Privacy Policy

Overview

Effective Date: July 1, 2022 · Last updated: October 15, 2026

This Privacy Policy (“Policy”) explains how Trust Capital Funding LLC (“Trust Capital”, “we”, “us”, or “our”) collects, uses, shares, and protects your information. This includes information collected through our website, the Trust Capital mobile app, our merchant, partner and investor portals, and any services we provide.

Scope of Policy

This Policy is divided into two parts:

• Part 1: U.S. Privacy Policy — Applies to all users nationwide.
• Part 2: California Privacy Policy — Supplements Part 1 for California residents under the California Consumer Privacy Act (CCPA).

Part 1: U.S. Privacy Policy — Information We Collect

We collect personal and business-related information, including:

• Contact Information: Name, email, phone number, address, business name.
• Identity Information: Date of birth, Social Security Number, and government-issued identification such as a driver’s license, including photos or scans you upload.
• Financial Information: Bank and credit card statements, bank account and routing numbers (including voided checks), business revenue and existing financing, tax ID and tax documents (such as Form W-9), credit history, and payment history.
• Credit and Background Reports: With your authorization, credit reports on business owners from a consumer reporting agency, and identity-verification and public-records reports. Our credit inquiries are soft inquiries that do not affect your credit score.
• Bank Connection Data: If you choose to connect a bank account through Plaid, account and routing numbers, balances, and transaction history from your bank. We never receive your bank login credentials.
• Documents and Signatures: Applications, statements, agreements, and other documents you upload or sign, your electronic signature, and the IP address and device details recorded when you sign.
• Identifiers: IP address, username/password, Social Security Number.
• Business Details: Company size, type, beneficial ownership.
• Technical Data: Browser type, ISP, pages visited, cookies, device info, and, if you allow notifications in our app, a push-notification device token.
• Third-Party Data: Credit bureaus, social media, site visits, and partner data, including applications a broker or referral partner submits on your behalf.

Use of Information

We use collected data to:

• Evaluate and process applications for business funding
• Fund and service accounts, including processing scheduled payments
• Operate, improve, and personalize our services
• Verify identity and conduct due diligence
• Communicate account updates and marketing messages
• Provide customer support
• Send app notifications you have allowed
• Detect and prevent fraud, and meet legal and regulatory obligations
• Analyze service performance and usage trends
• Generate anonymized analytics reports

Sharing of Information

We share your information as follows:

• Affiliates & Subsidiaries: For business operations
• Trusted Service Providers: Companies that process information on our behalf for underwriting, servicing, communications, hosting, and analytics. We share only what each needs to perform its service; they may use the information only to provide their services to us and must protect it. They include Heron Data (application and bank-statement processing), LendSaaS (funding and account-servicing platform), Zoho (customer records), CRS Credit API and Experian (credit reports), identity-verification and public-records report providers, Plaid (bank connections you choose to make), Microsoft (email), Telnyx (text messages and calls), Apple (app notifications), Cloudflare (website hosting and security), and Google (website analytics).
• At Your Request: Only when you ask us to, such as when you request a product we do not fund ourselves, and only the information needed for that request
• Referral Partners: If a broker or referral partner submitted or referred your application, we share your application status, offers, and underwriting results with that partner
• Funding Participants: Investors who participate in funding your account may receive information about your business and its funding, including our underwriting analysis
• Legal Requirements: To comply with subpoenas or regulatory actions
• Business Transfers: In case of mergers or asset sales
• With Consent: Where you provide permission

We do not sell your personal information or share it with third parties for their marketing.

Text Messaging and Mobile Data

Mobile phone numbers and text-messaging consent obtained by Trust Capital Funding LLC are not shared, sold, or rented to third parties or affiliates for their own marketing or promotional purposes. Text messaging originator opt-in data and consent are excluded from all categories of information sharing described in this Policy.

Text messages we send relate to your account and your relationship with Trust Capital Funding, and may include payment reminders, notices of returned payments, account balance and payoff information, and funding confirmations. Message frequency varies. Message and data rates may apply. You may reply STOP to any message to stop further messages, or reply HELP for assistance. You may also call 617-795-2100 or write to Trust Capital Funding LLC, 770 Legacy Place, Floor 2, Dedham, MA 02026. See our SMS Terms for full program details.

Mobile App

If you allow notifications, the Trust Capital app registers a device token with Apple Push Notification service so we can send updates about your applications and accounts. You can turn notifications off at any time in iOS Settings; signing out removes your device from our notification list.

The app can use Face ID or Touch ID to unlock. Biometric data stays on your device and is never sent to us. The app does not include advertising or third-party tracking tools.

Your Choices and Rights

• Access & Update: You can request updates or deletion of your information.
• Delete Your Account: In the Trust Capital app, choose Delete my account, or email [email protected] from the email address on your account. We will confirm the request, end your app access, and delete or de-identify your personal information, except information we must keep to meet legal, regulatory, tax, or accounting obligations or to service or enforce an existing funding agreement.
• Opt-Out of Marketing: Unsubscribe via email, settings page, or by writing to us.
• Cookies & Tracking: Control cookies via your browser settings.
• Testimonial Removal: Contact us to update or remove public testimonials.
• Social Features: Governed by respective third-party privacy policies.

Data Retention & Security

• We keep application and account information while your application or account is open, and afterwards for as long as needed to meet legal, regulatory, tax, and accounting obligations, resolve disputes, prevent fraud, and enforce our agreements. You can ask us to delete information we are not required to keep; see Delete Your Account.
• We use TLS encryption and other security best practices to protect sensitive data.
• Read-only access is used for bank data; login credentials are never stored.

Part 2: California Supplement (CCPA)

Under the California Consumer Privacy Act (CCPA), California residents have specific rights.

Categories of Personal Information We Collect

• Identifiers: Name, SSN, Tax ID, email, IP address
• Personal Data: Employment history, account details, contact info
• Protected Class Info: Age/date of birth
• Commercial Info: Transaction and funding records
• Network Activity: Site visits, device data, ad interactions
• Geolocation: For fraud prevention
• Audio Data: Call recordings with customer service
• Professional Info: Job title, employment history

Your Rights Under CCPA

You may request access to or deletion of personal data, opt out of the sale of personal information, request disclosure of data-collection practices, and exercise these rights without discrimination. Trust Capital states that it does not sell personal data.

To exercise these rights, email [email protected] or write to: Trust Capital Funding LLC, ATTN: Privacy Requests, 770 Legacy Place, Floor 2, Dedham, MA 02026 USA.

Cookies, Tracking, and Advertising

We use Google Analytics cookies and event data to understand page visits and non-sensitive actions such as application-link, phone-link, and email-link clicks. Application analytics events use action labels only and do not include form values. Your browser settings can limit cookies.

For more information about cookies or to opt out, visit allaboutcookies.org.

External Sites & Social Media

• Our site links to third-party sites. Their policies apply once you leave our site.
• Public blogs or forums may expose your data — use discretion.
• Social widgets are governed by their respective platforms.

Policy Updates

We may update this Policy from time to time. Material changes will be announced on our site or via email. Please review this Policy regularly.

Contact Information

For questions or data requests, email [email protected] or write to:

Trust Capital Funding LLC
ATTN: Marketing / Privacy
770 Legacy Place, Floor 2
Dedham, MA 02026 USA

To opt out of marketing communications, provide your full name, business name, email, mailing address, and account number via [email protected] or mail to the address above, Attn: Marketing Opt-Out.