TradeBrain Privacy Policy

Operated by Huffman & Finch LLC, Arlington, Virginia
Contact: privacy@tradebrain.us

Effective Date: June 12, 2026
Last Updated: June 14, 2026

1. Introduction

Huffman & Finch LLC, a Virginia limited liability company ("Company," "we," "us," "our"), operates TradeBrain, an AI phone agent and operating platform for trade-service businesses. This Privacy Policy explains what information we collect, how we use it, how we share it, and the choices you have. It applies to our websites at huffinch.com and tradebrain.us and to the TradeBrain service (the "Service").

2. Information We Collect

A. Information You Provide Directly

• Account Information: Business name, owner name, phone number, email, service area, license information, business address
• Customer Data: Customer phone numbers, contact information, service history, and notes you upload or create in TradeBrain
• Call Data: If Dana (our AI phone agent) is enabled, call recordings, transcripts, and voicemails
• Payment Information: Payment method, processed by Stripe, our third-party payment processor. We do not store full card numbers.

B. Information from Callers

When an individual contacts a business that uses our platform, we may process the phone number they call from and information they provide during the call (such as their name, service address, and the nature of their request) in order to handle the call and schedule service on the business's behalf.

C. Information Collected Automatically

• Usage Data: Features you use, frequency of use, account settings, scheduling patterns
• Device Data: Browser type, IP address, operating system
• Analytics: How you interact with the Service, which helps us improve performance
• Advertising and Analytics Pixels: We use third-party pixels (including Meta Pixel) on tradebrain.us to measure advertising effectiveness, track conversions, and build retargeting audiences. These pixels may store cookies in your browser and share data with Meta for those purposes.

D. Information from Third Parties

• Business Records: Company registration and license data from public records
• Payment Processors: Transaction history and payment status

3. How We Use Your Information

Primary Purposes:

• Provide and operate TradeBrain (scheduling, call handling, analytics)
• Answer and route calls, schedule and confirm appointments
• Support and maintain the Service
• Process payments and billing
• Respond to support requests
• Secure the platform and prevent fraud
• Enforce our agreements

Secondary Purposes (with your consent):

• Train and improve our AI models, only if you opt in, and only after we have implemented de-identification safeguards meeting applicable law
• Send updates about new features or service changes
• Analyze trends and benchmarks in aggregated, de-identified form

Legal Compliance:

• Comply with applicable laws and regulations
• Respond to legal requests and court orders
• Protect our legal rights

4. SMS / Text Messaging

The TradeBrain platform sends operational and transactional text messages on behalf of the trade-service businesses that use it. These include service-dispatch alerts to a business's own dispatch or office staff and appointment or booking confirmations related to a service request. Message types are limited to these operational and transactional purposes. We do not send marketing or promotional text messages through this program.

Message frequency varies based on call and appointment activity. Message and data rates may apply. Reply STOP to any message to opt out of further messages; reply HELP for help. For assistance you may also contact privacy@tradebrain.us.

Mobile information is never shared with third parties or affiliates for their marketing or promotional purposes, and we do not sell mobile information. Mobile opt-in data and consent are not shared with any third parties. We share information only with service providers that help us operate the platform (for example, our telephony and messaging provider, Twilio), strictly to deliver the service, and these providers are not permitted to use the information for their own marketing.

5. Sub-Processors and Data Sharing

We use the following vendors (sub-processors) to operate TradeBrain. Your data is transferred to and processed by:

We do not sell your personal information for monetary or other valuable consideration. We do not share your personal information for cross-context behavioral advertising.

Changes to Sub-Processors: If we add or replace a sub-processor that materially affects how your data is processed, we will update this Privacy Policy with 30 days' notice. You may cancel your account if you do not agree.

6. Business Transfer

If we are involved in a merger, acquisition, financing, sale of all or substantially all of our assets, reorganization, bankruptcy, or similar transaction, personal information held by us may be transferred to the acquiring or successor entity as a business asset. We will require any successor to honor this Privacy Policy and all then-existing opt-out and deletion requests, in accordance with applicable law (including California Civil Code section 1798.140 and AB 1824).

We expect to assign our customer agreements and associated data to a successor Delaware entity as part of a planned corporate reorganization in 2026. This intra-company transfer will be covered by the same data-handling commitments described in this Policy.

7. Data Retention

Active Account: While your account is active, we retain the data necessary to provide the Service (customer lists, call recordings, transcripts, account history). Call recordings are retained for up to 90 days; older recordings are deleted automatically.

After Cancellation:

• Personally identifiable information (names, phone numbers, addresses, emails) will be deleted from production systems and backups within 30 days of cancellation
• Call recordings and transcripts will be deleted
• Aggregate analytics and benchmarking data, in de-identified form, may be retained indefinitely
• You may request earlier deletion by contacting privacy@tradebrain.us

Legal Holds: If we receive a legal request or court order, we may be required to retain data longer than stated above.

8. Your Privacy Rights

Subject to verification of your identity, you may request to:

• Access: Receive a copy of the personal data we hold about you
• Portability: Receive your data in a portable format (CSV) within 30 days
• Correct: Correct inaccurate information
• Delete: Request deletion of personal data, subject to legal retention requirements
• Opt out: Opt out of AI model training (default: opted out), of marketing emails, and (if Dana is enabled) disable Dana at any time
• Revoke consent: Withdraw a previously given opt-in consent for AI training

Send requests to privacy@tradebrain.us. We will respond within 30 days. We will not discriminate against you for exercising any of these rights. You can opt out of operational text messages at any time by replying STOP.

9. California and Virginia Privacy Rights

We are not currently subject to the California Consumer Privacy Act (CCPA) or the Virginia Consumer Data Protection Act (VCDPA) based on the statutory thresholds for revenue and data volume. We nonetheless honor the substantive rights set out in those laws as a matter of policy.

California (CCPA / CPRA). If you are a California resident, you have the right to: know what categories of personal information are collected, used, sold, or shared; delete personal information (subject to exceptions); correct inaccurate personal information; opt out of the "sale" or "sharing" of personal information; limit use and disclosure of sensitive personal information; and receive non-discriminatory treatment for exercising these rights. We do not sell personal information for monetary or other valuable consideration. AI model training on de-identified data is not a "sale" under the CCPA when conducted within the de-identification safeguards required by law.

Virginia (VCDPA). If you are a Virginia resident acting in an individual or household context, you have the right to: confirm whether we process your personal data; access and correct your personal data; request deletion; obtain a portable copy; and opt out of targeted advertising, sale, or profiling.

10. Data Security

We use reasonable technical and organizational measures designed to protect information, including:

• HTTPS / TLS encryption for data in transit
• Encryption of sensitive data at rest at our sub-processors
• Access controls and authentication
• Multi-factor authentication
• Regular security testing and vulnerability assessments

No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

Breach Notification: If we discover a breach of personal data that creates a risk of harm to you, we will notify you without undue delay and within the timeframe required by applicable law.

11. Children's Privacy

The Service is intended for businesses and is not directed to individuals under 18. We do not knowingly collect personal information from children under 13. If we learn that we have collected data from a child under 13, we will delete it.

12. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify account holders by email at least 30 days before the change takes effect, and we will revise the "Last Updated" date above. Continued use of the Service after changes take effect constitutes acceptance.

13. Contact Us

For privacy questions, data access requests, or to exercise your rights:

Email: privacy@tradebrain.us
Mailing Address: Huffman & Finch LLC, 5039 9th Street South, Arlington, VA 22204

We will respond to requests within 30 days.