Privacy Policy

This Privacy Policy shall be effective as of July 20, 2023.

This website is owned and operated by Ready Capital Group. At Ready Capital Group, we prioritize and safeguard the privacy of our website visitors and customers. We highly value the confidentiality of our clients and have crafted this Privacy Policy to underscore our dedication to protecting your privacy. This Privacy Policy, unless specifically stated otherwise, is applicable to and outlines our practices for handling information when you use our services. These services encompass the content available on this website, as well as any other websites, pages, features, or content that we own or operate (collectively referred to as the “Site(s)”). Additionally, this policy extends to third-party applications relying on API and associated services, collectively referred to as “Services.”

These websites are designed for a general audience, and we do not knowingly gather personal or other information from individuals under the age of 18. If you are under 18 years old, please refrain from using our site. In cases where we suspect that information provided to us pertains to an individual under 18, we will promptly delete, aggregate, or anonymize such information. We encourage users to notify us if they are aware of any individuals under the age of 18 using our services so that we can take appropriate measures to restrict their access.

Ready Capital Group serves as a small business marketplace, aiding small businesses in accessing and managing capital. Our Privacy Policy applies to all users of our sites. We urge you to familiarize yourself with the Terms of Use for Ready Capital Group. In situations where we require your consent to process personal information, we will seek your approval for the collection, use, and disclosure of such information, as elaborated below. Additionally, we may offer “just-in-time” disclosures or information regarding specific Services, supplementing or clarifying our privacy practices and providing you with additional choices regarding how your data is processed.

We appreciate your cooperation in reviewing and understanding our privacy practices, and we remain committed to maintaining the security of your information on Ready Capital Group Sites.

1. Information Categories Collected

When you engage with our Sites, various types of information about you and your business are gathered.

Our Sites compile information that identifies, describes, references, is capable of being associated with, or could be linked directly or indirectly to a specific consumer, household, or device (“Personal Information”). Excluded from this definition are publicly available details from government records and deidentified or aggregated consumer information.

• Information accessible to the public through government records.
• Consumer information that has been anonymized or grouped together in a way that prevents the identification of individual details.

To establish an account and utilize our Services, we will request essential information from you. This information is either legally required (such as identity verification), necessary to deliver the requested services (for instance, submission of three (3) months of bank statements), or pertinent for specific outlined purposes detailed below. As we introduce new features and services, additional information may be requested.

It’s important to note that the choice to withhold certain information may impact our ability to serve you or could result in a degradation of our services.

1.1 Information Directly Obtained from You

Our Website may contain links to third-party websites for your convenience. We are not responsible for the content or practices of these websites.

• Personal Identification Information: This includes your full name, date of birth, demographic details (such as nationality and gender), signature, utility bills, photographs, phone number, home address, IP address, social security number, and/or email.
• Formal Identification Information: Government-issued identity documents, such as Passport, Driver’s License, National Identity Card, State ID Card, Tax ID number, passport number, driver’s license details, national identity card details, visa information, or any other details necessary to comply with legal obligations under financial, consumer protection, and commercial lending laws.
• Institutional Information: This pertains to the Employer Identification number (or an equivalent government-issued number), proof of legal formation (e.g., Articles of Incorporation), and personal identification information for all significant beneficial owners.
• Financial Information: This includes bank account details, tax return information, Federal and State Tax ID, profit and loss statements, income statements, credit score, business invoices, and wire instructions.
• Transaction Information: Details about the transactions you conduct on our Services, such as recipient names, your name, amounts, and timestamps.
• Employment Information: Office location, job title, and/or role description.
• Correspondence: Information like survey responses or details shared with our support or user research team.
• Business Information: Information about the type of business, a roster of officers, members, or managers, articles of incorporation, certificates of good standing, and ownership structure.

All collected documents and information are securely stored and protected. By availing our services, you grant permission to share the information provided to or obtained by Ready Capital Group on your behalf with lenders, other businesses essential for Ready Capital Group’s services, for Ready Capital Group’s business purposes, or to comply with regulatory and legal requirements. We assure you that, unless mandated by legal and regulatory requirements prohibiting prior notification, we will not disclose, transmit, or share these documents without your explicit permission.

1.2 Automatically Collected Information:

We capture information about your computer’s interactions with our Sites for various purposes.

Certain types of information are automatically received and stored whenever you engage with the Sites or use our Services. This data assists us in addressing customer support matters, enhancing the performance of our Sites and applications, offering you a seamless and personalized experience, and safeguarding your account against unauthorized access and fraud detection. Automatically collected information encompasses:

The information on our Website is provided for informational purposes only. We make no warranties or guarantees regarding the accuracy, completeness, or suitability of the content.

• Online Identifiers: This includes details like geolocation/tracking, browser fingerprint, operating system, browser name and version, and device IP addresses.
• Usage Data: Authentication data, security questions, click-stream data, public social networking posts, and other data collected through cookies and similar technologies.

For instance, our server logs may automatically receive and record:

• Your journey to and utilization of the Services;
• Device type and unique device identification numbers;
• Interaction of your device with our Sites and Services, including accessed pages and clicked links;
• Geographic location; and,
• Other technical data obtained through cookies, pixel tags, and similar technologies uniquely identifying your browser.

Identifiers may also be employed to recognize you when accessing our Sites through an external link, such as from a third-party site.

1.3 Information Obtained from Third Parties:

We may acquire certain information about you from external sources.

Periodically, we may receive information about you from third-party sources, as permitted or required by applicable laws. These sources may include:

• Public Databases & ID Verification Partners: Information from public databases and ID verification partners for identity verification in compliance with applicable laws.
• Credit Bureaus: With your consent, information from credit bureaus, including your credit report. Your credit report will not be disclosed without explicit permission, and it is obtained to enhance our services, match you with suitable lenders, verify your identity, and prevent fraud.
• Joint Marketing Partners & Resellers: In instances where permitted by applicable law, information may be shared by joint marketing partners or resellers to better understand your potential interest in our services.
• Advertising Networks & Analytics Providers: We collaborate with these providers to receive de-identified information about how you discovered our Sites and interacted with them. This data may be collected before account creation.

1.4 Data Anonymization and Data Aggregation

We reserve the right to utilize data that has been anonymized and aggregated for various business purposes.

Anonymization stands as a data processing method where personal information is altered or eliminated to prevent association with any specific individual. It’s important to note that, with the exception of this particular section, none of the other clauses in this Privacy Policy are applicable to anonymized or aggregated customer data. This refers to information about our customers that has been amalgamated in a manner that no longer identifies or pertains to an individual customer.

At Ready Capital Group, we may leverage anonymized or aggregate customer data for a range of business purposes. These include gaining a deeper understanding of customer needs and behaviors, enhancing our products and services, conducting business intelligence and marketing initiatives, and identifying security threats. We may conduct our own analyses on anonymized data or enable third-party analytics.

The types of data subject to anonymization may encompass transaction data, click-stream data, performance metrics, and indicators of fraudulent activity. Furthermore, should you opt to have your information deleted in alignment with the policies outlined more comprehensively below, your information will undergo anonymization or aggregation, aligning with relevant legal requirements concerning the deletion of personal information.

2. How Information is Collected

At Ready Capital Group, we gather information about you through both the application process and your interactions with our Sites.

When explicit consent is necessary for processing your personal information, we will seek your approval for the collection, usage, and disclosure of your personal information, as elaborated below. Additional, real-time disclosures or details about specific Services’ data processing practices may be provided to supplement or clarify our privacy practices, offering you additional choices regarding how we handle your data. If any aspect of this Privacy Policy is disagreeable or uncomfortable for you, we recommend discontinuing access or use of our Services promptly.

We collect the following categories of personal information from the specified sources:

• Directly from you: This may include information from forms you complete or data input through our Products and Services.
• Indirectly from you: Observing your activities on our Sites provides indirect information about your preferences and interactions.
• Third Parties: Services integrated into our offerings may contribute additional information through third-party connections.

During the Application Process: In processing your initial funding application, we may request personal details such as your name, address, phone number, email address, and other relevant information. Business-related information, including the name, address, federal and state tax ID of your business, type of business, business location, average monthly sales, state of incorporation, and landlord’s name, may also be required. This information is primarily used for order processing or as otherwise outlined herein, and it is provided by you through our Sites.

Emails and Telephone Calls: When you register for our services, we mandate an email address. We utilize your email for both transactional purposes (e.g., application updates, confirmation) and promotional outreach (e.g., newsletters, product offerings, event notifications). Our email messages may include tracking code for database analysis, capturing details like email opens and link clicks. Opt-out options are available for promotional emails. Certain communications related to Ready Capital Group services, such as service announcements, may be sent without opt-out opportunities. We may also contact you via telephone or text message (to a provided wireless number) in connection with our services, with opt-out options available.

Log Files: Whenever you visit our Sites, our servers automatically collect browser information (IP addresses, browser type, ISP, referring/exit pages, platform type, date/time stamp, and clicks) for analysis, fraud prevention, and demographic insights. IP addresses are logged for session tracking, giving us an overview of site usage. Log files are not shared externally.

Cookies: “Cookies” help us track information during your site visit or service use. These small files allow visitor counting, distinguishing repeat visitors, saving user preferences, and tracking trends. Proper site functionality relies on cookies; rejecting them may impair site operation. We do not link cookies to personally identifiable information.

Web Beacons: “Web beacons” are transparent graphic images, used alongside cookies to personalize Sites and collect limited visitor information. In email communications, web beacons aid in understanding customer behavior. We do not link web beacons to personally identifiable information.

Other Sources and Third Parties: Information from third parties is combined with existing data to create targeted advertising and product recommendations. If others provide your information or you provide details about others, it will be used for the specific reason it was shared. Third-party information may assist in matching your business with various lenders.

Our Sites include links to third-party websites. These sites are independently managed, and we advise contacting them directly for details on their security practices. We do not oversee or assume responsibility for the privacy and security practices of these third parties.

3. How Your Information Is Utilized

We utilize your information for various purposes, all of which are integral to supporting the functionality of Ready Capital Group Sites and Services.

Provide Ready Capital Group Services: Your personal information is processed to deliver the Services to you. When seeking business financing from our financing partners, specific details such as identification, contact information, and income details are necessary. Without such information, we cannot furnish the Services to you.

Service Communications: Administrative or account-related information is sent to you to keep you informed about our Services. This includes updates, relevant security information, or transaction-related details. Critical service communications, essential for legal or security purposes, cannot be opted out of.

Customer Service: Processing your personal information is essential when you reach out to us for issue resolution, dispute resolution, fee collection, or problem troubleshooting. Without such processing, responding to your requests and ensuring uninterrupted use of the Services is not possible.

Research and Development: Personal information is processed to comprehend how you interact with Ready Capital Group Services. This information aids in customizing, measuring, and improving our Services, content, and application layout, as well as in developing new services.

Enhance Your Experience: Your personal information is processed to offer a personalized experience and implement requested preferences. For instance, providing access to certain personal information stored by third parties enhances your enjoyment of our Services.

Facilitate Corporate Transactions: Information about your account and Service usage may be processed in the context of corporate acquisitions, mergers, or other transactions. You have the option to close your account if you do not wish for your personal information to be processed for such purposes.

Legal and Regulatory Compliance: Compliance with laws and regulations necessitates the collection, use, and storage of your personal information. Identifying and verifying customers are crucial to comply with commercial lending laws across jurisdictions.

Enforce Terms and Agreements: Processing sensitive information helps in actively monitoring, investigating, and mitigating potentially prohibited or illegal activities. It also aids in enforcing agreements with third parties and detecting violations of user agreements.

Detect and Prevent Fraud: Personal information is processed to identify, prevent, and mitigate fraud and abuse of our services, safeguarding against account compromise or information loss.

Quality Control: Personal information is processed for quality control and staff training to ensure the provision of accurate information and a seamless experience on the Services.

Network and Information Security: Processing personal information enhances security, monitors and verifies identity or service access, combats spam, malware, or other security risks, and ensures compliance with security laws and regulations. Accurate and up-to-date information about your use of our Services is crucial for maintaining security.

By providing your information, you enable us to uphold the integrity and functionality of Ready Capital Group Sites and Services across these essential purposes.

4. Sharing of Information with Third Parties

We may share your personal information as necessitated by legal requirements, for the provision of our Services, and for valid business reasons.

We may disclose your personal information to third parties for business purposes, exclusively through written agreements outlining the purposes, mandating confidentiality, and restricting the use of disclosed information solely for contractual performance.

4.1. Legal Disclosures

You acknowledge and agree that we may reveal information you provide if compelled by law, at the behest of a third party, or if, at our sole discretion, disclosure is deemed reasonable to (1) adhere to legal requirements, requests from law enforcement, or any legal process, and (2) safeguard the rights or property of Ready Capital Group or a third party.

4.2. Lenders and/or Brokers

Upon signing up for our services or requesting a business loan through our platforms, you affirm your consent to the disclosure of your information to lenders and/or brokers within our network. No credit check will be performed without your authorization. It’s important to note that the shared information may be retained by these entities even if no agreement is reached. Directly contact each party for their privacy policies.

4.3. Disclosure to Trusted Third Parties

Upon completing your profile and application, we will share your information with third-party service providers listed on our partners page. By accepting the Terms of Use, you agree to receive marketing materials from our trusted third parties. We are not liable for their content or actions. Your information may also be shared with contractors providing services to Ready Capital Group, bound by this privacy policy.

4.4. Service Providers

We share information with contracted service providers aiding our business operations, ensuring their use aligns with the services they provide and prohibits selling your information. Examples include network infrastructure, cloud storage, payment processing, and customer support.

• Network infrastructure
• Cloud storage
• Payment processing
• Transaction monitoring
• Security
• Document repository services
• Customer support
• Internet (e.g. ISPs)
• Data analytics
• Information Technology
• Marketing

4.5. Other Companies

Information may be shared with companies we intend to merge with or be acquired by, with prior notice given for any changes in applicable policies.

4.6. Third-Party Advertising Platforms

Certain personal information may be shared with third-party advertising platforms and providers when visiting specific sections of our sites.

4.7. Professionals

We share information with professional advisors offering banking, legal, compliance, insurance, accounting, or consulting services for third-party audits or compliance with legal obligations.

4.8. Miscellaneous

Your personal information may be disclosed for any purpose with your explicit consent.

5. Managing Your Information

You have the ability to update, access, or delete your information, although legal obligations may require us to retain certain data. You can easily update or access your contact information by logging into your account, with changes taking effect immediately.

If you wish to stop using your account, you can deactivate it. Deactivating prevents further sharing with lenders, brokers, or third parties, but your information remains stored. Deactivation allows for easy restoration of your account in its entirety.

Upon request, you may delete your account, subject to legal requirements for data retention. In cases where deletion isn’t feasible, we’ll deactivate your account, opt you out of communications, and restrict access.

If we can fulfill a deletion request, data will be retained in compliance with lending laws for a reasonable period. Once deleted, your information won’t be shared, and it will only be used for internal purposes like research and marketing.

We securely store personal information throughout your account’s existence, retaining it only as long as necessary for legal, accounting, or dispute resolution purposes. Retention periods vary, as outlined below:

• Personal information for legal compliance may be retained as required by financial, consumer protection, and credit laws.
• Contact information for marketing is retained until you unsubscribe, followed by adding to a suppression list.
• User-generated content may be kept post-account closure for audit and crime prevention.
• Recorded telephone calls may be retained for up to six years.
• Technical data from tools like cookies is kept for up to one year from cookie expiry.

Information collected via technical means such as cookies, web page counters and other analytics tools is kept for a period of up to one year from expiry of the cookie.

Opting out of receiving electronic communications from us. If you no longer wish to receive promotional email communications from us, please follow the instructions provided in Section 7 below.

Your California privacy rights. In addition to the above, if you are a California resident, please review our California Privacy Notice to learn more about the personal information we collect, use and disclose, as well as your privacy rights related to your personal information under the California Consumer Privacy Act (CCPA) and its amendment, the California Privacy Rights Act (CPRA), as well as other state laws.

6. Security

We’ve implemented robust security measures to safeguard your information. This includes industry-standard encryption and proprietary security measures for data storage and transmission. While we exercise reasonable care, the internet’s inherent uncertainties prevent a 100% guarantee.

In the event of a data breach, we’ll promptly notify you, providing necessary information to meet breach notification laws.

Protect your account login and password; sharing them poses a security risk. Any unintentional disclosure due to shared account information is not our liability.

Feel free to refer to our Terms of Use for further details on security measures.

7. Choice / Opt-out of Marketing

You have the option to discontinue your use of our services.

To stop receiving our newsletter or marketing emails, follow the unsubscribe instructions in these emails or contact us at info@gmail.com

You can choose not to provide certain information, but this may limit your access to certain features of the site and the services and products you seek. Avoid posting personal information on public forums, as you are solely responsible for any such postings.

If you decide to no longer receive our services or future contacts from referred lenders, brokers, or third parties, you can cancel your account as discussed herein. Upon cancellation, your information won’t be sent to these parties, but it doesn’t guarantee they will cease contacting you. Reach out to them individually to ensure cessation.

Certain regulations mandate the retention of your information for specific periods. Due to these regulations, we may be unable to completely delete your information until the specified time requirements have expired.

8. California Privacy Notice

This section applies to California residents and complies with the California Consumer Privacy Act of 2018 and California Privacy Rights Act of 2020 (CCPA).

8.1 Personal Information We Collect

Within the last twelve months, Ready Capital Group may have collected the following categories of personal information from California residents:

Note: Some information may fall under multiple categories due to state law requirements. Sensitive personal information may include:

• Social security, driver’s license, state ID, or passport number
• Account log-in information with access codes or passwords
• Precise geolocation
• Racial and ethnic origin
• Personal information related to sex life or sexual orientation

Refer to Section 1 of the Privacy Policy for specific types of personal information collected.

We retain information for a reasonable period based on our relationship with you, legal obligations, and advisable retention in light of our legal position.

8.2 Uses of Personal Information

Personal information may be collected, used, or disclosed for purposes listed in Section 3 of the Privacy Policy, including sensitive personal information.

8.3 Sources of Personal Information

Personal information may be collected from sources listed in Sections 1.3 and 2 of the Privacy Policy.

8.4 Disclosure of Personal Information

We may disclose personal information to service providers and third parties as outlined in Section 4 of the Privacy Policy. We also “sell”/”share” certain information for cross-contextual behavioral advertising.

In the last twelve months, we have “sold”/”shared” identifiers, internet activity information, and electronic activity information for cross-context behavioral advertising.

The CCPA requires us to identify the categories of personal information that we have “sold”/“shared” under the CCPA in the preceding twelve (12) months. In the last twelve (12) months, we have “sold”/”shared” the following categories of personal information to advertising partners for cross-context behavioral advertising purposes:

• Identifiers
• Internet or other electronic network activity information
• Internet or other electronic activity information

8.5 Your California Privacy Rights

California residents have specific privacy rights:

• Right to Know: Request information about personal information collection, use, disclosure, and sale.
• Right to Delete: Request deletion of personal information.
• Right to Opt-Out of Sale or Sharing: Opt-out of personal information “sale”/”sharing”.
• Right to Limit Use and Disclosure: Limit the use or disclosure of sensitive personal information.
• Right to Correct: Request correction of inaccurate personal information.
• Right to Non-Discrimination: No discriminatory treatment for exercising privacy rights.

How to Submit a Request

Contact us at info@gmail.com, call 123456789, or use our online form to make requests. Requests are subject to identification and residency verification.

Requests by Authorized Agents: Authorized agents must provide proof of authorization. Household Data: We do not collect household data. Responses: We respond within 45 days, with a possible extension of 45 days.

We will continue to update our business practices as direct regulatory guidance becomes available.

8.6 Notice of Right to Opt-Out

As detailed in Section 10.4, we “sell”/”share” personal information for cross-context behavioral advertising. Opt-out using our online form.

Direct Marketing by Third Parties: We do not disclose personal information for third-party direct marketing. California residents can inquire under the “Shine the Light” law at info@gmail.com. We update practices based on regulatory guidance.

9. Special Notice to Vermont Residents

Residents of Vermont benefit from additional protections concerning the sharing of their personal information, subject to specific exemptions.

Vermont law imposes extra restrictions on the disclosure of information pertaining to Vermont residents as long as they maintain residency in the state. In compliance with Vermont law, we commit not to share data we gather about Vermont residents with entities outside of Ready Capital Group, except under the following circumstances: (1) As allowed by applicable law; (2) With companies engaged in marketing or other services on our behalf; (3) Sharing name, contact, transaction, and experience information with other financial institutions under joint marketing agreements; or (4) With the explicit authorization or consent of the Vermont resident. Additionally, we undertake not to share non-transactional information about Vermont residents obtained from others within the Ready Capital Group family of companies, unless authorized or consented to by the Vermont resident.

10. Notification of Privacy Policy Changes

We retain the right to revise this Privacy Policy and will keep you informed of any changes; nevertheless, we recommend that you routinely review this policy for the latest details.

This privacy policy may be updated to reflect modifications in our information practices. In the event of significant changes, we will notify you through email (sent to the email address provided in your account) or through a notice on this Site. We advise you to check this page periodically for the most recent information on our privacy policy. Whenever revisions are made to this Privacy Policy, we will update the revision date at the top of the document.

11. Contact Information

Should you have any inquiries regarding this Privacy Policy or wish to exercise your privacy rights, please reach out to us using the following contact details:

180 Maiden Lane, New York,

New York 10038, United States

Telephone: 123456789

Email: info@gmail.com