Privacy Policy

OFFICE OF NATIONAL EXCELLENCE, LLC

PRIVACY POLICY

Effective Date: September 16, 2026

Last Revised: September 16, 2026

Contracting Entity: Office of National Excellence, LLC

Organization: ONE

Network: ON | ONE Network

Official Domain: ONEUSA.us

ARTICLE I

SCOPE; APPLICABILITY; CONTROLLING PRINCIPLES

§ 1.01 Scope.

This Master Privacy Policy ("Privacy Policy") describes the collection, receipt, access, use, processing, retention, disclosure, transmission, protection, and deletion of Personal Information by Office of National Excellence, LLC, a Michigan limited liability company ("ONE," "Company," "we," "us," or "our"), in connection with Services to which this Privacy Policy is posted, linked, incorporated, or otherwise expressly made applicable.

This Privacy Policy may apply to:

(a) ONEUSA.us;

(b) ONE;

(d) the ONE Network;

(e) ONE Membership;

(f) ONE ID;

(g) ONE Card;

(h) the Excellence Identity Registry;

(i) ONE Standard;

(j) ONE Recognition;

(k) ONE Awards;

(l) ONE Accounts;

(m) applications;

(n) websites;

(o) directories;

(p) bulletin boards;

(q) Listings;

(r) communications;

(s) search and discovery functions;

(t) Bookings and Appointments;

(u) marketplace functionality;

(v) P2P functionality;

(w) consulting services;

(x) Virtual Brand services;

(y) Provider services;

(z) governmental, educational, nonprofit, religious, business, and community bulletins; and

(aa) other ONE Services expressly subject to this Privacy Policy.

§ 1.02 Supplemental Privacy Notices.

Certain Services may require additional privacy notices, disclosures, authorizations, or consents, including notices concerning:

(a) children;

(b) health information;

(d) precise geolocation;

(e) employment;

(f) background screening;

(g) financial information;

(h) governmental information;

(i) educational information;

(j) cookies;

(k) targeted advertising;

(l) state privacy rights; or

(m) other specially regulated information.

A supplemental notice shall control concerning the particular processing expressly governed by that notice to the extent of an irreconcilable conflict.

§ 1.03 Private Entity.

ONE is a private entity.

ONE is not a governmental agency, department, authority, instrumentality, public body, law-enforcement agency, governmental identification authority, or governmental records office merely because ONE provides Services to governmental organizations or publishes governmental information.

§ 1.04 Applicability of Law.

Privacy rights and obligations vary according to jurisdiction, data type, Service, Transaction, relationship, age, and other circumstances.

ONE shall provide rights required by Applicable Law where such law applies to ONE and the relevant processing activity.

ARTICLE II

DEFINITIONS

§ 2.01 "Personal Information."

"Personal Information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an identifiable natural person or household, where recognized by Applicable Law.

§ 2.02 "Sensitive Personal Information."

"Sensitive Personal Information" means information designated as sensitive, sensitive data, special-category data, or substantially equivalent terminology under Applicable Law.

Depending upon applicable jurisdiction, Sensitive Personal Information may include certain:

(a) government identifiers;

(b) Account credentials;

(d) precise geolocation;

(e) racial or ethnic information;

(f) religious or philosophical information;

(g) health information;

(h) genetic information;

(i) biometric information;

(j) sexual-orientation information;

(k) citizenship or immigration information;

(l) communications content; or

(m) information concerning children.

§ 2.03 "Processing."

"Processing" means any operation performed upon Personal Information, whether manually or through automated means, including collection, receipt, organization, storage, modification, retrieval, consultation, use, disclosure, transmission, combination, restriction, deletion, or destruction.

§ 2.04 "User."

"User" means any natural person accessing a Service subject to this Privacy Policy.

§ 2.05 "Member."

"Member" means an eligible person maintaining ONE Membership.

§ 2.06 "Provider."

"Provider" means a Third Party offering or making available a Product, Service, Appointment, Place, Event, opportunity, Listing, or other offering through or in connection with ONE.

§ 2.07 "Third Party."

"Third Party" means a person or entity other than ONE, subject to distinctions imposed by Applicable Law.

§ 2.08 "Service Provider" and "Processor."

"Service Provider" or "Processor" means a person processing Personal Information on behalf of ONE pursuant to an applicable contractual or legal relationship.

§ 2.09 "Public Content."

"Public Content" means User Content intentionally designated or submitted for public or network-wide publication.

§ 2.10 "Deidentified Information."

"Deidentified Information" means information processed so that it cannot reasonably be associated with an identifiable person where applicable statutory requirements for deidentified information are satisfied.

§ 2.11 "Aggregated Information."

"Aggregated Information" means information combined or summarized in a manner not reasonably identifying a particular person.

ARTICLE III

CATEGORIES OF INFORMATION ONE MAY COLLECT

§ 3.01 Identification Information.

ONE may collect:

(a) name;

(b) preferred name;

(d) Account identifier;

(e) ONE ID number;

(f) Membership identifier;

(g) profile photograph;

(h) date of birth;

(i) age or age range; and

(j) other identification information.

§ 3.02 Contact Information.

ONE may collect:

(a) postal address;

(b) city;

(d) ZIP code;

(e) email address;

(f) telephone number; and

(g) other contact information.

§ 3.03 Account Information.

ONE may collect:

(a) username;

(b) password or protected credential data;

(d) Account settings;

(e) privacy preferences;

(f) Membership status;

(g) Account history; and

(h) security information.

§ 3.04 ONE ID Information.

Where required for ONE ID functionality, ONE may collect information necessary to:

(a) establish a Member profile;

(b) associate a credential with a Member;

(d) verify permitted attributes;

(e) prevent duplicate or fraudulent credentials;

(f) administer Membership; and

(g) protect credential integrity.

ONE ID remains a private membership identification credential.

§ 3.05 Verification Information.

Where a Service includes verification, ONE may request information reasonably necessary to verify a specified attribute.

Such information may include, where lawful and necessary:

(a) legal name;

(b) date of birth;

(d) business information;

(e) organizational authority;

(f) professional credentials;

(g) licensing information; or

(h) other verification documentation.

ONE shall not represent that an attribute has been verified unless ONE has established a corresponding verification process.

§ 3.06 Profile Information.

Users may provide:

(a) biographical information;

(b) interests;

(d) skills;

(e) expertise;

(f) business information;

(g) household preferences;

(h) community interests;

(i) availability; and

(j) other profile information.

§ 3.07 Transaction Information.

ONE may process information concerning:

(a) orders;

(b) purchases;

(d) Appointments;

(e) Memberships;

(f) subscriptions;

(g) payments;

(h) refunds;

(i) cancellations;

(j) Provider Transactions; and

(k) Transaction history.

§ 3.08 Payment Information.

Payments may be processed by ONE or independent payment processors.

Depending upon the payment architecture, ONE may receive information including:

(a) billing name;

(b) billing address;

(d) Transaction identifier;

(e) payment amount;

(f) payment method type; and

(g) limited payment-related information.

ONE need not directly retain complete payment-card information where an independent payment processor performs such processing.

§ 3.09 Communications.

ONE may process communications submitted through ONE Services, including:

(a) messages;

(b) inquiries;

(d) Provider communications;

(e) Booking communications;

(f) reports;

(g) complaints;

(h) feedback; and

(i) other correspondence.

§ 3.10 User Content.

ONE may collect Content voluntarily submitted by Users, including:

(a) Listings;

(b) photographs;

(d) documents;

(e) reviews;

(f) ratings;

(g) comments;

(h) reports;

(i) poll responses;

(j) bulletins;

(k) announcements; and

(l) other User Content.

§ 3.11 Device and Technical Information.

ONE may automatically receive:

(a) IP address;

(b) device type;

(d) operating system;

(e) device identifiers;

(f) language settings;

(g) referring pages;

(h) pages viewed;

(i) session information;

(j) timestamps;

(k) error information;

(l) network information; and

(m) technical logs.

§ 3.12 Usage Information.

ONE may collect information concerning interaction with ONE Services, including:

(a) searches;

(b) pages viewed;

(d) Listings viewed;

(e) links selected;

(f) search results;

(g) Bookings;

(h) saved items;

(i) Account activity; and

(j) interaction timestamps.

§ 3.13 Location Information.

Where permitted, ONE may process general location derived from information such as an IP address.

Where a feature requires more precise location information, ONE may request device permission or other legally sufficient authorization where required.

Users may be able to control location permissions through their devices.

§ 3.14 Business Information.

ONE may process:

(a) business name;

(b) business address;

(d) business category;

(e) locations;

(f) Products;

(g) Services;

(h) hours;

(i) resources;

(j) capabilities;

(k) equipment;

(l) technology;

(m) expertise;

(n) Listings; and

(o) other business information.

§ 3.15 Employment and Gig Information.

For employment, contractor, freelance, gig, or volunteer functionality, ONE may process information concerning:

(a) employment interests;

(b) qualifications;

(d) experience;

(e) availability;

(f) applications;

(g) professional credentials;

(h) work preferences; and

(i) communications with prospective hiring entities.

§ 3.16 Housing Information.

For housing-related functionality, ONE may process information concerning:

(a) housing interests;

(b) rental Listings;

(d) roommate preferences;

(e) general location;

(f) housing inquiries; and

(g) communications.

ONE shall not collect information unnecessary to the applicable housing functionality merely because such information could be collected.

§ 3.17 Healthcare Appointment Information.

Where ONE provides healthcare discovery or Appointment-routing functionality, ONE may process information necessary to identify a requested Provider, location, Appointment time, contact method, or administrative scheduling request.

ONE shall distinguish ordinary scheduling information from legally regulated protected health information where Applicable Law requires such distinction.

§ 3.18 Government and Public-Sector Information.

ONE may process governmental or public-sector information including:

(a) public notices;

(b) programs;

(d) resources;

(e) meetings;

(f) Events;

(g) opportunities;

(h) bulletins; and

(i) government-submitted Content.

§ 3.19 Educational Information.

ONE may process school or educational bulletin information concerning:

(a) Events;

(b) activities;

(d) closures;

(e) programs;

(f) sports;

(g) resources;

(h) opportunities; and

(i) announcements.

Student information shall receive any protection required by Applicable Law.

§ 3.20 Nonprofit Information.

ONE may process information submitted by nonprofit, charitable, civic, and community organizations concerning their organizations, programs, opportunities, volunteers, Events, resources, and Listings.

§ 3.21 Religious Organization Information.

ONE may process information voluntarily submitted by religious organizations concerning organizations, Events, programs, Services, resources, and opportunities.

§ 3.22 Recognition Information.

ONE may process information relevant to:

(a) ONE Standard;

(b) ONE Recognition;

(d) applications;

(e) nominations;

(f) assessments;

(g) supporting documentation;

(h) recognition history; and

(i) related records.

§ 3.23 Consulting Information.

ONE may process information supplied by consulting clients concerning their business, operations, personnel, resources, capabilities, Products, Services, technology, plans, objectives, or other matters relevant to an engagement.

ARTICLE IV

SOURCES OF PERSONAL INFORMATION

§ 4.01 Directly From Users.

ONE may obtain Personal Information through Account registration, ONE Membership, ONE ID, Listings, forms, Bookings, communications, purchases, support requests, surveys, reports, or other submissions.

§ 4.02 Automatically.

ONE may obtain information through websites, applications, cookies, logs, device technologies, security systems, and similar technologies.

§ 4.03 From Providers.

ONE may obtain information necessary to process a Booking, Appointment, Transaction, Listing, or Provider relationship.

§ 4.04 From Business and Organizational Customers.

ONE may receive information where a business, employer, nonprofit, school, governmental entity, religious organization, or other organization lawfully supplies information.

§ 4.05 From Service Providers.

ONE may receive information from payment processors, hosting providers, analytics providers, security providers, communications providers, verification providers, and technology vendors.

§ 4.06 From Publicly Available Sources.

Where lawful, ONE may obtain information from public records, publicly accessible websites, governmental publications, professional directories, organizational websites, or other lawful public sources.

§ 4.07 From Other Users.

Users may submit information concerning another person where legally permitted.

A User submitting another person's Personal Information represents that such submission is lawful.

§ 4.08 From Integrated Services.

Where a User authorizes integration with another service, ONE may receive information permitted by that authorization.

ARTICLE V

PURPOSES OF PROCESSING

§ 5.01 Service Delivery.

ONE may process Personal Information to operate and provide ONE Services.

§ 5.02 Account Administration.

ONE may process Personal Information to create, maintain, authenticate, secure, support, and administer Accounts.

§ 5.03 Membership Administration.

ONE may process Personal Information to administer ONE Membership and associated benefits.

§ 5.04 ONE ID Administration.

ONE may process Personal Information to issue, maintain, authenticate, secure, suspend, replace, or administer ONE ID.

§ 5.05 Network Operation.

ONE may process Personal Information to operate ON and enable search, discovery, Listings, communications, opportunities, resources, Products, Services, Events, and Connections.

§ 5.06 Transactions.

ONE may process Personal Information to facilitate permitted purchases, payments, Bookings, Appointments, subscriptions, refunds, and other Transactions.

§ 5.07 Matching and Discovery.

ONE may process Personal Information to identify potentially relevant people, organizations, Products, Services, Places, Events, opportunities, or resources.

§ 5.08 Personalization.

ONE may process Personal Information to personalize Service presentation according to lawful preferences, Account activity, or context.

§ 5.09 Communications.

ONE may process Personal Information to provide confirmations, administrative notices, support, security alerts, Account information, Membership information, and other communications.

§ 5.10 Safety and Security.

ONE may process Personal Information to:

(a) authenticate Accounts;

(b) detect fraud;

(d) investigate suspicious activity;

(e) protect Users;

(f) secure infrastructure;

(g) enforce policies; and

(h) respond to security incidents.

§ 5.11 Legal Compliance.

ONE may process Personal Information to satisfy lawful:

(a) tax;

(b) accounting;

(d) judicial;

(e) law-enforcement;

(f) recordkeeping;

(g) reporting; and

(h) other legal obligations.

§ 5.12 Improvement and Analytics.

ONE may process Personal Information to understand use of Services, troubleshoot functionality, conduct analytics, improve features, and develop lawful new functionality.

§ 5.13 Recognition.

ONE may process Personal Information to administer ONE Standard, ONE Recognition, and ONE Awards.

§ 5.14 Consulting.

ONE may process Personal Information to perform agreed consulting services.

§ 5.15 Fraud Prevention.

ONE may process Personal Information to identify potentially fraudulent Accounts, Listings, payments, credentials, Transactions, or conduct.

§ 5.16 Dispute Resolution.

ONE may process Personal Information to investigate complaints, enforce agreements, defend legal claims, establish legal rights, and resolve disputes.

ARTICLE VI

DISCLOSURE OF PERSONAL INFORMATION

§ 6.01 At User Direction.

ONE may disclose information when a User requests, directs, authorizes, or initiates the disclosure.

§ 6.02 Providers.

ONE may provide information reasonably necessary for a Provider to respond to or perform a requested Service, Booking, Appointment, Transaction, or inquiry.

§ 6.03 Other Users.

Information intentionally published through a public or network-visible profile, Listing, bulletin, review, Event, opportunity, or other public feature may be available to other Users.

§ 6.04 Service Providers and Processors.

ONE may disclose Personal Information to vendors performing functions on ONE's behalf, including:

(a) hosting;

(b) cloud infrastructure;

(d) communications;

(e) analytics;

(f) security;

(g) fraud prevention;

(h) customer support;

(i) verification;

(j) data storage; and

(k) other operational services.

§ 6.05 Professional Advisers.

ONE may disclose information to attorneys, accountants, auditors, insurers, consultants, and other professional advisers where reasonably necessary and legally permissible.

§ 6.06 Corporate Transactions.

Information may be disclosed or transferred in connection with an actual or proposed:

(a) merger;

(b) acquisition;

(d) investment;

(e) reorganization;

(f) bankruptcy;

(g) sale of assets;

(h) change of control; or

(i) similar corporate transaction,

subject to Applicable Law.

§ 6.07 Legal Process.

ONE may preserve or disclose information where ONE reasonably determines disclosure is required or permitted by Applicable Law, including in response to:

(a) subpoenas;

(b) court orders;

(d) governmental demands;

(e) regulatory inquiries; or

(f) other lawful process.

§ 6.08 Protection of Rights and Safety.

ONE may disclose information where legally permissible and reasonably necessary to:

(a) protect rights;

(b) investigate fraud;

(d) prevent abuse;

(e) protect Users;

(f) protect ONE; or

(g) address threats to life or physical safety.

§ 6.09 Deidentified and Aggregated Information.

ONE may use or disclose Deidentified Information and Aggregated Information where permitted by Applicable Law.

ARTICLE VII

PUBLIC AND NETWORK-VISIBLE INFORMATION

§ 7.01 Public Features.

Certain ONE Services are designed to make information discoverable.

Examples may include:

(a) business Listings;

(b) Provider profiles;

(d) public bulletins;

(e) reviews;

(f) ratings;

(g) opportunities;

(h) public organization profiles; and

(i) other public Content.

§ 7.02 User Responsibility.

Users shall not publish Personal Information through a public feature unless they possess lawful authority to make such information public.

§ 7.03 Search Engines.

Publicly accessible Content may be indexed, cached, copied, archived, or displayed by search engines and Third Parties.

Removal from ONE does not necessarily cause immediate removal of copies independently maintained by Third Parties.

§ 7.04 No Expectation of Confidentiality for Public Content.

Information intentionally designated for public publication should not be submitted with an expectation that it will remain confidential.

ARTICLE VIII

ONE ID PRIVACY

§ 8.01 Private Credential.

ONE ID constitutes a private membership identification credential.

§ 8.02 Data Minimization.

ONE may limit ONE ID processing to information reasonably necessary for credential administration, authentication, fraud prevention, Member identification, permitted verification, and associated functionality.

§ 8.03 Verification.

Where ONE verifies a particular attribute, ONE may maintain records reasonably necessary to establish or document the verification, subject to Applicable Law and retention requirements.

§ 8.04 No Governmental Database.

The Excellence Identity Registry and ONE ID systems constitute private systems and not governmental identity databases.

§ 8.05 Credential Disclosure.

ONE shall not represent ONE ID information as governmental identity information.

ARTICLE IX

CHILDREN AND MINORS

§ 9.01 Service Architecture.

Eligibility for ONE Services may vary by Service and age.

§ 9.02 Children Under Thirteen.

Where the Children's Online Privacy Protection Act ("COPPA") or other Applicable Law applies because ONE operates a covered child-directed Service or has actual knowledge that it collects Personal Information online from a child under thirteen (13), ONE shall provide legally required notices and obtain verifiable parental consent before covered collection, use, or disclosure unless a lawful exception applies.

§ 9.03 Parental Authorization.

Where a Minor may lawfully participate subject to parental or legal guardian authorization, ONE may obtain information reasonably necessary to verify or administer that authorization.

§ 9.04 Child Data Minimization.

ONE may restrict information requested from Minors and restrict functionality available to Minor Accounts.

§ 9.05 Minor Location Information.

ONE may restrict precise location collection, display, or sharing concerning Minors.

§ 9.06 Adult-Minor Communications.

ONE may restrict direct messaging, meetups, Transactions, Bookings, or other functionality between adults and Minors.

§ 9.07 Parental Rights.

Where Applicable Law provides a parent or legal guardian with rights concerning a child's Personal Information, ONE shall provide legally required mechanisms for exercising those rights.

§ 9.08 Child Safety.

ONE may preserve, restrict, or disclose information where lawfully required or permitted concerning suspected child exploitation, trafficking, abuse, grooming, or other unlawful conduct.

§ 9.09 Age Verification.

ONE may use proportionate age-assurance or age-verification mechanisms where appropriate or legally required.

ARTICLE X

HEALTHCARE AND HEALTH INFORMATION

§ 10.01 Healthcare Scheduling.

ONE may provide administrative healthcare Provider discovery and Appointment functionality.

§ 10.02 Data Minimization.

ONE may process only information reasonably necessary for applicable scheduling, discovery, communication, or administrative functionality.

§ 10.03 HIPAA.

Not all health-related information held by every private business is subject to the Health Insurance Portability and Accountability Act ("HIPAA").

Where ONE acts as a covered entity or business associate, or otherwise becomes subject to HIPAA through a particular relationship or activity, applicable HIPAA requirements and legally required agreements shall govern such processing.

§ 10.04 No Unnecessary Medical Records.

Users should not submit diagnoses, test results, treatment records, Social Security numbers, or other highly sensitive medical information through general-purpose ONE fields unless the applicable Service specifically requests and is designed to process such information.

§ 10.05 Emergency Information.

ONE healthcare scheduling functionality is not an emergency medical system.

ARTICLE XI

EMPLOYMENT AND GIG INFORMATION

§ 11.01 Employment Processing.

ONE may process employment-related information for:

(a) job discovery;

(b) gig discovery;

(d) referrals;

(e) communications;

(f) Provider onboarding; and

(g) related functionality.

§ 11.02 Independent Hiring Entities.

Prospective employers and hiring entities receiving Personal Information through ONE are independently responsible for their subsequent processing where they act as independent controllers, businesses, or other legally responsible persons.

§ 11.03 No Employment Guarantee.

ONE shall not represent that publication of employment information constitutes a guarantee of employment.

ARTICLE XII

HOUSING INFORMATION

§ 12.01 Housing Processing.

ONE may process information necessary for housing discovery, rental Listings, roommate discovery, housing resources, inquiries, and communications.

§ 12.02 Public Listings.

Users should not place highly sensitive information in public housing Listings.

§ 12.03 Independent Housing Providers.

Housing Providers receiving Personal Information through ONE may possess independent privacy obligations.

ARTICLE XIII

GOVERNMENTAL INFORMATION

§ 13.01 Government Participants.

Governmental entities may submit Content through ONE.

§ 13.02 Government Records.

Information supplied by a governmental entity may independently constitute a public record under laws applicable to that governmental entity.

ONE's possession of a copy does not independently determine its public-record status.

§ 13.03 Government Requests.

ONE may respond to legally valid governmental requests for information as required or permitted by Applicable Law.

§ 13.04 No Automatic Government Access.

Government participation in ON does not, by itself, grant governmental organizations unrestricted access to private User information.

ARTICLE XIV

EDUCATIONAL AND SCHOOL INFORMATION

§ 14.01 Educational Bulletins.

ONE may process school bulletins, public educational information, Events, activities, resources, and announcements.

§ 14.02 Student Records.

ONE shall not intentionally transform a general bulletin feature into a student-record repository without establishing any legally required privacy architecture.

§ 14.03 Protected Educational Records.

Where ONE receives legally protected student records through a covered relationship, additional contractual and legal requirements may apply.

ARTICLE XV

NONPROFIT AND RELIGIOUS ORGANIZATION INFORMATION

§ 15.01 Organizational Information.

ONE may process information concerning nonprofit, charitable, civic, religious, and faith-based organizations.

§ 15.02 Sensitive Inferences.

A User's interaction with religious or nonprofit Content may reveal sensitive inferences.

§ 15.03 Applicable Protection.

ONE shall process information designated sensitive by Applicable Law in accordance with applicable requirements.

ARTICLE XVI

PRECISE GEOLOCATION

§ 16.01 Collection.

Where ONE requests precise geolocation, ONE may:

(a) explain the feature requiring location;

(b) request device authorization where required;

(d) restrict use to disclosed purposes; and

(e) provide legally required rights concerning Sensitive Personal Information.

§ 16.02 Sensitive Classification.

Precise geolocation shall receive any additional treatment required where Applicable Law classifies such information as Sensitive Personal Information or Sensitive Data.

ARTICLE XVII

COOKIES AND SIMILAR TECHNOLOGIES

§ 17.01 Technologies.

ONE may use:

(a) cookies;

(b) pixels;

(d) local storage;

(e) session storage;

(f) authentication technologies;

(g) analytics technologies; and

(h) similar technologies.

§ 17.02 Purposes.

These technologies may support:

(a) authentication;

(b) security;

(d) functionality;

(e) analytics;

(f) performance; and

(g) lawful advertising.

§ 17.03 Consent and Opt-Out.

Where Applicable Law requires consent or an opt-out mechanism, ONE shall provide the applicable mechanism.

§ 17.04 Cookie Policy.

A separate Cookie Policy may provide additional details.

ARTICLE XVIII

ANALYTICS

§ 18.01 Analytics Processing.

ONE may use internal or Third-Party analytics to understand:

(a) Service usage;

(b) technical performance;

(d) traffic;

(e) errors;

(f) security; and

(g) aggregate trends.

§ 18.02 Analytics Providers.

Analytics providers may process information pursuant to applicable agreements and privacy requirements.

ARTICLE XIX

ADVERTISING; SALE; SHARING; TARGETED ADVERTISING

§ 19.01 Disclosure Requirement.

ONE shall accurately disclose its actual advertising and data-monetization practices.

§ 19.02 No Blanket Representation Without Operational Verification.

This Privacy Policy does not state that ONE "never sells" or "never shares" Personal Information unless ONE has verified that statement against all deployed advertising, analytics, data-transfer, cookie, SDK, and commercial practices.

§ 19.03 Applicable Opt-Out Rights.

Where Applicable Law provides a right to opt out of sale, sharing, targeted advertising, cross-context behavioral advertising, or substantially equivalent processing, ONE shall provide the applicable right where ONE engages in covered processing.

§ 19.04 Sensitive Personal Information.

Where Applicable Law provides a right to limit use or disclosure of Sensitive Personal Information, ONE shall honor such right where applicable.

ARTICLE XX

AUTOMATED PROCESSING AND ARTIFICIAL INTELLIGENCE

§ 20.01 Automated Technologies.

ONE may use algorithms, artificial intelligence, machine learning, search systems, recommendation systems, fraud-detection systems, matching systems, moderation systems, and other automated technology.

§ 20.02 Purposes.

Such technology may process information to:

(a) rank search results;

(b) identify relevant Content;

(d) personalize Services;

(e) recommend opportunities;

(f) moderate Content;

(g) improve Services; and

(h) perform other disclosed lawful functions.

§ 20.03 Applicable Rights.

Where Applicable Law establishes rights concerning covered automated decision-making or profiling, ONE shall provide applicable rights.

§ 20.04 No Infallibility Representation.

ONE does not represent automated output as infallible.

ARTICLE XXI

DATA RETENTION

§ 21.01 General Standard.

ONE may retain Personal Information for the period reasonably necessary to:

(a) provide Services;

(b) maintain Accounts;

(d) complete Transactions;

(e) maintain security;

(f) prevent fraud;

(g) resolve disputes;

(h) enforce agreements;

(i) maintain required records;

(j) comply with Applicable Law; and

(k) establish, exercise, or defend legal claims.

§ 21.02 Retention Criteria.

Retention periods may depend upon:

(a) information category;

(b) purpose;

(d) Transaction status;

(e) legal requirements;

(f) limitation periods;

(g) security needs;

(h) fraud-prevention requirements; and

(i) contractual obligations.

§ 21.03 Deletion Requests.

A valid deletion request does not require deletion of information that ONE is legally permitted or required to retain.

§ 21.04 Backups.

Information deleted from active systems may remain temporarily in backups or archival systems until overwritten or deleted according to applicable retention procedures.

ARTICLE XXII

INFORMATION SECURITY

§ 22.01 Safeguards.

ONE may maintain administrative, technical, organizational, and physical safeguards appropriate to the nature of the information and Services.

Safeguards may include:

(a) access controls;

(b) authentication;

(d) logging;

(e) monitoring;

(f) vendor controls;

(g) security testing;

(h) incident-response procedures; and

(i) data minimization.

§ 22.02 No Absolute Security.

No Internet transmission, storage environment, network, software, database, or information system can be represented as absolutely secure.

ARTICLE XXIII

SECURITY INCIDENTS AND DATA BREACHES

§ 23.01 Incident Response.

ONE may maintain procedures to identify, investigate, contain, remediate, document, and respond to security incidents.

§ 23.02 Legally Required Notification.

Where Applicable Law requires notification concerning a qualifying breach, ONE shall provide notification to affected persons, governmental authorities, regulators, consumer reporting agencies, or other recipients as legally required.

ARTICLE XXIV

USER PRIVACY CHOICES

§ 24.01 Available Controls.

Depending upon the Service and jurisdiction, Users may be able to:

(a) update Account information;

(b) modify profile visibility;

(d) manage cookies;

(e) manage device permissions;

(f) control location access;

(g) delete certain User Content;

(h) close an Account; and

(i) exercise statutory privacy rights.

§ 24.02 Service Differences.

Operational controls may differ by Service.

ARTICLE XXV

UNITED STATES STATE PRIVACY RIGHTS

§ 25.01 Applicable Rights.

Residents of states possessing applicable comprehensive privacy laws may have rights concerning Personal Information.

Depending upon Applicable Law, such rights may include:

(a) access;

(b) confirmation of processing;

(d) data portability;

(e) correction;

(f) deletion;

(g) opt-out of sale;

(h) opt-out of sharing;

(i) opt-out of targeted advertising;

(j) limitation of Sensitive Personal Information;

(k) appeal; and

(l) non-discrimination.

§ 25.02 Jurisdictional Differences.

Rights vary by state and may be subject to statutory applicability requirements, limitations, and exemptions.

ARTICLE XXVI

CALIFORNIA PRIVACY RIGHTS

§ 26.01 Applicability.

Where ONE is subject to the California Consumer Privacy Act, as amended ("CCPA"), eligible California consumers may possess applicable statutory rights.

§ 26.02 Right to Know.

Eligible consumers may request information concerning Personal Information collected and its applicable use and disclosure.

§ 26.03 Right to Delete.

Eligible consumers may request deletion of Personal Information, subject to statutory exceptions.

§ 26.04 Right to Correct.

Eligible consumers may request correction of inaccurate Personal Information.

§ 26.05 Right to Opt Out.

Eligible consumers may opt out of covered sale or sharing of Personal Information.

§ 26.06 Right to Limit.

Eligible consumers may limit certain uses and disclosures of Sensitive Personal Information where applicable.

§ 26.07 Right to Non-Discrimination.

Eligible consumers may exercise applicable privacy rights without unlawful discriminatory treatment.

§ 26.08 Applicability Thresholds.

ONE shall provide applicable California notices and request mechanisms if and when ONE is subject to the applicable statutory requirements.

ARTICLE XXVII

PRIVACY REQUESTS

§ 27.01 Submission.

Applicable privacy requests may be submitted through:

Privacy Request Portal: [PRIVACY REQUEST URL]

Email: [PRIVACY EMAIL]

Telephone: [PRIVACY TELEPHONE, IF REQUIRED]

§ 27.02 Verification.

ONE may reasonably verify the identity or authority of a requester before fulfilling a request.

§ 27.03 Authorized Agents.

ONE shall recognize authorized agents where required by Applicable Law and may request legally permissible evidence of authorization.

§ 27.04 Response.

ONE shall respond within time periods required by Applicable Law.

§ 27.05 Exceptions.

ONE may deny, limit, or partially fulfill a request where permitted or required by Applicable Law.

§ 27.06 Appeals.

Where Applicable Law establishes an appeal right following denial of a privacy request, ONE shall provide an applicable appeal mechanism.

ARTICLE XXVIII

NON-DISCRIMINATION

§ 28.01 Statutory Rights.

ONE shall not unlawfully discriminate against a person for exercising an applicable statutory privacy right.

§ 28.02 Permitted Distinctions.

This Article does not prohibit lawful differences reasonably related to the value or functionality of a Service where permitted by Applicable Law.

ARTICLE XXIX

MARKETING COMMUNICATIONS

§ 29.01 Marketing.

ONE may send marketing communications where legally permissible.

§ 29.02 Unsubscribe.

Users may unsubscribe from applicable email marketing through the unsubscribe mechanism provided in the communication.

§ 29.03 Administrative Communications.

Unsubscribing from marketing communications does not necessarily prevent ONE from sending:

(a) transactional communications;

(b) security alerts;

(d) Account notices;

(e) Membership notices; or

(f) other nonmarketing communications reasonably necessary to administer a Service.

ARTICLE XXX

THIRD-PARTY LINKS AND SERVICES

§ 30.01 Independent Services.

ONE Services may contain links to or integrations with Third-Party websites, applications, payment processors, Providers, social platforms, governmental sites, schools, businesses, nonprofits, religious organizations, healthcare Providers, employers, landlords, or other independent services.

§ 30.02 Independent Privacy Practices.

Unless otherwise provided by Applicable Law or agreement, the independent Third Party's privacy practices govern information processed independently by that Third Party.

§ 30.03 Links.

ONE's inclusion of a link does not cause the Third Party's privacy policy to become ONE's privacy policy.

ARTICLE XXXI

BUSINESS TRANSFERS

§ 31.01 Corporate Transactions.

Subject to Applicable Law, Personal Information may constitute an asset transferred, disclosed, reviewed, or otherwise processed in connection with a corporate Transaction.

§ 31.02 Recipient Restrictions.

ONE may require a recipient to process transferred information subject to applicable contractual and legal restrictions.

ARTICLE XXXII

LAW ENFORCEMENT AND GOVERNMENTAL REQUESTS

§ 32.01 Legal Process.

ONE may preserve or disclose information where required or lawfully permitted in response to legally sufficient governmental process.

§ 32.02 Legal Sufficiency.

ONE may evaluate governmental requests for legal sufficiency.

§ 32.03 No General Governmental Access.

Nothing in this Privacy Policy grants a governmental entity access to Personal Information beyond access permitted or required by Applicable Law, User authorization, or applicable agreement.

ARTICLE XXXIII

EMERGENCY DISCLOSURES

§ 33.01 Emergency Circumstances.

Where permitted by Applicable Law, ONE may disclose information where ONE reasonably and in good faith determines disclosure is necessary concerning an emergency involving an imminent risk of death or serious physical injury.

§ 33.02 No Emergency Monitoring Guarantee.

ONE does not guarantee continuous monitoring of communications for emergencies.

§ 33.03 No Emergency Response Service.

ON is not an emergency-response service.

ARTICLE XXXIV

INTERNATIONAL USERS

§ 34.01 United States Platform.

ONE is intended principally as a United States platform unless ONE expressly provides otherwise.

§ 34.02 Access From Other Jurisdictions.

Access from another jurisdiction does not necessarily mean ONE has offered every Service within that jurisdiction.

§ 34.03 Applicable International Requirements.

Where international privacy law applies to a particular processing activity, ONE shall address applicable legal requirements.

ARTICLE XXXV

DO NOT TRACK AND GLOBAL PRIVACY CONTROL

§ 35.01 Do Not Track.

Browser "Do Not Track" signals are not governed by a uniform federal standard requiring identical treatment by all websites.

§ 35.02 Universal Opt-Out Mechanisms.

Where Applicable Law requires ONE to recognize an applicable universal opt-out mechanism, including Global Privacy Control, ONE shall implement recognition for covered processing.

ARTICLE XXXVI

DEIDENTIFIED AND AGGREGATED INFORMATION

§ 36.01 Permitted Uses.

ONE may create and use Deidentified Information or Aggregated Information for lawful purposes, including:

(a) analytics;

(b) research;

(d) Service improvement;

(e) business intelligence;

(f) trend analysis; and

(g) statistical analysis.

§ 36.02 Maintenance of Deidentified Status.

Where Applicable Law imposes requirements concerning maintenance of deidentified status, ONE shall comply with applicable requirements.

ARTICLE XXXVII

DATA MINIMIZATION

§ 37.01 Minimization Standard.

ONE may seek to limit collection and processing to information reasonably necessary and proportionate for disclosed purposes, applicable Services, legal requirements, security, fraud prevention, and legitimate operational needs.

§ 37.02 Collection Capability.

Collection capability alone does not establish a business necessity to collect a category of Personal Information.

ARTICLE XXXVIII

PURPOSE LIMITATION

§ 38.01 Incompatible Processing.

ONE shall not materially expand processing of Personal Information into an incompatible purpose where Applicable Law requires additional notice, consent, or authorization without providing the legally required mechanism.

ARTICLE XXXIX

SENSITIVE PERSONAL INFORMATION

§ 39.01 Additional Protections.

Sensitive Personal Information may receive additional protections.

§ 39.02 Processing Restrictions.

ONE may restrict:

(a) collection;

(b) access;

(d) public display;

(e) disclosure;

(f) profiling; and

(g) secondary use

where required by Applicable Law or reasonably appropriate to the applicable risk.

ARTICLE XL

ACCOUNT CLOSURE

§ 40.01 Closure Request.

Users may request Account closure through available Account functionality or designated support channels.

§ 40.02 Continued Retention.

Account closure does not necessarily require immediate deletion of all Personal Information.

§ 40.03 Permitted Retention.

ONE may retain information where reasonably necessary and legally permissible for:

(a) fraud prevention;

(b) security;

(d) tax obligations;

(e) legal compliance;

(f) disputes;

(g) contract enforcement;

(h) claims; and

(i) other lawful retention purposes.

ARTICLE XLI

PRIVACY OF PASSWORDS AND ACCOUNT CREDENTIALS

§ 41.01 User Responsibility.

Users are responsible for maintaining confidentiality of credentials under their control.

§ 41.02 Unauthorized Access.

Users should promptly notify ONE of suspected unauthorized Account access.

§ 41.03 Protective Measures.

ONE may suspend or restrict an Account where reasonably necessary to investigate suspected unauthorized access or protect Users and systems.

ARTICLE XLII

INFORMATION RELATING TO OTHER PERSONS

§ 42.01 Authorization.

A User shall not submit another person's Personal Information unless legally authorized to do so.

§ 42.02 Sensitive Third-Party Information.

A User should not publicly post another person's:

(a) home address;

(b) telephone number;

(d) government identifier;

(e) financial information;

(f) precise location;

(g) health information; or

(h) other Sensitive Personal Information

without lawful authority.

ARTICLE XLIII

USER-GENERATED REPORTS

§ 43.01 Reports.

ONE may permit Users to report:

(a) Content;

(b) Users;

(d) Providers;

(e) Transactions;

(f) safety concerns;

(g) fraud;

(h) policy violations; or

(i) other matters.

§ 43.02 Processing of Reports.

ONE may process information contained in reports for:

(a) investigation;

(b) moderation;

(d) dispute resolution;

(e) legal compliance; and

(f) enforcement.

§ 43.03 Sensitive Information.

Reports should not contain unnecessary Sensitive Personal Information.

ARTICLE XLIV

RESEARCH, STATISTICS, AND PLATFORM IMPROVEMENT

§ 44.01 Internal Purposes.

ONE may use lawfully processed information to understand platform performance, identify trends, improve Services, develop features, prevent fraud, measure system reliability, and conduct internal research.

§ 44.02 Deidentified or Aggregated Information.

Where reasonably possible and appropriate, ONE may use Aggregated or Deidentified Information for such purposes.

ARTICLE XLV

PRIVACY AND ONE RECOGNITION

§ 45.01 Recognition Programs.

Participation in ONE Recognition or ONE Awards may require information concerning the applicant or organization.

§ 45.02 Public Recognition.

ONE may disclose Recognition publicly where the applicable program is designed to confer public recognition.

§ 45.03 Confidential Information.

Information designated confidential shall be handled according to applicable program terms and this Privacy Policy.

ARTICLE XLVI

PROVIDER PRIVACY OBLIGATIONS

§ 46.01 Lawful Processing.

Providers receiving Personal Information through ONE shall process such information only as legally permitted.

§ 46.02 Prohibited Processing.

Provider access to Personal Information does not authorize:

(a) identity theft;

(b) harassment;

(d) unauthorized marketing;

(e) unlawful discrimination;

(f) sale or disclosure of information contrary to Applicable Law or contract; or

(g) other unlawful processing.

§ 46.03 Enforcement.

ONE may restrict Provider access for material privacy or security violations.

ARTICLE XLVII

NO ABSOLUTE CONFIDENTIALITY OR SECURITY GUARANTEE

§ 47.01 Security Measures.

ONE may employ privacy and security measures according to applicable legal and operational requirements.

§ 47.02 No Absolute Guarantee.

NO INTERNET, NETWORK, SOFTWARE, DATABASE, STORAGE SYSTEM, COMMUNICATION SYSTEM, OR SECURITY MEASURE CAN BE WARRANTED AS ABSOLUTELY SECURE.

§ 47.03 Mandatory Obligations.

Nothing in this Article disclaims a security, privacy, notification, or data-protection obligation that Applicable Law directly imposes upon ONE.

ARTICLE XLVIII

CHANGES TO THIS PRIVACY POLICY

§ 48.01 Amendments.

ONE may amend this Privacy Policy prospectively.

§ 48.02 Last Revised Date.

The revised Privacy Policy shall display an updated "Last Revised" date.

§ 48.03 Material Changes.

Where Applicable Law requires additional notice or consent for a material change, ONE shall provide the legally required notice or obtain the legally required authorization.

§ 48.04 Retroactive Processing.

ONE shall not rely upon a Privacy Policy amendment to retroactively authorize processing where Applicable Law requires additional consent.

ARTICLE XLIX

§ 49.01 Private Status.

Neither this Privacy Policy nor ONE's compliance with federal, state, local, or other privacy requirements establishes ONE as a governmental entity.

§ 49.02 Michigan Limited Liability Company.

ONE remains a private Michigan limited liability company.

§ 49.03 Government Participation.

Government participation in ON does not independently provide governmental entities with ownership or unrestricted access to ONE's private systems or Personal Information.

ARTICLE L

MANDATORY-LAW SAVINGS CLAUSE

§ 50.01 Mandatory Legal Rights and Obligations.

NOTWITHSTANDING ANYTHING TO THE CONTRARY IN THIS PRIVACY POLICY, NO PROVISION SHALL BE CONSTRUED TO DISCLAIM, WAIVE, RESTRICT, TRANSFER, ELIMINATE, OR LIMIT ANY PRIVACY RIGHT, DATA-SECURITY OBLIGATION, BREACH-NOTIFICATION OBLIGATION, CHILD-PROTECTION REQUIREMENT, CONSUMER RIGHT, HEALTH-INFORMATION OBLIGATION, BIOMETRIC OBLIGATION, GOVERNMENTAL OBLIGATION, OR OTHER LEGAL REQUIREMENT TO THE EXTENT SUCH TREATMENT IS PROHIBITED BY APPLICABLE LAW.

§ 50.02 Controlling Law.

Where Applicable Law provides a greater mandatory protection than this Privacy Policy, the mandatory legal requirement shall control to the extent applicable.

§ 50.03 Remaining Provisions.

Any provision not affected by such mandatory legal requirement shall remain effective to the maximum extent permitted by Applicable Law.

ARTICLE LI

RELATIONSHIP TO MASTER TERMS

§ 51.01 ONE Legal Framework.

This Privacy Policy forms part of ONE's legal framework and shall be construed with, where applicable:

(a) Master Terms of Use and Services Agreement;

(b) ONE Membership Agreement;

(d) ONE Card Terms;

(e) ON Network Rules;

(f) Provider Agreement;

(g) Marketplace and Transaction Terms;

(h) Booking and Appointment Terms;

(i) Child and Family Privacy Notice;

(j) Healthcare Privacy Notice;

(k) Cookie Policy;

(l) Employment and Opportunity Rules;

(m) Housing Rules;

(n) Government Bulletin Terms;

(o) Educational Bulletin Terms;

(p) Tax Liability, Reporting, and Withholding Disclaimer; and

(q) other applicable supplemental terms.

§ 51.02 Privacy Matters.

This Privacy Policy governs applicable privacy practices.

§ 51.03 Contractual Use.

The Master Terms of Use and Services Agreement governs contractual use of ONE Services, subject to Applicable Law.

ARTICLE LII

CONTACT ONE REGARDING PRIVACY

§ 52.01 Privacy Office.

Privacy questions and legally applicable privacy requests may be directed to:

OFFICE OF NATIONAL EXCELLENCE, LLC

ATTN: PRIVACY OFFICE

Privacy Email: [PRIVACY EMAIL]

Privacy Request Portal: [PRIVACY REQUEST URL]

Telephone: [PRIVACY TELEPHONE, IF REQUIRED]

Mailing Address: [PRIVACY MAILING ADDRESS]

Official Domain: ONEUSA.us

ARTICLE LIII

FINAL PRIVACY NOTICE

§ 53.01 Notice.

BY USING A SERVICE SUBJECT TO THIS PRIVACY POLICY, USERS ARE PROVIDED NOTICE OF THE DATA PRACTICES DESCRIBED HEREIN.

§ 53.02 Consent Where Legally Required.

WHERE APPLICABLE LAW REQUIRES AFFIRMATIVE CONSENT RATHER THAN NOTICE, USE OF THE SERVICE ALONE SHALL NOT SUBSTITUTE FOR THE LEGALLY REQUIRED CONSENT.

§ 53.03 Non-Waivable Rights.

NOTHING IN THIS PRIVACY POLICY SHALL BE INTERPRETED TO WAIVE A PRIVACY, CONSUMER-PROTECTION, CHILD-PROTECTION, SECURITY, HEALTH-INFORMATION, OR OTHER STATUTORY RIGHT THAT APPLICABLE LAW DOES NOT PERMIT TO BE WAIVED.

OFFICE OF NATIONAL EXCELLENCE, LLC

ONE

ON | ONE NETWORK

Official Domain: ONEUSA.us

MASTER PRIVACY POLICY

Effective Date: September 16, 2026

Last Revised: September 16, 2026

Last Updated

September 16, 2026 at 6:39:45 AM

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