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:

• MrsNudgely.AI — 100% automated transaction coordination software
• StellarClean — email list verification and cleaning service
• NudgelyMail — managed cold email campaign platform
• MrsNudgely Studio — AI video production platform
• 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 and payment information (processed by third-party payment processor — we do not store full card numbers)
• Real estate license information
• Business name and address
• Transaction and client data you enter into MrsNudgely.AI
• Account credentials you create

B. Email Lists You Upload (StellarClean and NudgelyMail)

When you use StellarClean or NudgelyMail, you may upload lists of email addresses belonging to third parties. Regarding this data:

• We process uploaded lists solely to perform the service you requested — verification, cleaning, or managed sending
• We do not use your uploaded contact lists for any other purpose
• We do not sell, share, or mine uploaded contact data
• We do not combine your uploaded contacts with any other database
• Uploaded lists are retained only as long as necessary to complete your job and provide your results
• You are responsible for ensuring you have the legal right to upload and process the contact data you submit to us

C. NudgelyMail Email Account Information

• Email account credentials (app-specific passwords only, stored in encrypted vault)
• Email message content synced from connected accounts
• Email metadata (sender, recipient, subject, timestamps)

D. Automatically Collected Information

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

E. Voice and Call Data (MrsNudgely.AI)

• Phone calls may be recorded for quality assurance — callers are notified before recording begins
• Voice data is processed for AI transcription
• Call logs and transcripts are stored securely

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
• Verify and clean email lists you upload (StellarClean)
• Manage your email campaigns and domain sending infrastructure (NudgelyMail)
• Sync and display your email across connected accounts (NudgelyMail)
• 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. StellarClean — Email Verification Service

Because StellarClean processes contact data you upload on behalf of your business, we want to be explicit about how that data is handled.

What We Do With Uploaded Lists

• Run each address through our verification engine (syntax check, domain validation, MX record check, SMTP verification, disposable domain detection, role-based prefix detection)
• Return a scored, cleaned list and a verification report to you
• Log aggregate statistics (total verified, valid count, invalid count) for billing purposes — we log counts, not individual addresses, in billing records

What We Do NOT Do

• We do not retain your uploaded list after your results have been delivered and the retention window has passed
• We do not use your contacts for outreach of any kind
• We do not share your uploaded lists with any third party
• We do not combine your contacts with any other list or database

Your Responsibilities as the Uploader

• You represent that you have the legal right to submit the contact data you upload
• You are responsible for compliance with CAN-SPAM, GDPR, CASL, and any other applicable law governing how you use the verified list
• We are a processor — you are the controller — for all uploaded contact data

5. NudgelyMail — Email Campaign Platform

NudgelyMail manages email sending infrastructure on your behalf. Our role is as a data processor for your contact lists and campaign content.

• We process your contact lists to execute campaigns you configure and approve
• We maintain suppression lists on your behalf — contacts who have unsubscribed are permanently suppressed and will not receive future sends
• Unsubscribes are processed within 24 hours — this is enforced in code, not left to manual action
• We monitor bounce rates and complaint rates and will pause sends automatically if thresholds are exceeded
• We do not send to your contacts for any purpose other than the campaigns you configure
• All campaign content is your responsibility — you are the sender of record

6. 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:

• Amazon Web Services (AWS) — cloud hosting, storage, compute
• Payment processor — billing (we do not store full payment card data)
• Hetzner — server infrastructure for email campaign system

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 uploaded contact lists
• We never use your email content or contact data to target advertising

7. Data Security

We implement strong security measures, including:

• AES-256 encryption for stored credentials via AWS Secrets Manager
• TLS/SSL encryption for all data in transit
• DynamoDB encryption at rest for all stored data
• Isolated serverless compute (AWS Lambda) with no persistent state
• CloudFront CDN with built-in DDoS protection
• Read-only IMAP connections to email providers
• Access controls and authentication on all API endpoints
• Regular security monitoring and automated alerting

8. Data Retention

We retain your information only as long as necessary:

• Account information: retained while your account is active; deleted upon account cancellation
• Transaction records (MrsNudgely.AI): retained for 7 years per real estate industry standards
• Uploaded contact lists (StellarClean): retained until results are delivered, then purged within 30 days
• Campaign data (NudgelyMail): retained while your account is active
• Suppression lists: retained indefinitely — these protect your contacts from unwanted re-contact
• Call recordings and transcripts: retained for 90 days unless you request earlier deletion
• Billing records: retained for 7 years per accounting requirements
• Usage logs (aggregate counts): retained for 24 months

When we delete data, we delete it from all systems including backups, within the timeframe specified above.

9. 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 legal retention requirements)
• Portability: Receive your data in a structured, machine-readable format
• Opt-out: Unsubscribe from marketing communications at any time
• Disconnect: Remove connected email accounts from NudgelyMail at any time, immediately deleting all synced data
• 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 help@infostellarclose.com or 833-794-5488. We will respond within 30 days. We will confirm receipt of your opt-out request with a visible confirmation — not just a silent action.

10. 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
• 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 help@infostellarclose.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 verification and transaction coordination. Where these systems make significant decisions, we are prepared to provide information about the logic involved upon request.

11. 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
• 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
• 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: help@infostellarclose.com

12. Automated Decision-Making

Several of our services use automated systems:

• MrsNudgely.AI uses AI to coordinate real estate transactions, track deadlines, and communicate with parties — subject to your oversight and control as the agent
• StellarClean uses automated verification to score and classify email addresses
• NudgelyMail uses automated systems to enforce sending limits, warmup schedules, and bounce/complaint thresholds

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 help@infostellarclose.com to request review of any automated decision.

13. 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.

14. 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 help@infostellarclose.com and we will delete it.

15. 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.

16. 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

17. Contact Us

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

• Email: help@infostellarclose.com
• Phone: 833-794-5488
• Mail: StellarClose LLC, 3588 Plymouth Road 233, Ann Arbor, MI 48105
• Website: stellarclose.com

We respond to all privacy inquiries within 30 days.