Privacy Policy

Effective Date: June 8th, 2026 · Last Updated: June 8th, 2026

This Privacy Policy explains how CNH Holdings Inc and its subsidiary Elite Business Exchange collects, uses, stores, discloses, protects, and processes personal information when users access or use CNH websites, platforms, applications, tools, services, data rooms, valuation tools, analytics systems, communication tools, listing systems, buyer portals, seller portals, broker portals, lender portals, institutional products, and related services.

This Privacy Policy applies to all CNH-owned, affiliated, subsidiary, branded, or white-labeled platforms and services, including but not limited to:

CNH Holdings Inc.
Elite Business Exchange
Smart Biz Exchange
S2 Strategic Partners
ModelCore
Insight360
DealStream
PrivateStack
InsightX
CNH websites
CNH data rooms
CNH valuation tools
CNH analytics tools
CNH enterprise products
CNH lender or institutional portals
Related CNH services

For purposes of this Privacy Policy, "CNH," "Company," "we," "us," or "our" means CNH Holdings Inc. and its affiliates, subsidiaries, successors, assigns, contractors, service providers, and authorized representatives.

"User," "you," or "your" means any person accessing or using the Platform, including brokers, sellers, buyers, lenders, advisors, investors, institutions, enterprise users, website visitors, account holders, authorized representatives, and other users.

By accessing or using the Platform, you agree to this Privacy Policy.

Plain-English Summary

This summary is for convenience only. If there is a conflict between this summary and the full Privacy Policy, the full Privacy Policy controls.

CNH's privacy position is:

CNH collects personal information needed to operate accounts, listings, data rooms, subscriptions, communications, buyer/seller/broker/lender workflows, and platform tools.
CNH may share information with authorized users when needed for platform functionality.
CNH may use service providers to host, process, secure, analyze, and support the Platform.
CNH logs activity such as document views, downloads, account access, messages, and data room usage for security, audit, analytics, and platform operations.
CNH may use personal information to communicate with users, provide services, process payments, prevent fraud, and improve products.
CNH may retain information for legal, business, security, transaction, and compliance purposes.
CNH may transfer information in connection with financing, acquisition, sale, licensing, restructuring, white-label deployment, or other business transactions.
CNH's Data Usage Agreement separately governs business data, platform data, derived data, anonymized data, benchmark data, AI/model data, and platform intelligence.

1. Purpose of This Privacy Policy

This Privacy Policy explains:

What personal information CNH collects
How CNH collects personal information
How CNH uses personal information
How CNH shares personal information
How CNH protects personal information
How long CNH may retain personal information
What choices users may have regarding personal information
How this Privacy Policy relates to CNH's Data Usage Agreement

This Privacy Policy is intended to address personal information. Business information, transaction information, platform data, derived data, analytics, anonymized data, de-identified data, benchmark data, and platform intelligence are also governed by CNH's Data Usage Agreement.

2. Relationship to Other CNH Agreements

This Privacy Policy supplements CNH's:

Master Platform Terms of Service
Data Usage Agreement
Platform Confidentiality Agreement
Broker and Intermediary User Agreement
Seller User Agreement
Buyer User Agreement
Lender and Institutional User Agreement
AI, Valuation, Analytics, and Model Output Terms
Subscription and Billing Terms
Data Room Access Terms
API and Data Access Terms
Enterprise Agreements
White-Label or Licensing Agreements
Any applicable order form, statement of work, or written agreement

If there is a conflict between this Privacy Policy and a signed written agreement between you and CNH, the signed written agreement controls only to the extent of the conflict.

Questions or requests regarding this Privacy Policy may be directed to: CNH Holdings Inc., Attn: Privacy, 30 N Gould St. # 47506, Sheridan, WY 82801. [Insert Email] [Insert Phone Number]

3. Personal Information We May Collect

CNH may collect personal information directly from users, automatically through the Platform, from other users, from service providers, from business partners, from public sources, or from third-party data sources.

Personal information may include:

A. Account Information

Name
Email address
Phone number
Username
Password or authentication credentials
Role or user type
Company name
Job title
Brokerage, institution, employer, or organization
Account preferences
Subscription information
User permissions
Profile information

B. Contact Information

Mailing address
Business address
Billing address
Email address
Phone number
Communication preferences
Referral information

C. Identity and Verification Information

Depending on Platform functionality, CNH may collect or process:

Identity verification information
Business affiliation information
Professional license or credential information
Buyer qualification information
Seller authority information
Broker authority information
Lender or institutional authorization information
Proof of funds-related identifying information
Authorized representative information

CNH may use third-party providers to assist with identity verification, payment processing, fraud prevention, or compliance workflows.

D. Payment and Billing Information

CNH may collect or process:

Billing name
Billing address
Payment method information
Subscription plan
Invoice history
Payment status
Transaction history
Tax information where applicable

Payment card or bank information may be processed by third-party payment processors. CNH may not store full payment card numbers unless expressly stated or required for a specific payment method.

E. Communications

CNH may collect and retain communications, including:

Emails
Platform messages
Support requests
Chat messages
Inquiry forms
Buyer/seller communications
Broker communications
Lender communications
Data room Q&A
Meeting notes
Call notes
Feedback
Survey responses
Testimonials or comments submitted by users

F. Platform Activity Information

CNH may collect information about how users interact with the Platform, including:

Login activity
Pages viewed
Features used
Listings viewed
Searches performed
Documents accessed
Data rooms accessed
Messages sent
Files uploaded
Files downloaded
Reports generated
Valuation tools used
Analytics viewed
Buyer inquiries submitted
Seller listings created
Broker workflows used
Lender or institutional dashboards accessed

G. Device, Technical, and Log Information

CNH may collect technical information, including:

IP address
Browser type
Device type
Operating system
Referring pages
Session information
Access times
Cookie identifiers
Device identifiers
Error logs
Security logs
API logs
Authentication events
Approximate location inferred from IP address

H. Business-Related Personal Information

Because CNH platforms support business sales, acquisitions, lending, and diligence workflows, some business information may contain personal information, including:

Owner names
Employee information
Customer contact details
Vendor contact details
Advisor contact details
Broker contact details
Buyer representative details
Lender representative details
Shareholder, member, partner, or officer information

Users are responsible for ensuring they have authority to submit personal information relating to third parties.

4. Information Users Submit About Others

Users may submit information about other individuals, including owners, employees, buyers, sellers, brokers, advisors, lenders, contractors, customers, vendors, partners, shareholders, members, managers, or representatives.

By submitting personal information about another person, you represent that:

You have authority to provide the information
You have obtained any required consent
Your submission does not violate law, contract, privacy obligation, confidentiality duty, or third-party right
The information is accurate to the best of your knowledge

CNH may rely on your representation that you have authority to submit such information.

5. How CNH Collects Personal Information

CNH may collect personal information:

Directly from you
When you create an account
When you complete forms
When you upload documents
When you create listings
When you submit buyer or seller information
When you request valuations or reports
When you access data rooms
When you communicate through the Platform
When you contact support
When you make payments
When you attend meetings or events
When another user invites you to the Platform
When another user submits your information
Automatically through cookies, logs, and similar technologies
From service providers
From business partners
From public sources
From third-party data sources where lawful

6. How CNH Uses Personal Information

CNH may use personal information to:

A. Provide and Operate the Platform

Create and manage accounts
Authenticate users
Provide access to Platform features
Display listings
Enable messaging
Manage data rooms
Support buyer/seller/broker/lender workflows
Provide valuation and analytics tools
Generate reports
Enable subscriptions
Provide customer support
Maintain user permissions

B. Support Transaction and Platform Workflows

Facilitate buyer inquiries
Support seller listing workflows
Support broker workflows
Support lender or institutional review
Enable data room permissions
Track document access
Support diligence workflows
Support financing-readiness workflows
Support communication between authorized parties
Support user verification and qualification

C. Improve Products and Services

Analyze Platform usage
Improve user experience
Improve workflows
Improve valuation tools
Improve analytics tools
Improve AI and model systems
Develop new features
Troubleshoot issues
Measure product performance
Generate aggregated, anonymized, de-identified, derived, or benchmark data as described in the Data Usage Agreement

D. Communicate With Users

Send account notices
Send security alerts
Send support messages
Send billing notices
Send product updates
Send transactional notifications
Respond to inquiries
Request feedback
Send marketing communications where permitted

E. Billing and Payments

Process subscriptions
Send invoices
Manage payments
Prevent payment fraud
Manage taxes
Resolve billing disputes
Enforce payment terms

F. Security, Fraud Prevention, and Enforcement

Detect unauthorized access
Prevent fraud
Protect accounts
Investigate suspicious activity
Enforce agreements
Prevent misuse of confidential information
Prevent scraping or unauthorized data extraction
Protect CNH, users, and third parties

G. Legal and Compliance Purposes

Comply with law
Respond to subpoenas, court orders, or government requests
Maintain business records
Resolve disputes
Enforce legal rights
Defend claims
Support audits
Comply with regulatory obligations where applicable

H. Business Operations and Corporate Transactions

Manage CNH business operations
Conduct financing, investment, diligence, or corporate planning
Support mergers, acquisitions, restructurings, sales, licensing, enterprise deployments, white-label arrangements, or business transfers
Transfer information as part of a permitted business transaction

7. Data Usage, Analytics, and Derived Intelligence

CNH may use personal information and related platform activity as part of broader Platform operations, analytics, security, product development, and data-processing workflows. However, CNH's use of business, transaction, platform, derived, anonymized, aggregated, de-identified, benchmark, and intelligence data is governed primarily by CNH's Data Usage Agreement. CNH may use personal information to create or support:

Aggregated Data
Anonymized Data
De-Identified Data
Derived Data
Benchmark Data
Platform Intelligence
AI/Model Data
Statistical outputs
Product improvements
Market intelligence

CNH does not sell private deal documents, confidential business financials, tax returns, or non-public transaction materials in directly identifiable form without authorization, except as permitted by applicable agreements or law.

8. How CNH Shares Personal Information

CNH may share personal information in the following circumstances:

A. With Authorized Platform Users

CNH may share information with users authorized to access it, including:

Brokers
Sellers
Buyers
Lenders
Advisors
Institutions
Enterprise administrators
Data room administrators
Transaction participants
Authorized representatives

For example, CNH may share buyer profile information with a seller or broker, seller contact information with an authorized broker, or data room activity with a seller or broker.

B. With Service Providers

CNH may share information with third-party service providers who help operate the Platform, including:

Hosting providers
Payment processors
CRM providers
Email providers
Messaging providers
Analytics providers
Security providers
Identity verification providers
E-signature providers
Customer support tools
Developers
Consultants
Legal, accounting, and professional advisors

Service providers may process information on CNH's behalf and according to applicable agreements.

C. With Business Partners or Integrated Services

CNH may share information with authorized business partners or integrated services where needed to provide a requested feature, service, integration, transaction workflow, financing workflow, data room workflow, or enterprise functionality.

D. With Legal Authorities or Required Parties

CNH may disclose information when required or reasonably necessary to:

Comply with law
Respond to legal process
Comply with court orders
Respond to subpoenas
Cooperate with regulatory requests
Protect rights
Investigate fraud
Prevent harm
Enforce agreements
Defend legal claims

E. In Business Transfers

CNH may disclose, transfer, assign, or make available personal information in connection with:

Merger
Acquisition
Financing
Investment
Sale of assets
Sale of equity
Corporate restructuring
Reorganization
Bankruptcy
Assignment
Affiliate transfer
Subsidiary sale
Product spin-off
White-label licensing
Platform licensing
Strategic partnership
Enterprise deployment
Sale or licensing of a CNH product line

Any successor or transferee may continue to process information consistent with this Privacy Policy and applicable agreements.

F. With Consent or Direction

CNH may share information when you consent, request, authorize, invite another user, grant data room access, submit an inquiry, connect with a broker, connect with a buyer, connect with a lender, or otherwise direct CNH to share information.

G. Aggregated, Anonymized, De-Identified, or Derived Data

CNH may share aggregated, anonymized, de-identified, derived, benchmark, statistical, or platform intelligence data as described in the Data Usage Agreement. This type of data is not intended to directly identify a specific person.

9. Cookies and Similar Technologies

CNH may use cookies, pixels, local storage, session identifiers, analytics tools, and similar technologies to:

Keep users logged in
Remember preferences
Improve Platform performance
Analyze usage
Measure marketing effectiveness
Detect fraud
Improve security
Support product development
Personalize user experience

Users may be able to control cookies through browser settings. Disabling cookies may affect Platform functionality. CNH may provide a separate Cookie Policy where required or appropriate.

10. Marketing Communications

CNH may use contact information to send marketing communications, product updates, newsletters, event invitations, surveys, promotional materials, or educational content where permitted by law. Users may opt out of marketing emails by using unsubscribe links or contacting CNH. Even if you opt out of marketing communications, CNH may still send transactional, security, billing, account, legal, or service-related communications.

11. Data Room and Activity Visibility

Certain Platform activity may be visible to authorized users. For example:

Sellers or brokers may see buyer document views
Sellers or brokers may see buyer inquiries
Enterprise administrators may see team usage
Data room administrators may see access logs
CNH administrators may review activity for support, security, compliance, or enforcement
Lenders or institutions may see information shared with them through authorized workflows

By using the Platform, you acknowledge that certain activity may be logged and shared with authorized parties as part of Platform functionality.

12. Security

CNH uses commercially reasonable administrative, technical, and organizational safeguards designed to protect personal information from unauthorized access, loss, misuse, alteration, or disclosure. However, no system is completely secure. CNH does not guarantee that unauthorized access, cyber incidents, data loss, or security breaches will never occur. Users are responsible for:

Protecting login credentials
Using secure passwords
Managing account access
Not sharing credentials
Reviewing permissions
Securing devices
Promptly notifying CNH of suspected unauthorized access

13. Data Retention

CNH may retain personal information for as long as reasonably necessary to:

Provide the Platform
Maintain accounts
Support subscriptions
Process payments
Provide customer support
Maintain transaction records
Maintain data room records
Comply with law
Resolve disputes
Enforce agreements
Prevent fraud
Protect security
Maintain audit trails
Improve products
Support business operations
Preserve legal rights

CNH may retain activity logs, security logs, access records, billing records, transaction records, legal records, and other business records for legitimate business, legal, compliance, and security purposes. Aggregated, anonymized, de-identified, derived, benchmark, platform intelligence, and AI/model data may be retained as described in CNH's Data Usage Agreement.

14. Deletion Requests

Users may request deletion of certain personal information, subject to:

Legal obligations
Contractual obligations
Recordkeeping requirements
Security needs
Fraud prevention
Dispute resolution
Backup retention
Technical limitations
Business operations
Transaction records
Data room records
Compliance obligations
CNH's legitimate business interests

Deletion of personal information does not require CNH to delete:

Aggregated Data
Anonymized Data
De-Identified Data
Derived Data
Benchmark Data
Platform Intelligence
AI/Model Data
Security logs
Legal records
Transaction records
Billing records
Audit trails
Backup records
Data retained as necessary for legitimate business, legal, compliance, fraud prevention, or security purposes

15. User Choices and Account Controls

Depending on Platform functionality, users may be able to:

Update account information
Change communication preferences
Modify profile information
Manage listing visibility
Manage data room permissions
Remove documents
Invite or remove users
Opt out of marketing emails
Request access to certain information
Request correction of certain information
Request deletion of certain information

Some requests may be limited by legal, contractual, technical, security, or business reasons.

16. Children's Privacy

The Platform is intended for business and professional use. CNH does not knowingly collect personal information from children under the age of 13. If CNH becomes aware that it has collected personal information from a child under 13 without appropriate consent, CNH will take reasonable steps to delete such information.

17. International Users

CNH is based in the United States. If you access the Platform from outside the United States, you acknowledge that your information may be processed, stored, or transferred in the United States or other locations where CNH or its service providers operate. Data protection laws in those locations may differ from the laws in your jurisdiction.

18. State Privacy Rights

Depending on your location and applicable law, you may have certain privacy rights, which may include the right to:

Request access to personal information
Request correction of personal information
Request deletion of personal information
Request a copy of personal information
Object to or restrict certain processing
Opt out of certain marketing communications
Appeal certain privacy decisions where required by law

CNH will respond to applicable privacy requests as required by law. To make a privacy request, contact CNH at: [Insert Privacy Email]. CNH may need to verify your identity before processing certain requests.

19. California Privacy Notice

If applicable, California residents may have additional rights under California privacy laws. CNH may collect the following categories of personal information:

Identifiers
Commercial information
Internet or network activity information
Professional or employment-related information
Geolocation information based on approximate IP location
Inferences drawn from Platform activity
Account and communication information

CNH may use these categories for the purposes described in this Privacy Policy. CNH does not sell personal information in the traditional sense of exchanging personal information for money. However, certain privacy laws define "sale" or "sharing" broadly. If CNH engages in activities considered a "sale" or "sharing" under applicable law, CNH will provide required notices and opt-out rights.

20. Sensitive Personal Information

CNH does not intend to collect sensitive personal information unless necessary for a specific Platform function, transaction workflow, verification process, legal requirement, or user-submitted purpose. Sensitive personal information may include certain financial information, identity verification information, account credentials, or other information protected by law. Users should not upload unnecessary sensitive personal information. Where sensitive personal information is submitted, CNH may process it according to this Privacy Policy, applicable agreements, and applicable law.

21. Third-Party Links and Services

The Platform may contain links to third-party websites, tools, services, integrations, or platforms. CNH is not responsible for the privacy practices, content, security, or terms of third-party services. Users should review third-party privacy policies before using those services.

22. Business Transfers

If CNH is involved in a merger, acquisition, financing, sale of assets, sale of equity, restructuring, reorganization, bankruptcy, assignment, affiliate transfer, licensing arrangement, white-label arrangement, sale of subsidiary, product spin-off, strategic partnership, or similar transaction, personal information may be disclosed, transferred, assigned, licensed, or made available as part of that transaction. This may include information associated with CNH, EBE, SBE, S2, ModelCore, Insight360, DealStream, PrivateStack, or related products. The receiving party may continue to process information consistent with this Privacy Policy and applicable agreements.

23. Changes to This Privacy Policy

CNH may update this Privacy Policy from time to time. If changes are material, CNH may provide notice by:

Posting the updated policy
Sending an email
Providing an in-platform notice
Updating the effective date
Other reasonable means

Continued use of the Platform after an updated Privacy Policy becomes effective means you accept the updated policy.

24. Contact Information

Questions or requests regarding this Privacy Policy may be directed to: ATTN: Privacy, CNH Holdings Inc., 30 N Gould St. # 47506, Sheridan, WY 82801. [Insert Email] [Insert Phone Number]