TrueQoE Privacy and Confidentiality Policy

1. Scope

This Policy applies to:

• the TrueQoE website;
• the TrueQoE application;
• uploaded financial documents;
• generated reports;
• communications with our team; and
• professional review services offered through the platform.

2. Information We Collect

Depending on how you use TrueQoE, we may collect:

Account Information

• Name
• Email address
• Company name
• Phone number
• Billing information
• Login credentials

Business Information

You may upload information including:

• Profit & Loss Statements
• Balance Sheets
• Cash Flow Statements
• General Ledgers
• Trial Balances
• Tax Returns
• Bank Statements
• Payroll Reports
• Merchant Processor Statements
• Financial Models
• Broker packages (CIMs)
• Purchase offers
• Seller questionnaires
• Owner interview responses
• Supporting documentation

You control what information you upload.

Platform Activity

We may collect information regarding:

• login history
• pages viewed
• reports generated
• uploaded documents
• feature usage
• device information
• browser information
• IP address

This information helps us improve platform performance and security.

3. How We Use Your Information

We use your information to:

• provide financial analysis services;
• generate reports and calculations;
• identify potential financial adjustments;
• organize supporting evidence;
• produce decision-support reports;
• improve platform functionality;
• respond to support requests;
• detect fraud or abuse;
• comply with applicable law.

We do not use your uploaded financial information for advertising purposes.

4. Artificial Intelligence

TrueQoE uses artificial intelligence to assist with:

• extracting information from documents;
• organizing financial information;
• classifying transactions;
• identifying potential adjustments;
• generating summaries;
• drafting explanations.

Material financial calculations are performed using deterministic software logic.

AI-generated content is intended as decision support and may require professional review.

5. Professional Review

If you request a professionally reviewed report, relevant information may be shared with qualified reviewers engaged by Strategic Lever LLC.

These reviewers are contractually obligated to maintain the confidentiality of your information and may use it solely for providing the requested review services.

Professional reviewers do not acquire ownership of your information.

6. Confidentiality

We do not sell your information.

Your uploaded business information is treated as confidential.

Except as described in this Policy, we do not disclose your identifiable financial information to:

• other users;
• competing businesses;
• brokers;
• buyers;
• lenders;
• investors; or
• third parties

without your authorization or unless required by law.

7. How We Share Information

We may share information with trusted service providers that help us operate TrueQoE, including providers of:

• cloud infrastructure;
• secure file storage;
• payment processing;
• authentication;
• communications;
• customer support;
• artificial intelligence processing;
• application monitoring.

These providers receive only the information reasonably necessary to provide their services.

We use these providers to run the services described in this policy. Each processes information on our behalf:

• Google Workspace (Google LLC): we send email from it and store lead records in Google Sheets.
• Stripe, Inc.: processes payments for paid sessions. Stripe receives your payment details directly; we do not receive or store full card numbers.
• Calendly LLC: handles scheduling. When you book, Calendly collects your name, email address, the time you select and any answers you give on the booking form.

Google Analytics, Google Ads and Microsoft Clarity are described in §12.

8. De-identified and Aggregated Information

We may use information that has been de-identified or aggregated so that it no longer identifies you or your business to:

• improve our software;
• improve calculation methodologies;
• improve document extraction;
• develop benchmarking;
• improve educational content;
• improve system performance.

We do not publish identifiable customer financial information without your permission.

9. Data Security

We employ commercially reasonable administrative, technical, and physical safeguards designed to protect your information.

These safeguards may include:

• encryption during transmission;
• encryption of stored data;
• role-based access controls;
• authentication controls;
• audit logging;
• secure cloud infrastructure;
• regular software updates.

No method of electronic transmission or storage can be guaranteed to be completely secure.

10. Data Retention

We retain information only as long as reasonably necessary to:

• provide our services;
• maintain your account;
• comply with legal obligations;
• resolve disputes;
• enforce agreements.

Different categories of information may be retained for different periods.

Backups may persist for a limited period after deletion as part of normal disaster recovery processes.

We keep lead records for as long as we need them for the purposes above, or until you ask us to delete them. If you unsubscribe, we keep your email address on a suppression list so we can honor that choice.

11. Your Rights

Subject to applicable law, you may request to:

• access your information;
• update inaccurate information;
• download your information;
• request deletion of your account;
• request deletion of uploaded documents;
• close your account.

Certain information may be retained where required by law or necessary to protect legal rights.

To ask what we hold about you, or to have it deleted, email info@strategiclever.com.

12. Cookies

TrueQoE uses cookies and similar technologies to:

• authenticate users;
• maintain sessions;
• improve usability;
• understand website performance;
• protect against fraud.

You may configure your browser to refuse cookies, although some platform functionality may be limited.

Advertising measurement

Our public marketing pages load Google's advertising tag. It sets cookies that let us measure whether a visit from one of our Google ads later leads to a booked conversation, and may let us show our ads to people who have visited our site. The tag does not run on the pages where documents are uploaded or reviewed. You can manage Google's use of advertising cookies at https://adssettings.google.com.

Site analytics

Our public marketing pages use Google Analytics 4 and Microsoft Clarity to understand how visitors use the site. Google Analytics measures visits and actions such as viewing pricing or choosing a First Pass option, and this data may be used with Google Ads to measure and improve our advertising. We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps and session replay, such as clicks, scrolling and mouse movement; text entered into form fields is masked. Website usage data is captured using first- and third-party cookies and other tracking technologies. Neither service runs inside the TrueQoE review workspace, where uploaded financial documents are handled. You can opt out of Google Analytics with the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout. For more information about how Microsoft collects and uses your data, see the Microsoft Privacy Statement at https://privacy.microsoft.com/privacystatement.

13. Third-Party Services

TrueQoE integrates with third-party service providers.

Those providers maintain their own privacy policies governing information they receive while providing services to us.

We encourage you to review those policies where appropriate.

14. International Users

If you access TrueQoE from outside the United States, your information may be transferred to and processed in the United States.

15. Children's Privacy

TrueQoE is intended solely for business users.

We do not knowingly collect personal information from children under the age of 13.

16. Changes to this Policy

We may update this Privacy & Confidentiality Policy from time to time.

The Effective Date at the top of this Policy will indicate when revisions become effective.

Material changes will be communicated where required by law.

17. Free Resources and Email Communications

When you request a free resource from us, such as the Add-Back Evidence Checklist, we collect:

• your first name and email address;
• information about how you reached our page: the advertising campaign or link parameters in the page address, the page you came from, and the date and time of your request;
• any answer you choose to give us afterward, such as whether you are currently evaluating a specific business.

We use this information to:

• deliver the resource;
• send you a short series of related emails from Mark Hirsch;
• reply to you when you write back;
• understand which of our advertising and pages are useful.

If you choose to book a Live Deal Fit session from one of our pages or emails, we pass your email address to our payment processor so the checkout form is pre-filled. You can change it there.

Every marketing email we send includes an unsubscribe link. When you use it, we stop sending you those emails. We do not sell your email address or share it with third parties for their own marketing.

18. Contact Us