Privacy Policy

A LEGAL DISCLAIMER

OZXpro Privacy Policy

Effective Date: March 1, 2026

JBXpro LLC d/b/a OZXpro · 7600 Wayzata Blvd., Minneapolis, MN 55426

This Privacy Policy explains how JBXpro LLC d/b/a OZXpro collects, uses, discloses, and protects information about you when you visit www.ozxpro.com or use the OZXpro compliance platform. Please read it carefully.

1. Who We Are

JBXpro LLC, doing business as OZXpro ("OZXpro," "we," "us," or "our"), is a Minnesota limited liability company located at 7600 Wayzata Blvd., Minneapolis, MN 55426. We operate the OZXpro public website at www.ozxpro.com (the "Website") and the OZXpro compliance platform (the "Platform"), a subscription-based software product for Qualified Opportunity Fund managers.

This Privacy Policy covers two distinct contexts: (a) your use of the public Website, including as a visitor or prospective customer; and (b) your use of the Platform as a registered subscriber. Platform subscribers are also subject to the OZXpro End User License Agreement ("EULA"), which governs data rights in greater detail.

2. Information We Collect

2.1 Information You Provide

We collect information you voluntarily provide to us, including:

Contact and inquiry information: name, email address, phone number, company name, and job title submitted through contact forms, demo requests, or direct email correspondence.
Account registration information: email address, name, and organization details provided when creating a Platform account.
Payment information: billing name, address, and payment card details. Payment transactions are processed by our third-party payment processor; OZXpro does not store full payment card numbers.
Platform data: all data, documents, financial records, investor information, fund EIN details, and other content you upload or enter into the Platform ("User Data"), as defined in the EULA.
Communications: records of your correspondence with us, including support requests and feedback.

2.2 Information Collected Automatically

When you visit the Website or use the Platform, we and our service providers may automatically collect:

Log data: IP address, browser type and version, operating system, referring URLs, pages visited, and timestamps.
Device data: device identifiers, screen resolution, and hardware model.
Usage data: features accessed, clicks, search queries within the Platform, session duration, and error logs.
Cookie and tracking data: as described in Section 5 below.

2.3 Information from Third Parties

We may receive information about you from third parties, including:

Analytics providers such as Google Analytics, which provide aggregated information about Website traffic and user behavior.
Advertising and marketing platforms such as Meta (Facebook/Instagram) and LinkedIn, which may match your contact information with their user databases for advertising purposes, subject to their own privacy policies.
Third-party integrations you enable within the Platform, such as QuickBooks, Xero, or Sage, which may transmit financial data to the Platform in connection with your account.

3. How We Use Your Information

We use the information we collect for the following purposes:

To operate and provide the Platform Data used: Account data, User Data, payment data · Legal basis: Contract performance

To respond to inquiries and provide support Data used: Contact data, communications · Legal basis: Legitimate interests

To process payments and manage subscriptions Data used: Payment data, account data · Legal basis: Contract performance

To send transactional communications (receipts, alerts, compliance reminders) Data used: Email address, account data · Legal basis: Contract performance

To send marketing communications (product updates, newsletters) Data used: Email address, name · Legal basis: Consent / legitimate interests

To analyze Website usage and improve our products Data used: Log data, usage data, analytics data · Legal basis: Legitimate interests

To serve targeted advertising on third-party platforms Data used: Cookie data, pixel data · Legal basis: Consent

To generate Derived Data for commercial use (as defined in the EULA) Data used: User Data (anonymized/aggregated) · Legal basis: Contract / legitimate interests

To comply with legal obligations Data used: As required by law · Legal basis: Legal obligation

To enforce our agreements and protect our rights Data used: All categories as necessary · Legal basis: Legitimate interests

We do not use User Data to make automated decisions that produce legal or similarly significant effects on you without human review.

4. Platform Data and Derived Data

4.1 User Data

User Data you submit through the Platform — including fund financial records, investor information, ownership data, and compliance documentation — is used solely to provide and improve the Platform services, as described in the EULA. OZXpro does not sell raw, identifiable User Data to third parties.

You retain ownership of your User Data in its raw, identifiable form. OZXpro holds a license to process User Data during the term of your subscription for purposes of providing the Platform and generating Derived Data, as further described in the EULA.

4.2 Derived Data

OZXpro may generate "Derived Data" — aggregated, anonymized analytics, benchmarks, and insights produced from processing User Data that do not identify, and cannot reasonably be used to identify, you, your fund, your investors, or any individual. OZXpro owns all Derived Data and may use it for commercial purposes, including product development, market research, and data licensing.

You may opt out of having your data included in third-party Derived Data products by emailing privacy@ozxpro.com with the subject line "Derived Data Opt-Out." See the EULA for full details.

4.3 Data Retention and Data Location

We retain User Data for the duration of your subscription and for thirty (30) days following termination, during which time you may export your data. Timestamped audit logs may be retained longer for legal and regulatory compliance purposes. Contact data and communications are retained as long as necessary to fulfill the purposes described in this Policy or as required by law. Specific retention periods depend on the type of information and applicable legal obligations, and may vary accordingly.

OZXpro uses third-party infrastructure providers to host and operate the Platform and Website. These providers may store and process data in the United States or other jurisdictions where they or their subprocessors operate. By using the Website or Platform, you acknowledge that your data may be transferred to and stored in countries outside your country of residence, which may have different data protection laws than your own.

5. Cookies and Tracking Technologies

5.1 Types of Cookies We Use

We use the following categories of cookies and tracking technologies on the Website:

Strictly necessary cookies: required for the Website to function, including session management and security. These cannot be disabled.
Analytics cookies: tools such as Google Analytics that help us understand how visitors use the Website — which pages are visited, how long users stay, and where they come from. This data is aggregated and used to improve the Website.
Marketing and advertising pixels: tracking pixels placed by third-party advertising platforms including Meta and LinkedIn. These allow us to measure the effectiveness of our advertising campaigns and serve targeted advertisements to you on those platforms. These pixels may collect your IP address, browser data, and behavioral information.
Preference cookies: used to remember your settings and choices across sessions.

5.2 Your Cookie Choices

You may manage or disable non-essential cookies through your browser settings or any cookie consent tool we provide on the Website. Please note that disabling certain cookies may affect Website functionality. For information about opting out of Google Analytics tracking, visit tools.google.com/dlpage/gaoptout. For information about opting out of Meta or LinkedIn advertising, visit their respective privacy settings pages.

6. How We Share Your Information

We do not sell your personal information. Certain advertising practices, such as our use of third-party pixels and behavioral advertising, may be considered "sharing" of personal information under the CPRA or similar state laws. We may share your information in the following limited circumstances:

6.1 Service Providers

We share information with trusted third-party vendors who assist us in operating the Website and Platform, including cloud hosting providers, payment processors, email delivery services, analytics providers, and customer support tools. These providers are contractually required to use your data only as directed by OZXpro and to maintain appropriate security.

6.2 Advertising Platforms

We share limited data (such as email addresses or pixel-generated identifiers) with advertising platforms including Meta and LinkedIn for the purpose of serving targeted advertisements and measuring campaign performance. These platforms operate under their own privacy policies and may combine data we share with other data they hold about you.

6.3 Third-Party Integrations

If you enable integrations with third-party accounting platforms such as QuickBooks, Xero, or Sage, data may be transmitted between the Platform and those services. Such sharing is at your direction and subject to the third party's own terms and privacy policy.

6.4 Business Transfers

In the event of a merger, acquisition, financing, or sale of all or substantially all of OZXpro's assets, your information may be transferred to the successor entity. We will provide notice before your information is transferred and becomes subject to a different privacy policy.

6.5 Legal Requirements and Government Requests

We may disclose your information if required to do so by law, court order, or valid government request, or if we believe disclosure is necessary to protect the rights, property, or safety of OZXpro, our users, or the public. OZXpro may also disclose information to law enforcement agencies, regulatory authorities, or other government bodies where required by applicable law or compelled by legal process. Where permitted by law, OZXpro will endeavor to notify affected users of such requests prior to disclosure.

6.6 With Your Consent

We may share your information for other purposes with your prior written consent.

7. Data Security

OZXpro maintains commercially reasonable administrative, technical, and physical safeguards to protect your information against unauthorized access, loss, or destruction. These measures include encryption of data at rest and in transit, access controls, and regular security assessments.

No system can guarantee absolute security. In the event of a confirmed data breach affecting your personal information, OZXpro will notify affected users as required by applicable law.

8. Your Rights and Choices

8.1 General Rights

Depending on your location and applicable law, you may have the right to:

Access the personal information we hold about you;
Request correction of inaccurate or incomplete information;
Request deletion of your personal information, subject to certain exceptions;
Object to or restrict certain types of processing;
Request portability of your personal information in a structured, machine-readable format;
Withdraw consent where processing is based on consent, without affecting the lawfulness of prior processing;
Opt out of marketing communications at any time by clicking "Unsubscribe" in any email or contacting us at privacy@ozxpro.com.

8.2 California Residents

If you are a California resident, you have rights under the California Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA), including the right to know what personal information we collect, the right to delete, the right to correct, and the right to opt out of the "sale" or "sharing" of personal information. OZXpro does not sell personal information as defined under the CCPA. To exercise your California rights, contact us at privacy@ozxpro.com.

Residents of certain other U.S. states, including Colorado, Virginia, Texas, and others, may have additional privacy rights under applicable state privacy laws, such as the right to access, correct, delete, or opt out of certain processing of their personal information. OZXpro will honor such rights to the extent required by applicable law. To submit a request, contact us at privacy@ozxpro.com.

8.3 EU and UK Residents

If you are located in the European Economic Area (EEA) or United Kingdom, the General Data Protection Regulation (GDPR) or UK GDPR may apply to our processing of your personal data. In that case:

OZXpro acts as the data controller for personal data collected through the Website and as a data processor for User Data submitted through the Platform on behalf of subscribers.
Our legal bases for processing include contract performance, legitimate interests, legal obligation, and consent (as described in Section 3 above).
You have the rights described in Section 8.1 above, and may also lodge a complaint with your local data protection authority.
For data transfers from the EEA or UK to the United States, OZXpro relies on appropriate safeguards including Standard Contractual Clauses where required. Contact us at privacy@ozxpro.com for more information.

To exercise any of your rights, please contact us at privacy@ozxpro.com. We will respond within thirty (30) days, or as otherwise required by applicable law.

9. Children's Privacy

The Website and Platform are intended for use by business professionals and are not directed to children under the age of 13. We do not knowingly collect personal information from children under 13. If we become aware that we have collected such information, we will promptly delete it. If you believe we have inadvertently collected information from a child, please contact us at privacy@ozxpro.com.

10. Third-Party Websites

The Website may contain links to third-party websites. This Privacy Policy does not apply to those sites, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party sites you visit.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will post the updated Policy on this page with a revised effective date and, where appropriate, notify you by email. Your continued use of the Website or Platform after the effective date of any change constitutes your acceptance of the updated Policy.

12. How to Contact Us

For questions, requests, or complaints regarding this Privacy Policy or our data practices, please contact us:

JBXpro LLC d/b/a OZXpro 7600 Wayzata Blvd., Minneapolis, MN 55426 privacy@ozxpro.com (privacy requests and opt-outs) legal@ozxpro.com (legal and DMCA notices) info@ozxpro.com · www.ozxpro.com