Lead Registration & Customer Ownership Policy

This Nuveda AI Lead Registration & Customer Ownership Policy (“Lead Policy”) establishes the rules governing lead registration, prospect attribution, opportunity protection, duplicate leads, dormant opportunities, existing customers, reassignment, customer-requested Advisor changes, and the ownership and administration of customer relationships under the Nuveda AI Business Advisor Program.

This Lead Policy forms part of and is incorporated into the Nuveda AI Business Advisor Agreement (“Business Advisor Agreement”).

No separate signature or separate electronic acceptance of this Policy is required. An Advisor accepts this Policy by electronically accepting the Business Advisor Agreement.

1. Purpose

The purpose of this Policy is to establish clear, fair, and consistent rules for:

registering prospective customers;
determining whether a lead is valid;
establishing Advisor attribution;
resolving duplicate claims;
protecting legitimate Advisor-created opportunities;
preventing speculative lead hoarding;
identifying dormant opportunities;
reassigning opportunities when necessary;
handling existing customers and existing pipeline opportunities;
preserving customer continuity;
protecting Nuveda AI’s customer relationships; and
distinguishing customer ownership from Advisor attribution and commission rights.

2. Definitions

For purposes of this Policy:

“Lead” means a prospective customer that has not yet been accepted as an attributed customer account.

“Registered Lead” means a prospect submitted through an authorized Nuveda AI system in accordance with this Policy.

“Valid Lead” means a Registered Lead that satisfies Nuveda AI’s applicable registration requirements.

“Attributed Opportunity” means a sales opportunity assigned or recognized by Nuveda AI as attributable to an Advisor.

“Existing Customer” means an individual or organization that already has an active or otherwise recognized customer relationship with Nuveda AI.

“Existing Pipeline Opportunity” means a prospect already being actively pursued or administered by Nuveda AI, another Advisor, an employee, partner, or another authorized sales resource.

“Dormant Opportunity” means an attributed opportunity that has not received sufficient meaningful activity within the applicable period.

“Customer Relationship” means the contractual, account, service, billing, platform, and business relationship between Nuveda AI and a customer.

3. Leads Must Be Registered Through an Authorized Process

Advisors should register prospective customers through the system designated by Nuveda AI.

The authorized process may include:

Advisor Center;
CRM;
approved lead-registration form;
designated referral link or code;
or another Nuveda AI-approved system.

Nuveda AI may decline to recognize attribution that exists only in private notes or informal communications where the Advisor failed to use the designated registration process without a reasonable explanation.

4. Information Required for Lead Registration

Nuveda AI may require information such as:

prospect name;
company name;
business email;
business telephone number;
website;
industry;
geographic location;
primary contact;
source of the lead;
business need;
estimated opportunity;
current stage;
notes regarding Advisor involvement; and
other information reasonably necessary to evaluate the opportunity.

Advisors must provide accurate information to the best of their knowledge.

5. A Company Name Alone Is Not a Valid Lead

An Advisor may not reserve a business merely by entering its name into the system.

A valid registration should generally demonstrate a legitimate basis for the opportunity.

Nuveda AI may reject registrations consisting only of:

company names;
lists scraped from the internet;
public directories;
mass-uploaded businesses;
generic contact lists;
speculative targets with no meaningful Advisor activity; or
other information insufficient to demonstrate a bona fide sales opportunity.

6. Meaningful Basis for Registration

A meaningful basis for registration may include:

direct contact with the prospect;
a legitimate referral;
an existing professional relationship;
documented outreach;
a scheduled meeting;
discovery activity;
a customer request;
an authorized introduction;
or another credible basis recognized by Nuveda AI.

7. First Valid Registration

When more than one Advisor claims the same prospect, Nuveda AI may give priority to the first valid registration.

A timestamp alone does not make an invalid registration valid.

Nuveda AI may disregard an earlier registration if it was:

fabricated;
incomplete;
speculative;
bad faith;
mass-uploaded;
unsupported;
connected to an existing Company opportunity;
or otherwise invalid.

8. Attribution Is Not Created Automatically by Registration

Registering a lead does not automatically create permanent customer attribution or commission rights.

Attribution may depend upon:

validity of registration;
meaningful Advisor involvement;
customer status;
existing Company relationships;
duplicate claims;
continued opportunity development;
customer preference;
FDE or internal-sales involvement;
and other applicable rules.

9. Nuveda AI Review of Registrations

Nuveda AI may review a lead registration to determine whether:

the prospect is already a customer;
the prospect is already in the sales pipeline;
another Advisor previously registered the prospect;
the registration is legitimate;
the lead is sufficiently qualified;
a conflict exists;
the prospect falls within a restricted category;
or additional information is needed.

Nuveda AI may approve, reject, hold, merge, or reassign a registration based upon available information.

10. Existing Customers

An Advisor generally may not register an Existing Customer as a new lead.

Where an Advisor identifies a legitimate new expansion opportunity involving an Existing Customer, Nuveda AI may separately approve attribution for:

a new business unit;
a new subsidiary;
a new enterprise deployment;
a major upsell;
a new product category;
a new geographic division;
or another material expansion opportunity.

Such attribution must be expressly recognized by Nuveda AI.

11. Existing Pipeline Opportunities

A prospect may already be an Existing Pipeline Opportunity even if no contract has yet been signed.

If the prospect is already being actively pursued by Nuveda AI or another authorized sales resource, Nuveda AI may:

preserve existing attribution;
reject the new registration;
establish shared attribution;
establish an approved commission split;
add the Advisor as a contributor;
or otherwise allocate the opportunity based upon documented contribution.

12. Duplicate Registrations

Where duplicate registrations occur, Nuveda AI may review:

registration timestamps;
quality of each submission;
prospect communications;
meeting history;
discovery activity;
customer confirmation;
prior relationships;
existing CRM records;
source of introduction;
and material contribution.

13. Bad-Faith Lead Hoarding

Lead hoarding is prohibited.

Examples may include:

mass-registering companies without meaningful contact;
registering broad lists merely to block other Advisors;
registering businesses the Advisor has no reasonable intention of pursuing;
submitting fake contacts;
repeatedly renewing dormant leads without genuine activity;
or other conduct designed primarily to reserve opportunities.

Nuveda AI may remove such registrations and take disciplinary action where appropriate.

14. Lead Protection Period

Nuveda AI may provide a reasonable opportunity-protection period for a validly attributed lead.

The exact period may depend upon the nature of the opportunity.

Unless Nuveda AI communicates a different period for a particular opportunity, an attributed lead should remain protected while the Advisor is demonstrating legitimate ongoing activity.

Protection does not create permanent ownership of the prospect.

15. Qualifying Opportunity Activity

Activity supporting continued opportunity protection may include:

meaningful prospect communication;
scheduled meetings;
discovery;
demonstrations;
proposal development;
FDE coordination;
procurement discussions;
security or compliance review;
contract discussions;
approved follow-up;
customer-requested delay;
and other documented progress.

16. Dormant Opportunity Standard

Nuveda AI may classify an opportunity as Dormant when there has been no meaningful documented progress for 60 consecutive calendar days, unless the circumstances reasonably justify a longer sales cycle.

This 60-day dormancy period applies to opportunities, not to overall Advisor Active Status.

The broader Advisor inactivity period remains governed by the Active Advisor & Inactivity Policy.

17. Exceptions to Dormancy

An opportunity should not necessarily be treated as dormant where the lack of activity is reasonably explained by:

customer-requested delay;
procurement timing;
budget-cycle timing;
legal review;
security review;
enterprise implementation planning;
seasonal timing;
scheduled follow-up;
technical dependency;
or another legitimate documented reason.

The Advisor should document such circumstances.

18. Dormancy Notice

Before releasing a material attributed opportunity solely for dormancy, Nuveda AI may provide notice where practicable.

The notice may ask the Advisor to:

document recent activity;
provide a current opportunity status;
take appropriate follow-up action;
or explain why the opportunity should remain attributed.

19. Release of Dormant Leads

If a lead remains dormant without a legitimate reason, Nuveda AI may:

release the lead;
reassign the lead;
place the lead into an unassigned pool;
assign another Advisor;
assign an internal salesperson;
establish shared attribution;
or close the opportunity.

20. Reassignment Does Not Automatically Determine Commission Rights

Operational reassignment of an opportunity does not by itself determine whether the original Advisor has already earned or may later earn a commission.

Commission treatment remains governed by:

the Business Advisor Agreement;
Commission & Customer Attribution Policy;
documented contribution;
status of the underlying transaction;
and applicable law.

21. Advisor Inactivity

If an Advisor becomes Inactive under the Active Advisor & Inactivity Policy, Nuveda AI may review and reassign the Advisor’s open opportunities.

Nuveda AI may consider:

opportunity stage;
customer needs;
recent Advisor activity;
sales-cycle timing;
FDE involvement;
internal-sales involvement;
and customer continuity.

22. Advisor Suspension

During a suspension, Nuveda AI may temporarily reassign or take control of active opportunities where necessary to protect:

customers;
sales continuity;
data;
compliance;
security;
or the integrity of an investigation.

Temporary reassignment does not automatically create commission forfeiture.

23. Advisor Termination

Upon termination of the Business Advisor relationship, Nuveda AI may reassign all:

open leads;
active opportunities;
customers;
customer-support responsibilities;
discovery work;
FDE coordination;
proposals;
and related account responsibilities.

Post-termination commission rights remain governed separately.

24. Customer Request to Change Advisor

A prospect or customer may request to work with another Advisor, employee, FDE, or Nuveda AI representative.

Nuveda AI may honor that request.

Customer preference may be considered when determining future servicing responsibility.

25. Customer Request Does Not Automatically Erase Prior Contribution

A customer’s request to change Advisors does not automatically eliminate commission rights already earned.

Nuveda AI may evaluate future attribution based upon:

prior contribution;
stage of the account;
reason for the change;
future servicing;
applicable Program rules;
and applicable law.

26. Customer Relationship Belongs to Nuveda AI

All customer accounts, subscriptions, contracts, billing relationships, platform relationships, and customer records are maintained through Nuveda AI.

A Business Advisor does not acquire ownership of a customer merely because the Advisor:

identified the prospect;
registered the lead;
introduced the customer;
conducted discovery;
assisted with the sale;
supported onboarding;
or earned commission on the account.

27. Advisor Attribution Rights Are Contractual

Although the Customer Relationship is maintained by Nuveda AI, an Advisor may have contractual attribution and commission rights under the Business Advisor Agreement and incorporated policies.

Nuveda AI will not use the concept of customer ownership to disregard commission rights that have been validly created under applicable agreements and law.

28. No Property Interest in Customer Accounts

Except for contractual rights expressly granted by Nuveda AI, an Advisor does not obtain a property interest in:

customer accounts;
customer contracts;
customer data;
customer payment information;
customer credentials;
customer contact lists;
subscription relationships;
renewal rights;
goodwill;
or customer records.

29. Customer Contact Information

Customer contact information obtained through the Business Advisor Program may be used only for authorized Nuveda AI purposes.

Advisors may not treat Nuveda AI customer data as a personal customer list.

30. No Sale or Transfer of Leads

Advisors may not sell, trade, assign, pledge, gift, or otherwise transfer a registered lead or attributed opportunity without Nuveda AI authorization.

31. No Private Side Agreements for Attribution

Advisors may not create private attribution or commission arrangements with other Advisors that purport to bind Nuveda AI unless Nuveda AI approves the arrangement.

32. Authorized Commission Splits

Nuveda AI may approve commission splits involving:

multiple Advisors;
FDEs;
Account Executives;
internal sales resources;
or other authorized participants.

The split should be documented through an authorized Nuveda AI process.

33. Forward-Deployed Engineer Involvement

Assignment of an FDE does not automatically transfer the entire opportunity away from the Business Advisor.

The Advisor and FDE may each have responsibilities appropriate to the opportunity.

Applicable commission treatment is governed by the Commission & Customer Attribution Policy.

34. Internal Sales Involvement

Nuveda AI may involve internal sales, leadership, technical, legal, compliance, procurement, or implementation personnel in any opportunity.

Such involvement does not automatically eliminate Advisor attribution.

The commercial structure may be adjusted where shared contribution requires an approved split.

35. Enterprise Opportunities

Enterprise opportunities may require broader Nuveda AI involvement.

Nuveda AI may assume direct control of negotiations involving:

enterprise contracts;
security reviews;
data-processing terms;
procurement;
legal negotiations;
custom pricing;
implementation;
APIs;
MCP resources;
integrations;
data residency;
or complex technical requirements.

The Advisor should not interpret Company involvement as automatic loss of attribution.

36. Customer Contracts

All customer contracts are subject to Nuveda AI acceptance.

An Advisor may not personally enter into a customer contract on behalf of Nuveda AI unless expressly authorized.

37. Lead Source Accuracy

Advisors should accurately identify how a lead was obtained.

Advisors may not falsely claim:

personal introduction;
referral;
prior relationship;
customer request;
Company assignment;
or another source

to improve attribution.

38. Customer Confirmation

Where attribution is disputed, Nuveda AI may seek confirmation from the prospect or customer concerning:

who introduced Nuveda AI;
who conducted discovery;
which Advisor materially participated;
or other relevant facts.

Customer confirmation is one factor and may not always be dispositive.

39. CRM Records

Advisors should maintain accurate CRM records where required.

Records should reasonably reflect:

contacts;
meetings;
opportunity stage;
next steps;
customer needs;
follow-up;
and material developments.

40. Falsified CRM Activity

Falsifying CRM records is prohibited.

Examples include:

fake calls;
fake emails;
fake meetings;
fabricated customer interest;
altered timestamps;
fake notes;
or other false activity.

Such conduct may result in loss of attribution, suspension, or termination.

41. Abandoned Opportunities

An Advisor may be treated as having abandoned an opportunity where the Advisor:

stops responding;
fails to follow up for an extended period;
states that they no longer wish to pursue it;
fails to document a legitimate delay;
or otherwise ceases meaningful involvement.

Nuveda AI may reassign abandoned opportunities.

42. Customer Continuity

Customer experience and continuity may take priority over maintaining a particular Advisor as the servicing contact.

Nuveda AI may reassign servicing responsibility where reasonably necessary to protect the customer.

43. No Guaranteed Territory

Lead registration does not create an exclusive territory.

Nuveda AI may operate, advertise, sell, assign representatives, and accept customers in any geographic area.

44. No Exclusive Industry Rights

Lead registration does not create exclusive rights to:

an industry;
vertical;
market segment;
customer category;
state;
region;
or other category

unless Nuveda AI expressly grants those rights in writing.

45. No Guaranteed Company-Generated Leads

Nuveda AI does not guarantee that Advisors will receive Company-generated leads.

Lead assignment may depend upon legitimate factors including:

availability;
Advisor activity;
qualifications;
customer need;
location;
industry experience;
capacity;
technical requirements;
performance;
or other reasonable business considerations.

46. Lead Reassignment for Customer Needs

Nuveda AI may reassign an opportunity where:

a different Advisor has more appropriate expertise;
technical requirements require FDE leadership;
the customer requests a change;
the Advisor lacks capacity;
the Advisor is inactive;
the Advisor is suspended;
compliance concerns exist;
or another legitimate business reason applies.

47. Shared Opportunities

Nuveda AI may designate an opportunity as shared where multiple authorized participants materially contribute.

Shared opportunities may include:

Advisor + FDE;
Advisor + Advisor;
Advisor + Account Executive;
Advisor + internal sales;
or another approved structure.

48. Attribution Dispute Process

An Advisor disputing attribution should submit a written request through the designated Nuveda AI process.

The request should include:

prospect or customer name;
relevant dates;
basis of the claim;
supporting communications;
meeting history;
CRM records;
and other available evidence.

49. Nuveda AI Review of Attribution Disputes

Nuveda AI may review:

CRM data;
lead timestamps;
emails;
customer statements;
meeting records;
call records where available;
referral information;
FDE involvement;
sales contributions;
and other relevant evidence.

50. Possible Attribution Outcomes

Following review, Nuveda AI may determine:

sole attribution to one Advisor;
shared attribution;
an adjusted commission split;
attribution to another authorized sales resource;
no Advisor attribution;
continued review;
or another reasonable resolution.

51. Bad-Faith Attribution Claims

Knowingly false attribution claims may result in:

denial of the claim;
warning;
loss of lead-registration privileges;
suspension;
or termination.

52. Correction of Administrative Errors

Nuveda AI may correct legitimate attribution errors.

If an error caused an Advisor to be underpaid, Nuveda AI should make an appropriate correction.

If an error caused an overpayment, Nuveda AI may recover or offset the amount where permitted by law.

53. Customer Cancellation

Customer cancellation does not transfer ownership of the customer to the Advisor.

Any future reactivation or new sale may be evaluated under then-current attribution rules.

54. Former Customers

A former customer may be treated as:

a prior Nuveda AI customer;
a reactivation;
an expansion opportunity;
or a new opportunity

depending upon the circumstances and applicable rules.

Nuveda AI may determine whether new attribution is appropriate.

55. Customer Acquisition Through Multiple Channels

A prospect may encounter Nuveda AI through:

Advisor outreach;
Company advertising;
organic search;
social media;
referral partners;
events;
inbound website traffic;
internal sales;
or other channels.

Nuveda AI may evaluate which activity materially contributed to the customer relationship.

56. Attribution Technology

Referral links, cookies, CRM records, codes, and similar technology may assist with attribution.

Technology is not necessarily conclusive where evidence shows:

misuse;
fraud;
technical error;
prior relationships;
or conflicting records.

57. Customer Privacy

Lead registration must comply with applicable privacy and data-protection requirements.

Advisors should not collect unnecessary personal information merely to create a lead record.

58. Prohibited Lead Sources

Advisors may not use unlawfully obtained data to create leads.

This may include:

stolen databases;
unlawfully scraped personal information;
confidential competitor lists;
compromised accounts;
unlawfully purchased data;
or other prohibited sources.

59. Communication Preferences

Advisors must respect applicable prospect and customer opt-out requirements.

A lead may not remain “active” merely because the Advisor continues prohibited outreach after the prospect has lawfully opted out.

60. Customer Records After Reassignment

When a customer or opportunity is reassigned, the former servicing Advisor may lose access to related records where that access is no longer necessary.

The Advisor may not retain unauthorized copies.

61. Customer Records After Termination

Upon termination, former Advisors must stop accessing customer and prospect records except where expressly authorized or legally required.

Applicable data-return and deletion requirements are governed by the Customer Data & Security Policy.

62. Confidentiality

Lead lists, customer lists, CRM information, prospect data, opportunity data, and sales records may constitute confidential Nuveda AI information.

Advisors must protect such information in accordance with the Business Advisor Agreement.

63. No Competitor Transfer

An Advisor may not transfer active Nuveda AI leads or customer information to a competitor using information obtained through the Business Advisor Program.

64. No Customer Hostage Practices

An Advisor may not:

withhold customer information from Nuveda AI;
refuse to transition an account;
threaten a customer because of reassignment;
demand personal payment to release an account;
interfere with customer access;
or otherwise attempt to control a Nuveda AI customer outside the Advisor’s contractual authority.

65. No Customer Poaching Through Program Access

An Advisor may not use Nuveda AI systems or confidential customer information to solicit customers for unrelated competing products or services.

66. Customer Relationship After Advisor Departure

A customer may continue using Nuveda AI after the Advisor resigns or is terminated.

The Advisor’s departure does not terminate the customer’s contract with Nuveda AI.

67. Commission Rights After Advisor Departure

Whether a former Advisor remains entitled to any commission after departure is determined by:

the Business Advisor Agreement;
Commission & Customer Attribution Policy;
status of the commission;
reason for termination;
applicable law;
and other relevant Program terms.

Customer ownership by Nuveda AI does not itself resolve commission entitlement.

68. No Lifetime Customer Ownership

Attribution does not create:

lifetime customer ownership;
permanent account ownership;
permanent servicing rights;
perpetual territorial rights;
or an irrevocable right to control a customer relationship.

69. Customer Relationship Administration

Nuveda AI may manage customer relationships according to legitimate business needs, including through:

Customer Success;
Account Executives;
FDEs;
support teams;
technical teams;
leadership;
or other authorized personnel.

70. Program Integrity

Nuveda AI may take action against conduct intended to manipulate:

attribution;
customer ownership;
CRM records;
lead status;
opportunity stage;
commission splits;
or customer assignments.

71. Policy Enforcement

Violations of this Policy may result in:

correction of attribution;
lead removal;
warning;
loss of registration privileges;
reassignment;
recertification;
suspension;
or termination.

72. No Automatic Commission Forfeiture

Violation of this Policy does not automatically eliminate commissions already legally earned.

Commission consequences are governed by:

the Business Advisor Agreement;
Commission & Customer Attribution Policy;
Suspension & Termination Policy;
the facts of the violation;
validity of the underlying customer transaction;
and applicable law.

Fraudulent or fabricated leads do not create valid commission rights.

73. Policy Modifications

Nuveda AI may modify this Policy prospectively where reasonably necessary to reflect:

Program growth;
CRM changes;
sales-process changes;
customer needs;
technology;
legal requirements;
commission administration;
or legitimate business needs.

Material changes affecting substantial contractual rights will be handled consistently with the Business Advisor Agreement.

74. Relationship to Other Program Documents

This Policy should be read together with:

Nuveda AI Business Advisor Agreement;
Commission & Customer Attribution Policy;
Active Advisor & Inactivity Policy;
Suspension & Termination Policy;
Advisor Code of Conduct;
Advertising, Social Media & Claims Policy;
Customer Data & Security Policy; and
Earnings & Opportunity Disclosure.

If this Policy conflicts with the Business Advisor Agreement concerning a material contractual provision, the Business Advisor Agreement controls unless a later validly accepted amendment expressly provides otherwise.

75. No Separate Signature

This Policy does not require:

handwritten signature;
paper execution;
separate electronic signature;
separate checkbox; or
separate acceptance.

It is incorporated into the Business Advisor Agreement.

76. Electronic Acceptance

The Advisor accepts this Policy when the Advisor electronically accepts the Nuveda AI Business Advisor Agreement.

Nuveda AI may maintain electronic records identifying:

Advisor or user ID;
Business Advisor Agreement version;
Lead Policy version;
acceptance date and time;
electronic acceptance event; and
other reasonable evidence of acceptance.

77. Electronic Acknowledgment

By electronically accepting the Nuveda AI Business Advisor Agreement, the Advisor acknowledges and agrees that:

this Lead Registration & Customer Ownership Policy forms part of that Agreement;
registering a company name alone does not create valid attribution;
leads must have a legitimate business basis;
Nuveda AI may give priority to the first valid registration;
duplicate, existing-customer, and existing-pipeline rules apply;
attribution requires legitimate and documented Advisor involvement;
speculative lead hoarding is prohibited;
an opportunity may become dormant after approximately 60 consecutive days without meaningful progress, subject to legitimate sales-cycle exceptions;
dormant or abandoned opportunities may be released or reassigned;
Advisor inactivity, suspension, or termination may result in reassignment of opportunities;
customers may request to work with another Advisor or Nuveda AI representative;
customer contracts and customer relationships are maintained by Nuveda AI;
an Advisor does not acquire ownership of a customer merely through introduction, attribution, or commission eligibility;
Advisor attribution and commission rights are contractual rights governed by the Business Advisor Agreement and Commission & Customer Attribution Policy;
customer ownership by Nuveda AI does not eliminate commissions already legally earned;
customer and prospect information may not be sold, transferred, or used for unrelated competitive activity;
attribution disputes may be reviewed using CRM records, communications, customer confirmation, and other reliable evidence; and
fraudulent or fabricated lead activity may result in suspension or termination.

No separate signature or separate electronic acceptance of this Policy is required.

The Advisor's electronic acceptance of the Nuveda AI Business Advisor Agreement constitutes acceptance of this Policy.

NUVEDA AI LLC Nuveda AI Business Advisor Program Huntersville, North Carolina, United States