OFFMKTS.COM

Legal

Off Mkts Privacy Policy

Version:
1.1
Effective Date:
June 20, 2026
Last Updated:
June 20, 2026

1. Scope of This Privacy Policy

This Privacy Policy applies to information collected through the Platform, including:

  • Website usage;
  • Account creation;
  • Marketplace participation;
  • Opportunity submissions;
  • Referrals;
  • Introductions;
  • Communications;
  • Customer support interactions;
  • Marketing activities;
  • Artificial Intelligence Systems;
  • Analytics systems; and
  • Related Platform services.

This Privacy Policy applies whether information is collected through:

  • Desktop devices;
  • Mobile devices;
  • Applications;
  • Websites;
  • Electronic communications;
  • Artificial Intelligence Systems; or
  • Other technologies utilized by Off Mkts.

This Privacy Policy governs information collected directly from Users, information collected automatically through Platform activity, information received from third parties, and information generated through marketplace participation.

This Privacy Policy does not apply to information practices of third parties that are not owned or controlled by Off Mkts, even where links, referrals, integrations, or communications are facilitated through the Platform.

2. Information We Collect

Off Mkts may collect information directly from Users, automatically through Platform usage, from marketplace activity, from communications, from third-party sources, and through Artificial Intelligence Systems.

2.1 Account Information

We may collect information provided when creating or maintaining an account, including:

  • Name;
  • Business name;
  • Username;
  • Email address;
  • Telephone number;
  • Mailing address;
  • Profile information;
  • Licensing information;
  • Professional credentials;
  • Account preferences; and
  • Related account information.

Users are responsible for maintaining accurate and current account information.

2.2 Marketplace Information

We may collect information relating to marketplace activity, including:

  • Opportunities;
  • Referrals;
  • Introductions;
  • Listings;
  • Marketplace participation;
  • Communications;
  • User interactions;
  • Relationship information;
  • Opportunity status information; and
  • Related marketplace activity.

Marketplace information may contribute to Marketplace Assets and Marketplace Intelligence Assets.

2.3 Communications Information

We may collect information contained in:

  • Emails;
  • SMS messages;
  • Platform messages;
  • Customer support requests;
  • Marketplace communications;
  • Surveys;
  • Feedback submissions; and
  • Related communications.

Communications may be retained for customer support, compliance, security, dispute resolution, training, analytics, and Platform improvement purposes.

2.4 Device Information

We may automatically collect device-related information including:

  • IP addresses;
  • Browser type;
  • Operating system;
  • Device identifiers;
  • Device characteristics;
  • Network information;
  • Language settings; and
  • Related technical information.

2.5 Usage Information

We may collect information regarding Platform usage, including:

  • Login activity;
  • Session activity;
  • Page views;
  • Clickstream information;
  • Search activity;
  • User interactions;
  • Referral sources;
  • Navigation patterns; and
  • Related usage information.

2.6 Artificial Intelligence Interaction Information

Where Artificial Intelligence Systems are utilized, Off Mkts may collect information relating to:

  • User prompts;
  • User requests;
  • Recommendations;
  • Matches;
  • Routing interactions;
  • Analytics outputs;
  • Automated communications; and
  • Related interactions with Artificial Intelligence Systems.

2.7 Information from Third Parties

We may receive information from:

  • Service providers;
  • Marketplace participants;
  • Business partners;
  • Publicly available sources;
  • Marketing providers;
  • Analytics providers; and
  • Other lawful sources.

Information obtained from third parties may be combined with information collected directly through Platform activity.

3. Marketplace Information

The Platform is designed to facilitate opportunities, referrals, introductions, communications, and related marketplace activities.

As a result, Off Mkts may collect, generate, analyze, maintain, and utilize marketplace information relating to:

  • Marketplace participation;
  • Opportunity activity;
  • Referral activity;
  • Introduction activity;
  • Relationship activity;
  • Communications;
  • User engagement;
  • Marketplace trends;
  • Operational analytics; and
  • Related marketplace functions.

Marketplace information may contribute to Marketplace Assets and Marketplace Intelligence Assets.

Marketplace Intelligence Assets may include analytics, behavioral information, relationship intelligence, routing intelligence, marketplace insights, rankings, trends, and operational intelligence generated through Platform activity.

Off Mkts may utilize marketplace information to improve marketplace functionality, facilitate opportunities, enhance Platform performance, support Artificial Intelligence Systems, protect marketplace integrity, and improve User experience.

Users acknowledge that marketplace information may be processed, analyzed, aggregated, categorized, and utilized in connection with Platform operations and marketplace development.

4. How We Use Information

Off Mkts may use information collected through the Platform for lawful business, operational, compliance, security, marketplace, and technology purposes.

Information may be used to:

  • Operate the Platform;
  • Provide Platform services;
  • Facilitate opportunities, referrals, and introductions;
  • Facilitate marketplace participation;
  • Manage user accounts;
  • Respond to inquiries and provide customer support;
  • Communicate with Users;
  • Deliver and improve Platform functionality;
  • Maintain marketplace integrity;
  • Prevent fraud, detect abuse, and investigate misconduct;
  • Enforce Platform policies;
  • Comply with legal obligations;
  • Protect Users, Marketplace Assets, and Marketplace Intelligence Assets; and
  • Support business operations.

Information may also be used to evaluate Platform effectiveness, identify operational trends, improve User experience, and develop new Platform features and services. Off Mkts may aggregate, anonymize, pseudonymize, or de-identify information and may use such information for lawful business, operational, analytical, research, marketplace, technology, security, and product development purposes.

4.1 Communications

Off Mkts may use information to communicate with Users regarding:

  • Account activity;
  • Marketplace opportunities;
  • Referrals and introductions;
  • Platform updates;
  • Customer support matters;
  • Security matters;
  • Legal notices;
  • Compliance matters; and
  • Related Platform activities.

Communication practices are further described in the Off Mkts Consent to Contact Disclosure.

4.2 Security and Compliance

Information may be used to:

  • Verify identities;
  • Prevent fraud;
  • Detect suspicious activity;
  • Monitor Platform integrity;
  • Enforce contractual obligations;
  • Resolve disputes;
  • Protect Platform systems;
  • Investigate misconduct; and
  • Comply with legal obligations.

4.3 Analytics and Platform Improvement

Off Mkts may analyze information to improve:

  • Platform functionality;
  • Marketplace performance;
  • Artificial Intelligence Systems;
  • User experience;
  • Communications;
  • Opportunity matching;
  • Routing systems; and
  • Business development.

Analytics may be performed on an individual, aggregated, anonymized, pseudonymized, or de-identified basis where appropriate.

5. Artificial Intelligence Systems

Off Mkts may utilize Artificial Intelligence Systems in connection with Platform operations, including opportunity matching, lead routing, marketplace recommendations, analytics, communications, customer support, fraud detection, marketplace integrity, platform optimization, product development, and related operational activities.

Artificial Intelligence Systems may utilize information generated through Platform participation to improve matching accuracy, routing performance, marketplace functionality, analytics capabilities, operational efficiency, communications systems, and related Platform services.

Users acknowledge that Artificial Intelligence Systems may not always produce accurate, complete, current, reliable, or error-free outputs. Users remain responsible for independently evaluating recommendations, opportunities, referrals, communications, investments, transactions, and business decisions.

Information used by Artificial Intelligence Systems may be retained, analyzed, processed, categorized, and utilized in accordance with this Privacy Policy and applicable law.

6. Information Sharing

Off Mkts may share information where reasonably necessary to operate the Platform, provide services, facilitate marketplace participation, comply with legal obligations, protect Users, protect Platform operations, or support legitimate business purposes.

6.1 Service Providers

Information may be shared with service providers that assist with:

  • Hosting;
  • Cloud services;
  • Customer support;
  • Payment processing;
  • Communications;
  • Analytics;
  • Security;
  • Technology infrastructure;
  • Artificial Intelligence Systems; and
  • Related services.

Service providers may receive information only as reasonably necessary to perform services on behalf of Off Mkts.

6.2 Marketplace Participants

Information may be shared with marketplace participants where reasonably necessary to:

  • Facilitate opportunities;
  • Facilitate referrals;
  • Facilitate introductions;
  • Support marketplace communications;
  • Support transactions; or
  • Support marketplace participation.

Users acknowledge that marketplace participation may require sharing certain information with other participants.

6.3 Corporate Affiliates

Information may be shared among affiliated entities under common ownership or control with Off Mkts where reasonably necessary for business operations, customer support, technology operations, compliance, security, Platform administration, and related business purposes.

6.4 Professional Advisors

Information may be shared with attorneys, accountants, auditors, consultants, insurers, and professional advisors where reasonably necessary for legal, operational, compliance, insurance, business, or financial purposes.

6.5 Legal Compliance

Information may be disclosed where reasonably necessary to:

  • Comply with law;
  • Respond to legal process;
  • Cooperate with regulatory authorities;
  • Cooperate with law enforcement;
  • Protect legal rights;
  • Prevent fraud;
  • Protect Platform integrity; or
  • Protect Users.

6.6 Safety and Security

Information may be disclosed where reasonably necessary to:

  • Investigate misconduct;
  • Detect fraud;
  • Prevent abuse;
  • Respond to security incidents;
  • Protect Platform systems;
  • Protect Marketplace Assets;
  • Protect Marketplace Intelligence Assets; or
  • Protect the safety of Users.

7. Business Transfers

Users acknowledge that information maintained by Off Mkts may be reviewed, disclosed, transferred, licensed, assigned, sold, or otherwise conveyed in connection with:

  • Mergers;
  • Acquisitions;
  • Financings;
  • Reorganizations;
  • Asset sales;
  • Strategic transactions;
  • Joint ventures;
  • Business combinations; and
  • Successor entities.

Information may also be reviewed by prospective investors, lenders, acquirers, purchasers, advisors, financing sources, and transaction participants in connection with evaluation of a proposed transaction.

Any successor entity may continue to process information in accordance with applicable law and the privacy practices adopted by the successor entity.

8. Cookies and Tracking Technologies

Off Mkts may utilize cookies, analytics technologies, tracking technologies, session technologies, security technologies, and related tools to operate, maintain, improve, secure, and analyze the Platform.

These technologies may be used to:

  • Maintain sessions;
  • Authenticate Users;
  • Improve performance;
  • Analyze activity;
  • Measure engagement;
  • Improve User experience;
  • Detect fraud;
  • Protect security; and
  • Support Platform operations.

Users may be able to adjust browser settings to limit or disable certain cookies or tracking technologies. However, certain Platform functionality may be unavailable or impaired if such technologies are restricted.

9. Data Retention

Off Mkts retains information for as long as reasonably necessary to operate the Platform, comply with legal obligations, protect Users, protect Platform operations, protect Marketplace Assets, protect Marketplace Intelligence Assets, resolve disputes, enforce agreements, and support legitimate business operations.

Off Mkts may also maintain records including:

  • Accepted document versions;
  • Acceptance timestamps;
  • IP addresses;
  • Device information;
  • User agent information;
  • Communication preferences;
  • Account activity;
  • Platform activity;
  • Opt-in records; and
  • Opt-out records.

Information may be retained after account closure where reasonably necessary for compliance, dispute resolution, enforcement of agreements, security, fraud prevention, recordkeeping, marketplace protection, or other lawful purposes.

10. Security

Off Mkts implements reasonable administrative, technical, organizational, and operational safeguards designed to protect information against unauthorized access, disclosure, alteration, destruction, misuse, or loss. Security measures may include access controls, authentication procedures, security monitoring, encryption technologies where appropriate, vendor management practices, network protections, and security reviews.

Despite reasonable efforts, no method of transmission, storage, processing, or security system is completely secure. Users acknowledge that transmission of information over the internet involves inherent security risks and that no method of transmission or storage can be guaranteed to be completely secure.

Users are responsible for maintaining the confidentiality of account credentials and promptly reporting suspected unauthorized access or security concerns.

11. User Rights

Depending upon applicable law and jurisdiction, Users may possess certain rights relating to information maintained by Off Mkts.

Such rights may include:

  • Access rights;
  • Correction rights;
  • Deletion rights;
  • Restriction rights;
  • Objection rights;
  • Withdrawal of consent rights;
  • Portability rights; and
  • Other rights provided by applicable law.

Off Mkts may request information necessary to verify identity before responding to requests relating to personal information. Off Mkts may deny requests where permitted by law, including where compliance would interfere with legal obligations, security requirements, fraud prevention efforts, protection of Marketplace Assets, protection of Marketplace Intelligence Assets, or the rights of others.

Requests relating to privacy rights may be submitted using the contact information contained in this Privacy Policy.

12. Children’s Privacy

The Platform is intended for Users who are at least eighteen (18) years of age. Off Mkts does not knowingly collect personal information from children under thirteen (13) years of age.

If Off Mkts becomes aware that personal information has been collected from a child under thirteen (13) years of age without appropriate authorization, Off Mkts may take reasonable steps to delete such information. Parents or legal guardians who believe a child has submitted personal information to Off Mkts may contact Off Mkts using the contact information provided in this Privacy Policy.

13. International Users

Off Mkts operates primarily within the United States.

Information collected through the Platform may be processed, stored, maintained, reviewed, analyzed, and transferred within the United States and other jurisdictions where Off Mkts, its affiliates, service providers, contractors, partners, or vendors operate.

Data protection laws may differ among jurisdictions. By using the Platform, Users acknowledge that information may be transferred to, processed in, stored in, or maintained in jurisdictions that may have different privacy protections than those available in the User’s place of residence. Off Mkts will take reasonable measures to process information in accordance with this Privacy Policy and applicable law.

14. Changes to This Privacy Policy

Off Mkts may modify, update, revise, replace, or otherwise change this Privacy Policy from time to time due to changes in Platform functionality, business practices, marketplace operations, Artificial Intelligence Systems, legal requirements, technology, data practices, or other business developments.

Updated versions may be communicated through website postings, account notifications, email communications, Platform messages, or other reasonable methods. The “Last Updated” date appearing at the beginning of this Privacy Policy shall reflect the effective date of the most recent revision.

Continued use of the Platform following an update constitutes acknowledgment of the revised Privacy Policy to the fullest extent permitted by law.

15. Contact Information

Questions, requests, concerns, or notices relating to this Privacy Policy may be directed to Off Mkts LLC using the contact information below.

User Acknowledgment

By creating an account, accessing the Platform, submitting information, participating in marketplace activities, communicating through the Platform, or otherwise using Platform services, Users acknowledge that:

  • They have reviewed this Privacy Policy;
  • They understand this Privacy Policy;
  • They have had the opportunity to review this Privacy Policy;
  • They understand information may be collected, used, shared, stored, transferred, and processed as described herein;
  • They acknowledge the privacy practices described in this Privacy Policy; and
  • Electronic acceptance constitutes acknowledgment of this Privacy Policy.

Users further acknowledge that Off Mkts may maintain records relating to acceptance, accepted document versions, timestamps, IP addresses, device information, user agent information, communication preferences, Platform activity, and related records to demonstrate compliance, consent, acknowledgment, and operational administration.

Contact

OFF MKTS LLC

Website: www.offmkts.com

Email: legal@offmkts.com