Privacy Policy

Effective Date: August 25, 2026

Version: Built to Close 1.0

This Privacy Policy explains how Otto AI Inc., doing business as Howdee AI ("Howdee," "we," "us," or "our"), collects, uses, discloses, retains, and deletes personal information in connection with the Built to Close sales training course, Howdee's websites, course portals, AI-powered practice calls, scoring and coaching features, and related services (collectively, the "Service").

This Privacy Policy is incorporated into the Built to Close Terms of Service. Capitalized terms not defined here have the meaning given in the Terms of Service.

1. Who we are

Otto AI Inc., doing business as Howdee AI, is responsible for the personal information described in this Privacy Policy.

Otto AI Inc., d/b/a Howdee AI
4539 N 22nd St # 5349
Phoenix, AZ 85016
support@builttoclose.ai

This Privacy Policy applies to individual learners who access the Built to Close course through the Service.

The Service is offered to learners located in the United States. It is not directed to, or intended for, or marketed at individuals located outside the United States.

This Privacy Policy does not apply to The Elliott Group's own handling of your information. The Elliott Group sells and administers course enrollments and maintains its own relationship with you. Its practices are governed by its own policies and its arrangements with you. The Elliott Group Privacy policy is listed here: https://elliott247.com/privacy

This Privacy Policy also does not apply to third-party websites or services you reach through links in the Service.

2. Relationship to the Terms of Service

This Privacy Policy is incorporated into the Terms of Service by reference. If the Terms of Service and this Privacy Policy conflict regarding the handling of personal information, this Privacy Policy controls to the extent of that conflict.

3. Information we collect

3.1 Information you provide

• Account information. Your name, email address, and password. Passwords are stored in hashed form and are not readable by Howdee personnel.
• Enrollment information. Your enrollment or redemption code and the enrollment record it corresponds to.
• Profile information. Information you add to your profile, such as a short bio and any uploaded media you add.
• Job application information. If you apply to an employment listing through the Service, the application you submit, including your name, email address, cover letter, short bio, and any media you add.
• Support communications. The contents of messages you send to support@builttoclose.ai, including any information you choose to include.
• Feedback. Suggestions or feedback you voluntarily provide about the Service.

3.2 Practice session information

Practice calls are live voice sessions between you and an AI counterpart. These sessions generate:

• Audio. Your microphone captures your side of the conversation during a practice call.
• Recordings. A recording of the practice session is created to transmit to a service provider for the purpose of providing the service.
• Transcripts. Text transcripts of the session, covering both your responses and the AI counterpart's responses.
• Scores and coaching feedback. Rubric scores, sub-scores, and written coaching feedback generated from the transcript.
• Session metadata. Timestamps, session duration, completion status, and the number of attempts, and other system information that enable the service.

Howdee does not retain practice-call audio. Recordings are held by our voice infrastructure provider under our account and are deleted by that provider 90 days after the session. Howdee's own systems store the transcript, the scores, the coaching feedback, and the session metadata, but not the audio file.

Anything you say during a practice session becomes part of the transcript. As stated in Section 6 of the Terms of Service, you should not disclose confidential, regulated, or sensitive information during a practice session, including real customer information, credentials, or payment details. Practice sessions are for simulated conversations and are not a secure channel for sensitive data.

3.3 Course activity

We collect information about your use of the course, including modules viewed, completion status, progress, certificates earned, and activity in course video and community features.

3.4 Information collected automatically

When you use the Service we automatically collect:

• Device and browser information, including operating system and browser type
• IP address, and an approximate location at the country and region level derived from it
• Log data, including pages viewed, actions taken, timestamps, and errors
• Performance and reliability data used to monitor the Service
• Information collected through cookies and similar technologies, described in Section 11

3.5 Information from The Elliott Group

The Elliott Group provides us with enrollment information so that we can grant you access to the course. This includes your enrollment status, the email address needed to associate your account with a valid enrollment, and enrollment metadata from any 3rd party service providers that we use to provision your account.

3.6 Information we do not collect

• Payment information. The Elliott Group handles all course enrollment and payment. Howdee does not collect, receive, or store payment card numbers, bank account information, or other billing details from learners.
• Government identification numbers. We do not collect government-issued identification numbers.
• Voice identity data. We do not use your voice to verify your identity and we do not create or store a voiceprint or other biometric identifier from your audio. Your voice is converted to text so that your responses can be scored, and it is not used to determine who you are.

4. How we use information

We use the information described above to:

• create and maintain your account and authenticate your access
• verify your enrollment and grant access to the course
• operate AI practice sessions
• generate transcripts, scores, and coaching feedback
• display your progress, scores, and certificates to you and to The Elliott Group as described in Section 6.1
• provide customer support and respond to your requests
• review practice-session records for quality assurance and to maintain the reliability and accuracy of scoring, as described in Section 5
• monitor, secure, and troubleshoot the Service
• detect, prevent, and investigate fraud, abuse, security incidents, account sharing, and evasion of usage limits
• enforce the Terms of Service
• comply with legal obligations and respond to lawful requests
• send you transactional and legal communications about your account and the Service
• operate the job marketplace and display employment listings to you
• transmit your application to an employer when you apply to its listing

We do not send marketing email. Howdee sends learners transactional and legal messages only, such as account notices, session-related messages, and changes to our terms. Communications you receive from The Elliott Group are sent under its own relationship with you.

5. AI processing, human review, and model training

5.1 Automated processing

Practice sessions are processed by third-party artificial intelligence providers acting on our behalf. These providers perform speech-to-text transcription, generate the AI counterpart's side of the conversation, and evaluate transcripts to produce scores and coaching feedback.

Scores and coaching feedback are generated automatically. As stated in Section 4 of the Terms of Service, AI-generated dialogue, scoring, and feedback may be incomplete, inconsistent, or inaccurate, and scores do not by themselves determine course completion, certification acceptance by any third party, employment, or any other legal or similarly significant outcome.

5.2 We do not train models on your session data

Howdee does not use your practice-session recordings, transcripts, scores, or other session data to train, fine-tune, or otherwise develop artificial intelligence models.

5.3 Human review

Authorized Howdee personnel may review practice-session transcripts, scores, and coaching feedback for quality assurance, to investigate a support request, to improve the accuracy and reliability of scoring, and to investigate suspected fraud, abuse, or security incidents.

6. How we share information

6.1 The Elliott Group

The Elliott Group is the sponsoring organization for the Built to Close course. As described in Section 7 of the Terms of Service, The Elliott Group can access:

• your course progress and completion status
• your scores, sub-scores, and coaching feedback
• the transcripts of your practice sessions, including what you said during those sessions for the purpose of ensuring service quality and enforcing terms of service

Requests about information held by The Elliott Group should be directed to The Elliott Group.

6.2 Service providers

We use third-party providers to operate the Service. These providers process personal information on our behalf, under contract, and are not permitted to use it for their own purposes. The categories of providers we use are:

• voice infrastructure providers, for live call handling, recording, and transcription
• artificial intelligence providers, for conversation generation and for scoring and coaching analysis
• cloud hosting and application infrastructure providers
• database and storage providers
• course video hosting and community platform providers
• authentication providers
• transactional email providers
• product analytics and application monitoring providers

6.3 Legal and safety disclosures

We may disclose information when we believe in good faith that doing so is necessary to:

• comply with applicable law, legal process, subpoena, or a lawful government request
• enforce the Terms of Service or investigate potential violations
• detect, prevent, or address fraud, abuse, security, or technical issues
• protect the rights, property, or safety of Howdee, our users, The Elliott Group, our providers, or the public
• establish, exercise, or defend legal claims

6.4 Business transfers

If Howdee is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or part of its assets, personal information may be transferred as part of that transaction. This mirrors the assignment right in Section 22 of the Terms of Service. We will require that the recipient honor commitments made in this Privacy Policy or provide notice of any material change.

6.5 We do not sell or share your personal information

Howdee does not sell your personal information and does not share it for cross-context behavioral advertising, as those terms are defined under California law. We have not done so in the preceding twelve months.

We do not use advertising networks, advertising pixels, or third-party targeting technologies in the Service.

Sending your application to an employer at your direction is not a sale or sharing of personal information.

6.6 Employers you apply to

The Service includes a job marketplace where you can view open employment listings and apply to them. When you submit an application, we send the information in that application to the employer that posted the listing. That information is the name, email address, cover letter, short bio, and any media you include in your application or profile.

We do not include your practice-session scores, sub-scores, coaching feedback, or transcripts in an application, and we do not provide them to employers. Employers are independent third parties, not our service providers. Once an employer receives your application, its use of that information is governed by its own practices, and we cannot retrieve or delete information an employer has already received. Applying does not guarantee an interview, an offer, or any employment outcome.

7. Recording and consent

Practice sessions are recorded. Before each practice session begins, the Service presents a disclosure explaining that the session will be recorded, transcribed, and scored, and that your transcript and scores are visible to The Elliott Group.

This session-level disclosure is separate from, and is not replaced by, your acceptance of the Terms of Service or this Privacy Policy.

If you do not wish to be recorded, do not begin a practice session. This service cannot be provided without recording and transcription.

Practice sessions are conversations between you and an automated AI counterpart. No other person participates in the call while it is in progress.

8. Retention and deletion

8.1 How long we keep information

"Life of your account plus 90 days" means we retain the information while your account is active, and for up to 90 days after your account is deleted. That trailing window allows deletion to propagate across our systems and allows routine backups to cycle out. We retain this information while your account is active because your progress, scores, and prior sessions are what make coaching across the course possible.

The retention windows above are outer limits, not commitments to keep anything for that long. As stated in Section 8.2, we may delete information sooner.

8.2 No storage or preservation right

As stated in Section 8 of the Terms of Service, the Service is not a storage or archival service. Nothing in this Privacy Policy or the Terms of Service gives you an ownership or property interest in any account record, transcript, score, session record, or other copy maintained on Howdee's systems, or requires Howdee to preserve any of it for a minimum period. Session data may become unavailable or be deleted before your account is terminated. If there is information you want to keep, save or export it where the Service allows you to.

8.3 If your subscription or enrollment ends

If your subscription or course enrollment ends, your account remains in place and is not deleted so that you can resume a subscription again at a later point in time.

When your subscription or enrollment ends:

• You are no longer able to login

You choose what happens to the data. When your subscription or enrollment ends, we email you and ask whether you want to keep your account or close it.

• Keep your account. We retain your information and profile. If you return later, they are restored, so you do not start from a blank slate.
• Close your account. We delete your information as described in Section 8.4.

If you do not respond, we keep your account so that your certificate and score history are not lost. You can change that decision at any time by emailing support@builttoclose.ai. Closing your account is permanent.

8.4 Deleting your account

You may request deletion of your account and your personal information by emailing support@builttoclose.ai from the email address associated with your account. We may take reasonable steps to verify your identity before acting on a deletion request.

We will acknowledge your request promptly and act on it within 45 days.

After that, we retain no personal information about you, except:

• information we must retain to comply with a legal obligation
• information reasonably necessary to detect, prevent, or investigate fraud, abuse, or security incidents
• information reasonably necessary to establish, exercise, or defend legal claims

Information retained for one of these reasons is not used for ordinary product, scoring, coaching, training, or commercial purposes, and is deleted or de-identified when the applicable purpose expires.

8.5 What deletion does not cover

Deleting your Howdee account does not delete information held independently by The Elliott Group, or information an employer received in an application you submitted.

Ending your course enrollment, or having your access suspended or terminated, is not the same as account deletion. To delete your account, send a deletion request as described above.

9. Security

We use administrative, technical, and physical safeguards designed to protect personal information, including:

• encryption of information in transit and at rest
• access controls limiting which personnel can reach which data
• authentication requirements for account access
• monitoring for security and reliability events

No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If you believe your account or credentials have been compromised, notify us promptly at support@builttoclose.ai.

10. Your privacy rights

10.1 Rights

Depending on where you live, you may have the right to:

• Know and access. Request the categories and specific pieces of personal information we have collected about you, the sources, the purposes, and the categories of third parties to whom we disclosed it.
• Delete. Request deletion of your personal information, subject to the exceptions in Section 8.4.
• Correct. Request correction of inaccurate personal information.
• Opt out of sale or sharing. As stated in Section 6.5, we do not sell or share personal information, so there is nothing to opt out of.
• Limit the use of sensitive personal information. We do not use or disclose sensitive personal information for purposes beyond those permitted without a limitation right.
• Non-discrimination. We will not deny you service, charge you a different price, or provide a different level of service because you exercised a privacy right.

10.2 How to exercise your rights

Email support@builttoclose.ai from the email address associated with your account, and describe what you are requesting. To protect your information, we verify requests before acting on them, which may require you to confirm information we already hold about your account. We cannot fulfill a request we are unable to verify.

We respond within 45 days, with one additional 45-day extension where permitted and where we tell you the reason.

10.3 Authorized agents

You may use an authorized agent to submit a request on your behalf. We may require written proof of the agent's authority and may ask you to verify your identity directly.

10.4 Appeals

If we decline your request, you may appeal by replying to our response or emailing support@builttoclose.ai with the word "appeal" in the subject line. We will review the appeal and respond with our decision and the reasons for it.

10.5 Residents of other states

Several states have comprehensive privacy laws providing rights similar to those described above. Howdee honors verified requests to know, delete, and correct from any learner, regardless of the state you live in, rather than limiting these rights by residency.

11. Cookies and similar technologies

We use cookies and similar technologies for:

• Strictly necessary purposes. Authentication, session management, and security. The Service cannot function without these.
• Functional purposes. Remembering preferences and settings.
• Analytics and performance. Understanding how the Service is used and monitoring reliability and errors.

We do not use advertising or cross-site tracking cookies.

You can control cookies through your browser settings. Blocking strictly necessary cookies will prevent you from signing in and using the Service.

12. Children

The Service is for individuals who are at least 18 years old, as stated in Section 1 of the Terms of Service. We do not knowingly collect personal information from anyone under 18. If we learn that we have collected information from a person under 18, we will delete it. If you believe a minor has provided us information, contact support@builttoclose.ai.

13. Changes to this Privacy Policy

We may update this Privacy Policy. The Version and Effective Date appear at the top.

If a change is material, we will provide reasonable notice, such as by email to the address associated with your account, through the Service, or by requiring acknowledgement before continued use. Changes take effect on the Effective Date of the updated policy.

14. Contact us

Questions, privacy requests, and appeals may be sent to:

Otto AI Inc., d/b/a Howdee AI
Email: support@builttoclose.ai
Mailing address: 4539 N 22nd St # 5349, Phoenix, AZ 85016