our users and to customize certain aspects of your specific user experience. A cookie is a small data text file which is stored on your computer that uniquely identifies your browser. Cookies may also include more personalized information, such as your IP address, browser type, the server your computer is logged onto, the area code and zip code associated with your server, and your first name to welcome you back to our Platform. We may use cookies to perform tasks such as: monitoring aggregate site usage metrics, storing and remembering your passwords (if you allow us to do so), storing account and advertising preferences that you have set, and personalizing the offerings we make available to you. However, we do not use cookies to track your browsing behaviors.

We may also use an outside advertising partner to display banner advertisements on our Site. As part of their service, they will place a separate cookie on your computer. We will not provide any third-party advertising partners with any of your PII or information about your purchases. We and our third party ad server will collect and use Aggregate Information about you, such as your IP address, browser type, the server your computer is logged onto, the area code and zip code associated with your server and whether you responded to a particular ad. Other advertisers may also place banner ads on our Site in the same manner as above, but we will not disclose any PII to them.

Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some aspects of the Platform may not function properly if you elect to disable cookies.

We, or our Service Providers (as defined below), may use your PII and Aggregate Information in the following ways:

To provide products and services within the Platform to you, for example to:

• Provide you with the Platform, create your account and manage our relationship with you;
• Run and manage our business, including resolving billing and financial disputes;
• Evaluate your eligibility for marketing offers, products and services;
• Provide features to you, such as your free credit reports and scores;
• Provide a product or service that you have requested through the Platform;
• Connect you with experts and other users;
• Communicate with you, such as sending you electronic notifications concerning your financial privacy;
• Understand your needs and interests, and personalize your experience with the Services and our communications;
• Provide you with support and resolve disputes;
• Authenticate your identity;
• Manage event registrations and attendance, including sending related communications to you; or
• Register visitors to our offices for security reasons and manage non-disclosure agreements that visitors may be required to sign.

Additional purposes:

• Improve the Platform;
• Protect against misuse of the Platform;
• For marketing and advertising;
• Ensure compliance with legal and regulatory requirements;
• Enforce our Terms of Service;
• Exercise our rights in any legal or administrative proceeding; or
• With your consent, as may be required by law.

We will not sell, trade, or rent your PII to others. We do provide some of our product and service offerings through contractual arrangements made with affiliates, service providers, partners and other third parties ("Service Partners"). We and our Service Partners may need to use some PII in order to perform tasks between our respective sites, or to deliver products or services to you. For example, we must release your credit card information to the card-issuing bank to confirm payment for products and services purchased on this Platform; release your address information to the delivery service to deliver products that you ordered; and provide order information to third parties that help us provide customer service.

The use of your PII by our Service Partners is governed by the respective privacy policies of those providers, and is not subject to our control. Except as otherwise discussed in this Privacy Policy, this document only addresses the use and disclosure of information we collect from you. Other websites accessible through this Platform, including our Service Partners, have their own privacy policies and data collection, use and disclosure practices. Please consult each Site's privacy policy. We are not responsible for the policies or practices of third parties.

Occasionally we may be required by law enforcement or judicial authorities to provide PII to the appropriate governmental authorities. In such cases, we will disclose PII upon receipt of a court order, subpoena, or to cooperate with a law enforcement investigation. We fully cooperate with law enforcement agencies in identifying those who use our services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful.

We may also provide Aggregate Information about our customers' sales, traffic patterns, and related Platform information to third party advertisers, but these statistics do not include any PII.

We believe you should have the ability to access and edit the PII that you have provided to us. You may change any of your PII in your account online at any time by linking to your account in accordance with instructions posted elsewhere on this Site.

We encourage you to promptly update your PII if it changes. You may ask to have the information on your account deleted or removed; however, some information, such as past transactions, logs of technical support calls, or other information may not be deleted. In addition, it may be impossible to completely delete your information without some residual information because of backups.

We may, from time to time, send you email regarding new products and services that we feel may interest you. In addition, if you indicated upon registration that you are interested in receiving offers or information from us and our partners, we may occasionally call or send you direct mail about products and services that may be of interest to you. Only Nalepa Labs (or agents working on behalf of Nalepa Labs and under confidentiality agreements) will send you these solicitations, and only if you have previously indicated that you wish to receive them. If you do not want to receive solicitations from us, you can "opt-out" by accessing your account online and editing your account information to no longer receive such offers and mailings.

You also have choices with respect to cookies, as described above. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies some parts of our Platform may not work properly in your case.

At our Platform you can be assured that your PII is secure, consistent with current industry standards. We strive to take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of your PII. For example:

We work hard to ensure that the data we collect is reliable, accurate, complete and current. We encrypt all PII, in order to prevent unauthorized parties from viewing such information when it is transmitted to us. We also only keep collected information for 30 days, after which we archive the information for 60 days and then permanently delete it, and use it only for the purposes for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements.

We limit access to PII only to specific employees, contractors and agents who have a reasonable need to come into contact with your information. For example, we may provide members of our technical support team with limited access to your account in order to allow them to troubleshoot problems you may be having with the Site.

Additionally, we also employ a number of physical, electronic, and procedural safeguards to protect PII. Our secure servers and our data centers are protected by industry-standard encryption, and our servers reside behind firewalls and employ high-level password protection.

Finally, access by you to your PII is available through a password and unique customer ID selected by you. This password is encrypted. We recommend that you do not divulge your password to anyone.

In order to most effectively serve you, credit card transactions and order fulfillment are handled by established third party banking institutions and processing agents (such as PayPal). They receive the information needed to verify and authorize your credit card or other payment information and to process and ship your order.

Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your PII, you acknowledge that: (a) there are security and privacy limitations inherent to the Internet which are beyond our control; and (b) the security, integrity and privacy of any and all information and data exchanged between you and us through this Platform cannot be guaranteed.

You must be at least 18 years old to have our permission to use the Platform. Our policy is that we do not knowingly collect, use or disclose PII about minor visitors.

You should also be aware that when PII is voluntarily disclosed (i.e. your name, email address, etc.) in the discussion forums or other public areas on this Platform, that information, along with any information disclosed in your communication, can be collected and used by third parties and may result in unsolicited messages (including unwanted spam messages) from third parties. Such activities are beyond our control and this Privacy Policy does not apply to such information.

If you have any questions, concerns or inquiries about our Privacy Policy, or our use of your PII, or our privacy practices, please contact us at: info@nalepalabs.com.

The State of California enacted the Shine the Light law (California Civil Code Section 1798.83) that permits users who are California residents to request certain information regarding the disclosure of certain "personal information" during the past year for marketing purposes. To make such a request, please contact us using our contact form or alternatively write us at Nalepa Labs LLC, 8198 S Jog Rd Suite 104, Boynton Beach, FL 33472.

This Privacy Policy is effective as of April 27, 2026. Nalepa Labs reserves the right to change this Privacy Policy from time to time. Your continued use of the Platform after such modifications will constitute your: (a) acknowledgment of the modified Privacy Policy; and (b) your agreement to abide and be bound by that Privacy Policy.