Privacy Notice

Effective Date: September 18, 2026

New Eagle, LLC (“New Eagle,” “we,” “us” or “our”) respects your concerns about privacy. This Privacy Notice describes the types of personal information we collect on https://openecu.com (the “Site”), how we may use the information and with whom we may share it. This notice also describes the measures we take to safeguard personal information and how users can contact us about our privacy practices.

Information We Obtain

We may obtain certain personal information about you on the Site, such as:

• Contact information (such as name, telephone number, postal address and email address)
• User name and password
• Other personal information contained in content you choose to submit on the Site (such as information submitted in a Contact Us form)

In addition, when you visit the Site, we may obtain certain information by automated means, such as cookies, web server logs and web beacons. The information collected in this manner may include IP addresses, operating system type, browser type, domain and other system settings.

A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag, or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server. Through these automated collection methods, we may obtain “clickstream data,” which is a log of content on which a visitor clicks while browsing a website. As a visitor clicks through the website, a record of the action may be collected and stored. Your browser may allow you to be notified when you receive certain types of cookies or to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all features of our Site.

We may use third-party web analytics services on our Site, such as Google Analytics. These services help us analyze how users interact with the Site. Information collected for this purpose, including your IP address and other information collected by automated means, may be disclosed to or collected directly by these service providers. To learn about opting out of Google Analytics, you may visit https://tools.google.com/dlpage/gaoptout.

The providers of other third-party plug-ins or services on our Site, such as social sharing tools, may use automated means to collect information regarding your use of the Site and your interactions with those services. This information is subject to the privacy policies or notices of those providers. We are not responsible for their information practices.

How We Use The Information We Obtain

We may use the information you provide to:

• Respond to, process and communicate with you about your requests, inquiries and comments
• Manage user accounts and access to applicable OpenECU or New Eagle services
• Send you news updates, promotional materials and other communications
• Operate, evaluate and improve our business, including enhancing and improving our services, managing our communications, performing data analytics and performing other internal functions
• Protect against, identify and prevent fraud and other unlawful activity, claims and other liabilities
• Comply with applicable legal requirements, industry standards and our own policies and terms

We also may use the information in other ways for which we provide specific notice at the time of collection.

We may use information obtained online through cookies, web beacons and other automated means for purposes such as customizing visitors’ experiences on the Site, delivering content that may be tailored to users’ interests and understanding the manner in which visitors browse the Site.

We also use this information to help diagnose technical and service problems, administer the Site, understand Site usage and gather demographic or analytical information about our visitors.

We may use clickstream data to determine how much time visitors spend on pages of the Site, how visitors navigate through the Site and how we may tailor the Site to better meet visitors’ needs.

Interest-Based Advertising

New Eagle may collect information about your online activities for use in providing advertising or communications about products and services that may be relevant to your interests.

You may see certain advertisements on other websites because New Eagle may participate in advertising networks or use third-party advertising services. These services may use cookies, web server logs, web beacons or similar technologies to collect information about online activity and provide advertisements that may be tailored to your interests. This process may also help us measure the effectiveness of our marketing efforts. You can learn more about options for interest-based advertising at https://optout.aboutads.info.

Sharing of Information

We do not sell or otherwise disclose personal information we collect about you except as described in this Privacy Notice. We may share personal information with service providers who perform services on our behalf based on our instructions. We also may share personal information with our subsidiaries, affiliates and related entities.

We also may disclose information about you if we are required to do so by law, regulation or legal process, in response to requests by government agencies or law enforcement authorities, or when we believe disclosure is necessary or appropriate to prevent physical harm, financial loss, fraud or other unlawful activity. We reserve the right to transfer information we have about you in connection with a sale, merger, reorganization, dissolution or transfer of all or a portion of our business or assets.

Your Options

You may contact us as described in the “How To Contact Us” section of this Privacy Notice to request that we update your preferences, remove you from applicable mailing lists or respond to other privacy-related requests.

How We Protect Personal Information

We maintain administrative, technical and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

For Residents of the European Economic Area

If you are a resident of the European Economic Area (EEA), you may have certain rights under applicable data protection laws, including the right:

• to access your personal data and obtain a copy of such personal data (right of access);
• to have inaccurate personal data corrected and incomplete personal data supplemented (right of rectification);
• to have your personal data erased to the extent permitted by applicable data protection law (right to erasure);
• to restrict processing of your personal data to the extent permitted by applicable law (right to restriction of processing); and
• to receive certain personal data you have provided to us in a structured, commonly used and machine-readable format and, where applicable, transmit such personal data to another controller (right to data portability).

Where permitted by applicable law, you may also have the right to object to certain processing of your personal data, including processing for direct marketing purposes.

Where you have given consent to the processing of your personal data, you may have the right to withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

To exercise applicable privacy rights, you may use the contact details provided below under “How To Contact Us.” Depending on your jurisdiction, you also may have the right to lodge a complaint with an appropriate supervisory authority.

We may require additional information from you in order to verify your identity and respond to your request.

For Residents of California

California residents may have certain rights under applicable California privacy laws, including rights to request information about personal information collected about them, request access to or deletion of certain personal information, request correction of inaccurate personal information, and exercise applicable privacy rights without unlawful discrimination.

Depending on applicable law and how personal information is processed, California residents also may have rights relating to the sharing or use of personal information for certain advertising purposes.

Requests regarding your personal information may be submitted using the contact information provided below under “How To Contact Us.” We may need to verify your identity before completing certain requests.

Links to Other Websites

Our Site may contain links to other websites for your convenience and information. These websites may be operated by companies not affiliated with New Eagle. Linked websites may have their own privacy policies or notices, which we encourage you to review if you visit them. We are not responsible for the content, use or privacy practices of websites that are not operated by New Eagle.

Updates To Our Privacy Notice

This Privacy Notice may be updated periodically and without prior notice to reflect changes in our personal information practices, legal requirements or Site functionality.

How To Contact Us

If you have any questions or comments about this Privacy Notice, or if you would like us to update information we have about you or your preferences, please contact us at sales@neweagle.net.

You also may write to us at:

New Eagle, LLC
5220 S State Rd
Ann Arbor, MI 48108
USA