1. Introduction

1.1. This Privacy Policy outlines the practices of Company (hereinafter, the "Company"), a U.S.-based financial services provider offering loans to legal entities (e.g., corporations, LLCs, partnerships), regarding the collection, processing, storage, and use of personal and business-related data.

1.2. This Policy complies with applicable U.S. federal and state laws, including but not limited to:

• The Gramm-Leach-Bliley Act (GLBA)
• The California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA)
• The Fair Credit Reporting Act (FCRA)
• The CAN-SPAM Act (for electronic communications)

1.3. By engaging with the Company’s services, submitting data, or using our website, you consent to the terms of this Policy.

2. Definitions

• Personal Data: Information that identifies, relates to, or could reasonably be linked to an individual (e.g., names, Social Security Numbers, contact details of authorized representatives).
• Business Data: Information related to a legal entity (e.g., EIN, financial statements, business credit history).
• Processing: Any operation performed on data, including collection, storage, analysis, or sharing.
• Authorized Representative: An individual acting on behalf of a legal entity (e.g., CEO, CFO, account signatory).

3. Data Collection

3.1. Categories of Data Collected

• Business Data:
  • Legal entity name, EIN/Tax ID, business registration details
  • Financial records (bank statements, revenue, credit history)
  • Loan application details (purpose, collateral, repayment terms)
• Personal Data of Authorized Representatives:
  • Full name, job title, contact information (email, phone)
  • Government-issued ID (e.g., driver’s license for KYC compliance)
• Technical Data:
  • IP addresses, cookies, device information, website usage analytics

3.2. Sources of Data

• Directly from legal entities (e.g., loan applications, agreements)
• Credit bureaus (e.g., Experian, Dun & Bradstreet)
• Public records (e.g., SEC filings, business registries)
• Third-party service providers (e.g., payment processors, background check agencies)

4. Purposes of Data Processing

4.1. Primary Objectives

• Evaluating creditworthiness and underwriting loans
• Executing loan agreements and managing accounts
• Compliance with anti-money laundering (AML) and Know Your Customer (KYC) regulations
• Marketing financial products (e.g., refinancing offers) via email, SMS, or direct mail
• Fraud prevention and risk management

4.2. Legal Bases

• Performance of a contract (e.g., loan agreement)
• Compliance with legal obligations (e.g., tax reporting under IRS regulations)
• Legitimate business interests (e.g., credit risk assessment)
• Consent (for marketing communications)

5. Marketing Communications

5.1. Opt-In Consent

• Legal entities or their representatives may opt in to receive promotional materials via email, phone, or mail.
• Explicit consent is obtained through checkboxes on digital forms (e.g., "I agree to receive marketing communications").

5.2. Content of Communications

• Loan product updates, pre-qualification offers, and educational content
• Industry insights or regulatory changes affecting borrowers

5.3. Opt-Out Rights

• Unsubscribe links are included in all marketing emails
• Requests to opt out are processed within 10 business days
• Opt-out preferences are retained indefinitely to prevent future communications

6. Data Sharing & Third Parties

6.1. Recipients of Data

• Credit bureaus and reporting agencies (to report loan performance)
• Regulatory bodies (e.g., FinCEN, SEC) as required by law
• Service providers (e.g., cloud storage, payment processors) bound by data protection agreements

6.2. Cross-Border Transfers

Data may be transferred to third countries under safeguards such as Standard Contractual Clauses (SCCs) or participation in Privacy Shield frameworks (where applicable).

7. Data Retention & Security

7.1. Retention Periods

• Business and loan-related data: Retained for 7 years post-account closure to comply with IRS and FCRA requirements
• Marketing consent records: Retained until withdrawal of consent

7.2. Security Measures

• Encryption of data in transit (TLS 1.2+) and at rest (AES-256)
• Multi-factor authentication (MFA) for system access
• Regular penetration testing and employee training on data protection

8. Your Rights

8.1. Authorized Representatives May

• Request access to or correction of Personal Data
• Object to processing for direct marketing
• Request deletion of data (subject to legal exceptions)

8.2. Legal Entities May

• Dispute inaccuracies in Business Data (e.g., credit reports)
• Request a copy of data shared with credit bureaus

8.3. Submission of Requests

Email: lenderpro3@gmail.com

Requests are verified to prevent unauthorized access and resolved within 45 days.

9. Cookies & Tracking Technologies

9.1. Types of Cookies Used

• Essential cookies (e.g., session management)
• Analytics cookies (e.g., Google Analytics 4)
• Advertising cookies (e.g., LinkedIn retargeting)

9.2. Consent Management

A cookie banner enables users to customize preferences. Users may block cookies via browser settings, but site functionality may be impaired.

10. Policy Updates

Updates are posted on our website with a revised effective date. Material changes (e.g., new data-sharing practices) are notified via email or account portal.

11. Dispute Resolution

Complaints may be submitted to lenderpro3@gmail.com. Unresolved disputes may be escalated to the American Arbitration Association (AAA) under its Commercial Rules.