Privacy Policy

Last updated: April 27, 2026

This Privacy Policy explains how Bolt Foundry ("Bolt Foundry," "we," "us," or
"our") collects, uses, discloses, and protects personal information in
connection with Kelly, an AI-assisted transaction workflow tool for real estate
professionals.

1. Scope

This Privacy Policy applies to information we collect when you use Kelly,
interact with us, or connect third-party systems to Kelly.

2. Information We Collect

We may collect the following categories of information:

• account and contact information, such as name, email address, phone number,
  company name, role, and billing or account identifiers
• authentication and connected-account information, such as tokens,
  permissions, and system identifiers needed to access authorized third-party
  services
• transaction workflow information, such as buyer names, property addresses,
  transaction milestones, document status, signer status, and related task
  metadata
• document and content information, such as files, form names, document
  metadata, notes, instructions, and workflow comments that you authorize Kelly
  to process
• communications information, such as email intake messages, support requests,
  and status notifications
• technical and usage information, such as log data, timestamps, browser and
  device metadata, API activity, and system performance information

3. Sources of Information

We collect information:

• directly from you
• from systems you connect or authorize, such as email providers, Keller
  Williams Command, DocuSign, and ZipForms
• automatically from use of Kelly and related infrastructure

4. How We Use Information

We use information to:

• provide, operate, and maintain Kelly
• authenticate access and connect authorized third-party systems
• create, update, reconcile, and monitor transaction workflows
• organize, process, and route documents and workflow status
• send service-related notices, alerts, and support communications
• improve functionality, reliability, security, and product performance
• detect, investigate, prevent, and respond to misuse, fraud, and security
  issues
• comply with legal obligations and enforce our agreements

We do not use customer data to send marketing communications to customers'
buyers or other transaction participants.

5. How We Share Information

We may share information:

• with service providers and subprocessors who help us operate Kelly
• with connected third-party systems at your direction or through your
  authorized configuration
• with professional advisors, auditors, insurers, or financing counterparties
  where reasonably necessary
• when required by law, legal process, or governmental request
• to protect the rights, safety, security, or property of users, third parties,
  or Bolt Foundry
• in connection with a merger, acquisition, financing, reorganization, sale of
  assets, or similar transaction

We do not sell personal information for money. We do not share customer data
with third parties for their independent direct marketing purposes.

6. Legal Bases

Where applicable law requires a legal basis for processing, we rely on one or
more of the following:

• performance of a contract
• legitimate interests in operating, securing, and improving Kelly
• consent where required
• compliance with legal obligations

7. Data Retention

We retain information for as long as reasonably necessary to provide the
service, maintain security and operational records, resolve disputes, enforce
agreements, and comply with law.

Retention periods may vary depending on the type of information, the nature of
the workflow, contractual requirements, and legal obligations.

8. Data Security

We use reasonable administrative, technical, and organizational safeguards
designed to protect information against unauthorized access, loss, misuse,
alteration, and disclosure. No system can be guaranteed fully secure, and we
cannot guarantee absolute security.

9. Your Choices and Rights

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

• access personal information we hold about you
• request correction of inaccurate information
• request deletion of information, subject to exceptions
• object to or restrict certain processing
• request portability of certain information
• withdraw consent where processing is based on consent

To exercise these rights, contact us using the information below. We may need
to verify your identity before processing a request.

10. International Transfers

If we transfer information across borders, we take reasonable steps designed to
ensure that such transfers are subject to appropriate safeguards as required by
applicable law.

11. Children's Privacy

Kelly is not intended for children under 13, and we do not knowingly collect
personal information from children under 13.

12. Third-Party Services

Kelly may interact with third-party services that have their own privacy
practices. This Privacy Policy does not apply to the practices of third-party
services, and we encourage you to review their policies separately.

13. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material
changes, we will update the "Last updated" date and may provide additional
notice where appropriate.

14. Contact

If you have questions or requests relating to this Privacy Policy, contact:

Bolt Foundry
228 Park Ave S
New York, NY 10003
support@boltfoundry.com