Privacy Policy

BUGS AND BYTES LLC

Privacy and Data Use Policy

Last modified: June 2026 · Effective date: 1st June 2026

1. Introduction

This Privacy and Data Use Policy outlines BUGS AND BYTES LLC ("we," "our," or "the Company") practices with respect to information collected from users who access our website at www.bugsnbytesllc.com, our platform ambasSUBTOr™ at app.bugsnbytesllc.com, or otherwise share personal information with us (collectively: "Users"). This policy also satisfies the permissible purpose requirements of the Fair Credit Reporting Act, 15 U.S.C. § 1681 et seq. ("FCRA"), applicable to our ambasSUBTOr™ platform. When you use our website or platform, you consent to the collection, storage, use, and disclosure of your personal information as described in this policy. We encourage all users to read this policy carefully and use it to make informed decisions.

2. Grounds for data collection

Processing of your personal information (meaning any information which may potentially allow your identification with reasonable means; hereinafter "personal information") is necessary for the performance of our contractual obligations towards you, to provide you with our services, to protect our legitimate interests, and for compliance with legal and financial regulatory obligations to which we are subject.

3. What information we collect

We collect two types of information:

Non-personal information — unidentified and non-identifiable information including aggregated usage data and technical information transmitted by your device (browser type, operating system, language preference, access time, pages viewed, clicks, and actions).

Personal information — individually identifiable information, including:

Device information — geolocation data, IP address, unique identifiers (MAC address, UUID)
Registration information — full name, email address, physical address, and other details provided at registration
Platform usage data — license key activity, feature usage, and session data within ambasSUBTOr™
Policy acceptance records — timestamp, license key, and browser/device info recorded at the time of policy acceptance within ambasSUBTOr™

4. How we receive your information

When you voluntarily provide personal details to register on our site or platform
When you use or access our site or services
From third-party providers, services, and public registers (e.g., traffic analytics vendors)

5. How we use your information

Communicating with you — sending notices regarding our services, providing technical information, and responding to customer service inquiries
Keeping you informed of updates and new services
Marketing our website and products (see section 12)
Conducting statistical and analytical purposes intended to improve our site and platform
Maintaining FCRA compliance records related to ambasSUBTOr™ platform access and policy acceptance

6. SMS disclaimer

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. All SMS messaging originator opt-in data and consent information will not be shared with any third parties.

All SMS outreach conducted by BUGS AND BYTES LLC or ambasSUBTOr™ platform users must comply with the Telephone Consumer Protection Act (TCPA), 47 U.S.C. § 227:

Contact only consumers who have publicly listed their phone number in connection with a property for sale
All SMS messages must identify the sender by name and entity
All SMS messages must include a clear opt-out mechanism (e.g., "Reply STOP to opt out")
Opt-out requests must be honored immediately and lead status updated within 24 hours
Do not contact numbers listed on the National Do Not Call Registry without prior express written consent
Opt-out records must be retained for a minimum of 5 years

7. FCRA permissible purpose — ambasSUBTOr™ platform

BUGS AND BYTES LLC hereby declares that all consumer data accessed through skip trace providers, consumer reporting agencies, and data aggregators via the ambasSUBTOr™ platform is accessed solely for the following FCRA-recognized permissible purposes:

FCRA § 1681b(a)(3)(F)(i) — in connection with a credit transaction involving the extension of credit to the consumer
FCRA § 1681b(a)(3)(F)(ii) — in connection with a business transaction initiated by the consumer, specifically a consumer who has publicly listed their property for sale and thereby initiated contact with the marketplace for the purpose of completing a real property transaction

Consumer data accessed through the platform is limited to identifying property owners who have publicly listed or indicated their intent to sell real property, for the sole purpose of initiating a legitimate real estate acquisition transaction.

Prohibited uses. Consumer data obtained through the ambasSUBTOr™ platform shall not be used for: marketing of unrelated products or services; employment, tenant, or credit screening; resale or redistribution to any third party; harassment or any contact violating federal or state consumer protection law; or building marketing databases unrelated to specific real estate transactions.

CAN-SPAM compliance. All email outreach must include the sender's physical mailing address, a functional unsubscribe mechanism, and must not use deceptive subject lines. Unsubscribe requests must be honored within 10 business days.

8. Data retention and disposal

We retain personal information for as long as necessary to provide our services and comply with our legal obligations. For ambasSUBTOr™ platform data specifically:

Active leads — retained 12 months from creation, then auto-archived
Qualified leads (deal in progress) — retained for duration of transaction plus 3 years
Dead leads (no response / declined) — hard deleted within 90 days of last contact
Closed transaction records — retained 7 years per legal and tax requirements
Skip trace raw output — hard deleted within 90 days
Policy acceptance records — retained indefinitely as legal compliance records

9. Data security

We take great care in implementing and maintaining the security of our site and your information. We employ industry-standard procedures and policies to ensure the safety of information we collect and retain. For ambasSUBTOr™ specifically:

All consumer data is stored in encrypted, access-controlled cloud database infrastructure
Role-based access controls restrict data to authorized personnel and licensed platform users only
No consumer data is stored in plaintext outside of encrypted database fields
API credentials are stored as environment variables and never hardcoded in source code

Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our site, and we make no warranty, express, implied, or otherwise, that we will prevent such access.

10. Sharing of information

We do not rent, sell, or share users' information with third parties except as described in this policy. We may share personal information with trusted third-party providers for the following purposes:

Hosting and operating our site and platform
Providing you with our services, including personalized display of our site
Storing and processing information on our behalf
Performing research, technical diagnostics, or analytics

We may also disclose information if we have good faith to believe that disclosure is helpful or reasonably necessary to: comply with applicable law or governmental request; enforce our policies; investigate illegal activities, suspected fraud, or security issues; establish or exercise rights to defend against legal claims; or prevent harm to the rights, property, or safety of us, our users, or any third party.

11. Cookies

We and our trusted partners use cookies and other technologies on our site and platform. We use the following types:

Session cookies — stored temporarily during a browsing session and deleted when the browser is closed
Persistent cookies — saved on your device for a fixed period to remember your preferences for repeat visits
Third-party cookies — set by other online services running content on the page you are viewing, such as analytics companies

We also use Google Analytics to collect information about your use of the site. You may remove cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our site may not operate properly.

You may opt out of third-party ad networks through the Network Advertising Initiative at optout.networkadvertising.org or the Digital Advertising Alliance at optout.aboutads.info.

12. Marketing

We may use your personal information to provide you with promotional materials concerning our services which we believe may interest you. All marketing communications include means to decline further marketing offers. If you unsubscribe, we will remove your contact information from our marketing distribution lists. Please note that even if you have unsubscribed from marketing emails, we may send other types of important communications such as customer service announcements or administrative notices.

13. Consumer dispute resolution — ambasSUBTOr™

In the event a consumer disputes the accuracy of information obtained through the ambasSUBTOr™ platform, BUGS AND BYTES LLC will acknowledge the dispute in writing within 5 business days, cease use of disputed data pending resolution, notify the applicable data provider, complete its investigation within 30 days, and notify the consumer of the resolution in writing. Platform support and dispute inquiries: [email protected].

Violation of the ambasSUBTOr™ data use terms may result in immediate termination of platform access and civil liability under FCRA — statutory damages of $100–$1,000 per willful violation; actual damages for negligent violations.

14. Your rights

You may request to:

Receive confirmation as to whether personal information concerning you is being processed, and access your stored personal information
Receive a copy of personal information you directly volunteered to us in a structured, commonly used, and machine-readable format
Request rectification of your personal information that is in our control
Request erasure of your personal information
Object to the processing of personal information by us
Request restriction of processing of your personal information
Lodge a complaint with a supervisory authority

To exercise any of these rights, contact our Data Protection Officer at [email protected].

15. Minors

Our site and platform are not designed for or directed at children. Under no circumstances shall we allow use of our services by minors without prior consent or authorization by a parent or legal guardian. We do not knowingly collect personal information from minors.

If a parent or guardian becomes aware that their child has provided us with personal information without consent, they should contact us at [email protected].

16. Transfer of data outside the EEA

Some data recipients may be located outside the European Economic Area. In such cases we will transfer your data only to countries approved by the European Commission as providing adequate data protection, or we will enter into legal agreements ensuring an adequate level of data protection.

17. Corporate transactions

We may share information in the event of a corporate transaction such as a sale of a substantial part of our business, merger, consolidation, or asset sale. In the event of the above, the transferee or acquiring company will assume the rights and obligations as described in this policy.

18. Third-party sites

This policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or sites throughout the internet, different rules may apply. This policy does not apply to the practices of companies we do not own or control, or to individuals we do not employ or manage.

19. Updates to this policy

We reserve the right to periodically amend or revise this policy. Material changes will be effective immediately upon display of the revised policy. The last revision will be reflected in the "last modified" date above. Your continued use of our site or platform following notification of such amendments constitutes your acknowledgment and consent to the amended policy.

20. How to contact us

For general inquiries:

BUGS AND BYTES LLC

P.O. Box 810231, Boca Raton FL 33481

[email protected]

www.bugsnbytesllc.com

For ambasSUBTOr™ platform support and dispute resolution:

[email protected]

Data Protection Officer — BUGS AND BYTES LLC:

[email protected]

P.O. Box 810231, Boca Raton FL 33481