1. Introduction and Scope
This Privacy Policy ("Policy") describes how EXITios and Homera Partners LLC collect, use, disclose, retain, and protect personal information obtained from users, visitors, clients, prospects, and any other individuals ("you" or "User") who access or interact with our websites, mobile applications, software platforms, advisory services, and related offerings (collectively, the "Services"). By accessing or using our Services, you acknowledge that you have read, understood, and agree to the practices described in this Policy. If you do not agree, you must discontinue use of our Services immediately.
This Policy applies to all personal information collected online through our platforms, via email, text message, telephone, and any other communications channel. It governs data collected from individuals located in the United States and, to the extent applicable, individuals in jurisdictions with their own data protection frameworks, including the European Economic Area (EEA), the United Kingdom, and California.
2. Information We Collect
2.1 Information You Provide Directly
We collect information you voluntarily provide when you: create an account or register on our platform; submit a contact form, intake form, or onboarding questionnaire; communicate with us via email, telephone, or text message; subscribe to newsletters, alerts, or marketing communications; participate in surveys, user research, or beta programs; or engage our advisory, brokerage, or transactional services.
Categories of information collected directly include: full legal name; business name and title; email address; mailing address and physical location; telephone numbers, including mobile numbers; financial data submitted for analysis, including revenue figures, EBITDA, and business valuation inputs; deal-related documentation including letters of intent, purchase agreements, and due diligence materials; account credentials including usernames and passwords; and any other information you voluntarily submit.
2.2 Information Collected Automatically
When you access our Services, we automatically collect certain technical and usage data, including but not limited to: IP address; browser type and version; operating system; device identifiers; referring URLs; pages visited and time spent; clickstream data; session recordings; and interaction logs. This data is collected through cookies, web beacons, pixels, log files, and similar tracking technologies as further described in our Cookie Policy.
2.3 Information from Third Parties
We may receive information about you from third-party sources, including data enrichment providers, social media platforms, business databases, publicly available sources, referral partners, and co-marketing partners. We may combine this information with data we have already collected about you.
3. How We Use Your Information
We use the information we collect for the following purposes, each of which constitutes a lawful basis for processing: (a) to provide, operate, maintain, and improve our Services; (b) to process transactions and fulfill service agreements; (c) to communicate with you about your account, inquiries, and service updates; (d) to send promotional and marketing communications where you have provided consent or where we have a legitimate interest; (e) to analyze usage patterns and improve user experience; (f) to comply with legal and regulatory obligations; (g) to prevent fraud, enforce our Terms of Service, and protect the rights, property, and safety of our users and the public; (h) to conduct research and analytics; (i) to respond to legal process and law enforcement requests; and (j) to carry out any other purpose described to you at the time the information was collected.
4. TCPA Compliance and Telephone Communications
IMPORTANT NOTICE REGARDING TELEPHONE AND TEXT MESSAGE COMMUNICATIONS: By providing your telephone number, including your mobile phone number, to EXITios or Homera Partners LLC, and by checking the applicable consent box or executing a service agreement that references this Policy, you expressly consent to receive telephone calls, text messages (including SMS and MMS), and prerecorded or artificial voice messages from us and our authorized agents, including for marketing and informational purposes, to the telephone number(s) you provide, even if such number is listed on a federal, state, or internal Do Not Call registry.
This consent is provided pursuant to the Telephone Consumer Protection Act, 47 U.S.C. Section 227 ("TCPA"), and its implementing regulations at 47 C.F.R. Part 64. You acknowledge that: (1) your consent is not a condition of purchasing any goods or services from us; (2) you may revoke this consent at any time by replying "STOP" to any text message we send, by calling us at the number provided in this Policy, or by submitting a written revocation to our contact address below; (3) message and data rates may apply; (4) message frequency may vary; and (5) we are not responsible for any charges applied by your mobile carrier.
If you revoke consent to receive text messages, we will honor that revocation within a commercially reasonable time, not to exceed ten (10) business days. Revocation of consent to text communications does not revoke consent to receive email communications or other forms of contact unless you separately revoke such consent. We maintain records of consent in accordance with TCPA requirements and applicable regulations.
For California residents, this consent also satisfies the requirements of the California Consumer Privacy Act ("CCPA") as amended by the California Privacy Rights Act ("CPRA") with respect to the collection and use of your telephone number for direct marketing purposes.
5. CAN-SPAM Act and Email Communications Compliance
All commercial email communications sent by EXITios and Homera Partners LLC comply with the requirements of the Controlling the Assault of Non-Solicited Pornography And Marketing Act of 2003 ("CAN-SPAM Act"), 15 U.S.C. Sections 7701 et seq., and its implementing regulations at 16 C.F.R. Part 316. Specifically: (a) we do not use false or misleading header information; (b) we do not use deceptive subject lines; (c) all commercial email messages are identified as advertising where required; (d) each commercial email includes our valid physical postal address; (e) each commercial email includes a clear and conspicuous explanation of how you can opt out of receiving future commercial email from us; and (f) we honor opt-out requests promptly and within ten (10) business days of receipt.
By providing your email address to us, you consent to receive transactional and service-related emails at that address. Where required by law, we will obtain your affirmative consent before sending marketing or promotional emails. You may opt out of marketing emails at any time by clicking the "Unsubscribe" link included in any marketing email, by emailing us at the address provided in this Policy, or by updating your communication preferences in your account settings. Opting out of marketing emails will not prevent us from sending transactional, legal, or account-related notices.
For users located in the European Economic Area or United Kingdom, email marketing communications are sent only with your prior explicit consent, in compliance with the EU General Data Protection Regulation (GDPR) and the UK GDPR, and you have the right to withdraw that consent at any time.
6. Data Sharing and Disclosure
We do not sell your personal information to third parties for their own marketing purposes. We may share your information in the following circumstances: (a) with service providers and vendors who perform services on our behalf, subject to confidentiality obligations; (b) with professional advisors including attorneys, accountants, and consultants under attorney-client privilege or similar protections; (c) with other parties to a transaction where you have authorized such sharing in connection with M&A, brokerage, or advisory services; (d) with business partners and co-advisors where necessary to deliver the Services you requested; (e) with successors in the event of a merger, acquisition, or sale of all or substantially all assets; (f) in response to lawful subpoenas, court orders, or legal process; (g) to enforce our legal rights or protect against legal liability; and (h) with your consent.
7. California Privacy Rights (CCPA/CPRA)
If you are a California resident, you have the following rights under the California Consumer Privacy Act as amended by the California Privacy Rights Act: (a) the right to know what personal information we collect, use, disclose, and sell; (b) the right to delete personal information we have collected, subject to certain exceptions; (c) the right to correct inaccurate personal information; (d) the right to opt out of the sale or sharing of personal information; (e) the right to limit the use and disclosure of sensitive personal information; and (f) the right to non-discrimination for exercising your privacy rights. To exercise any of these rights, please submit a verifiable consumer request to us at the contact information below. We will respond within 45 days, with a possible extension of an additional 45 days where necessary.
8. Data Retention
We retain personal information for as long as necessary to fulfill the purposes described in this Policy, to comply with legal obligations, resolve disputes, enforce agreements, and as required by applicable law. When personal information is no longer needed, we securely delete or anonymize it. Deal-related and financial records may be retained for longer periods in accordance with industry standards and applicable regulatory requirements.
9. Security
We implement administrative, technical, and physical safeguards designed to protect your personal information against unauthorized access, disclosure, alteration, and destruction. These measures include encryption of data in transit and at rest, access controls, regular security assessments, and vendor due diligence. However, no data transmission over the internet or storage system is completely secure, and we cannot guarantee absolute security.
10. Children's Privacy
Our Services are not directed to individuals under the age of eighteen (18). We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take prompt steps to delete such information.
11. Changes to This Policy
We reserve the right to modify this Privacy Policy at any time. We will notify you of material changes by posting the revised Policy on our website with an updated effective date, and, where required by law, by providing additional notice via email or platform notification. Your continued use of the Services after the effective date of any modification constitutes your acceptance of the updated Policy.
12. Contact Information
For privacy-related inquiries, to exercise your rights, or to revoke consent to communications, please contact us at:
EXITios / Homera Partners LLC
Lehi, Utah 84043
Email: legal@exitios.com
Website: www.exitios.com