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Privacy Policy

Last updated: August 1, 2026 · Effective date: August 1, 2026

Operator: Empire Digital Resources, doing business as FiveToClose (“FiveToClose,” “we,” “us,” or “our”) · Website: https://fivetoclose.com/ · Privacy & support contact: hello@fivetoclose.com

This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information when you visit https://fivetoclose.com/ (the “Site”), purchase digital products (including the Revenue Leak Audit), subscribe to membership or Monthly Funnel Review, submit a funnel URL and intake details for auditing, access private results pages (including on results.fivetoclose.cloud), access the member vault, or otherwise interact with our checkout, emails, or support channels (collectively, the “Service”). By using the Service, you acknowledge that you have read and understood this Policy. If you do not agree, do not use the Site or complete a purchase.

This Policy is intended to be read together with our Terms of Service and Disclaimer. Capitalized terms not defined here have the meanings given in the Terms where applicable.

1. Scope and who this Policy applies to

This Policy applies to:

• Visitors to the Site, whether or not they purchase anything;
• Customers who buy a Revenue Leak Audit, Operators Kickstart, or another one-time offer sold on the Site;
• Customers who submit funnel URLs, traffic-source notes, problem statements, and other intake content for an audit;
• Subscribers to Operators Monthly, Monthly Funnel Review ($37/mo re-review of a previously audited funnel), or other recurring products;
• Individuals who email support or otherwise contact us about the Service; and
• Technical data generated when tracking or analytics scripts we control run on the Site (for example traffic-quality or engagement scripts).

This Policy does not control third-party websites linked from the Site (including tool sites such as Funnel Canary, Email Fire Domain, Is Your Traffic Real, or LaunchDock). Those properties have their own privacy policies. When you leave fivetoclose.com, their rules apply.

2. Categories of information we collect

2.1 Information you provide

• Identity and contact data: name, email address, and any other details you enter at Stripe Checkout or send to hello@fivetoclose.com.
• Communication content: the substance of support requests, refund requests, and related correspondence.
• Preferences: optional marketing or product preferences if you expressly communicate them.

2.2 Purchase and billing data

• Transaction records: product purchased, amount, currency, timestamps, payment status, order or session identifiers.
• Stripe identifiers: Stripe customer ID, Checkout Session ID, PaymentIntent or subscription ID, invoice references, and related status fields returned by Stripe webhooks.
• Card and bank data: full payment card numbers, CVV, and bank account credentials are collected and processed by Stripe, not stored on our servers. We may receive limited card metadata (for example brand, last four digits, or funding type) if Stripe provides it for receipts or fraud review.

2.3 Account and access data

• Member vault access tokens and membership status (for example whether Kickstart is unlocked and whether a subscription is active);
• Records needed to re-issue access when you request help with the email used at checkout.

2.4 Technical and usage data

• IP address, approximate location derived from IP (if a geolocation or analytics provider is used), browser type, device/user-agent string, referring URL, pages viewed on the Site, timestamps, and similar log data;
• Cookies, local storage, or session identifiers used for checkout continuity, security, or analytics;
• Signals from traffic-quality or engagement scripts placed on the Site (for example page views, bot/automation heuristics, source or UTM parameters), subject to those tools’ configurations.

2.5 Information we do not intentionally collect

We do not intentionally collect government ID numbers, precise GPS location, biometric templates, or special-category health data through the standard Kickstart or Membership checkout. Do not send sensitive personal data to support unless we specifically request it for identity verification.

3. Sources of information

We collect information directly from you (forms, checkout, email), automatically from your device when you use the Site, and from service providers that process payments or infrastructure on our behalf (notably Stripe). If you arrive from an email campaign or affiliate/tracking link, we may associate campaign identifiers with your visit or purchase for attribution and fraud prevention.

4. How we use information (purposes)

We use personal information to:

• Process orders, deliver purchased audits or digital products, and grant or revoke member vault access;
• Create and manage subscriptions, renewals, invoices, failed-payment retries, and cancellations through Stripe;
• Authenticate access to the member vault (including token-based links);
• Provide customer support and respond to inquiries;
• Detect, investigate, and prevent fraud, abuse, chargebacks, and security incidents;
• Operate, secure, debug, and improve the Site and Service;
• Comply with tax, accounting, and legal obligations;
• Send transactional messages related to your purchase or membership (receipts, access instructions, material service notices);
• Where permitted by law and consistent with your expectations as a customer, send product-related updates about FiveToClose offerings you purchased or requested; and
• Allow authorized site administrators to view purchase, membership, and technical records as needed to operate and troubleshoot the Service (see Section 6).

We do not use your information to make automated decisions that produce legal or similarly significant effects solely by algorithmic means without human involvement in the ordinary course of this Service.

5. Legal bases (EEA/UK and similar regimes, where applicable)

Where the GDPR, UK GDPR, or analogous laws apply to our processing as a controller, we rely on one or more of the following bases:

• Contract: processing necessary to perform a contract with you (deliver Kickstart/Membership, process payment, provide vault access) or to take steps at your request before a contract;
• Legitimate interests: securing the Service, preventing fraud, improving reliability, basic analytics, and internal administration, balanced against your rights;
• Legal obligation: retaining transaction records, responding to lawful requests, and meeting tax/accounting rules; and/or
• Consent: where required for non-essential cookies or optional marketing, which you may withdraw without affecting the lawfulness of prior processing.

6. Platform operator / site administrator access

By creating a purchase record or membership, you acknowledge and agree that authorized operators of FiveToClose (site administrators with privileged credentials) may access, view, and use: (a) your checkout identity data (name and email); (b) purchase and subscription status and Stripe-related identifiers; (c) member vault tokens and access flags; and (d) technical logs and analytics associated with the Site, solely for legitimate Service purposes—including delivery of access, security, fraud prevention, troubleshooting failed checkouts or vault links, responding to support requests, and enforcing the Terms. This access is limited to authorized operators; it is not a public directory and is not a sale of your personal information.

7. How we share information

We may disclose personal information to:

• Stripe, Inc. and its affiliates for payment processing, fraud tools, tax features, and the customer billing portal;
• Hosting, DNS, CDN, email, and infrastructure providers that process data to keep the Site online and deliver mail (including hello@fivetoclose.com);
• Analytics or tracking providers we intentionally embed on the Site (for example traffic-quality tooling), under their terms;
• Professional advisers (legal, accounting) under confidentiality obligations;
• Authorities when required by law, legal process, or to protect rights, safety, and property; and
• Successors in connection with a merger, acquisition, financing, or sale of assets, subject to appropriate confidentiality and this Policy’s spirit.

We do not sell personal information for money. We do not knowingly sell or share personal information for cross-context behavioral advertising as those terms are defined under the California Consumer Privacy Act (CCPA/CPRA), as amended. If our practices change, we will update this Policy and provide required notices or opt-outs.

8. Cookies and similar technologies

The Site and third-party processors (including Stripe Checkout) may use cookies, local storage, pixels, or similar technologies for security, session continuity, fraud prevention, and analytics. You can control cookies through browser settings; blocking some cookies may break checkout or vault features. Where a consent banner or preference mechanism is presented, we honor the choices you record there to the extent technically and legally required.

9. International transfers

We and our providers may process data in the United States and other countries. Where required, we use appropriate transfer mechanisms (for example contractual clauses approved by relevant authorities) or rely on other lawful transfer grounds.

10. Retention

We retain purchase and subscription records for as long as needed to provide the Service, resolve disputes, enforce agreements, and meet legal, tax, and accounting requirements. Member access tokens remain until you request deletion (subject to retention needs) or we rotate them for security. Support emails are retained for a reasonable support and audit period. Technical logs are kept for security and debugging on a rolling basis.

11. Security

We implement reasonable administrative and technical safeguards, including HTTPS, access controls, and least-privilege practices for operator accounts. No method of transmission or storage is completely secure. You are responsible for protecting your email inbox and any vault links sent to you.

12. Children’s privacy

The Service is directed to adults and business operators. It is not intended for children under 13 (or under 16 where stricter rules apply). We do not knowingly collect personal information from children. If you believe a child has provided us data, contact hello@fivetoclose.com and we will take appropriate steps to delete it.

13. Your rights and choices

Depending on your location, you may have rights to access, correct, delete, or export personal information; to object to or restrict certain processing; to withdraw consent; and to lodge a complaint with a supervisory authority. California residents may have rights to know, delete, correct, and opt out of sale/share (we state we do not sell/share as described above). To exercise rights, email hello@fivetoclose.com with sufficient detail to verify your identity and request. We will respond within the time required by applicable law. We may decline requests that are unfounded, excessive, or exempt (for example records we must keep for tax or fraud prevention).

You may cancel a subscription via the Stripe customer portal (when available) or by contacting support. Canceling stops future renewals according to Stripe’s billing cycle rules; it does not automatically delete historical purchase records.

14. Do Not Track / Global Privacy Control

Browser “Do Not Track” signals are not uniformly standardized. Where Global Privacy Control (GPC) or similar legally recognized opt-out signals apply to our processing as a business, we will treat them as required for covered activities. Core checkout and fraud-prevention processing may still occur as necessary to provide the Service you request.

15. Third-party links and tools

Member vault materials may link to third-party tools and documentation. We are not responsible for third-party privacy practices. Review each provider’s policy before creating accounts or pasting scripts on your own websites.

16. Changes to this Policy

We may update this Privacy Policy from time to time. We will change the “Last updated” date above and, for material changes, provide additional notice when appropriate (for example a Site banner or email to the address used at checkout). Continued use of the Service after the effective date of changes constitutes acceptance of the revised Policy, except where applicable law requires another process.

17. Contact

For privacy requests or questions: hello@fivetoclose.com
Web: https://fivetoclose.com/
Operator: Empire Digital Resources d/b/a FiveToClose

This Policy is provided for transparency and compliance. It is not legal advice to you about your own business obligations.

Contact: hello@fivetoclose.com