Privacy Policy

This Policy applies to information collected through the website and related communications. It does not replace a transaction-specific privacy notice or disclosure that may be provided in connection with a financial product, securities offering, borrower application, due-diligence process, or completed transaction. If a transaction-specific notice conflicts with this Policy, the transaction-specific notice controls for the information and transaction it covers.

Depending on how you interact with TCL, we may collect:

Contact and identity information

• Name;
• Company or entity name;
• Email address;
• Telephone number;
• Mailing or business address; and
• Professional title or role.

Financing and property information

• Property address and property type;
• Requested loan amount and lien position;
• Existing debt and senior-loan terms;
• Proposed use of proceeds;
• Ownership, development, construction, rental, and transaction information;
• Estimated property value and exit strategy; and
• Other information included in a deal submission or financing inquiry.

Investor and compliance information

When applicable, TCL or its service providers may collect information needed to evaluate investor eligibility and comply with law, including accredited-investor verification, entity information, tax forms, identity-verification information, beneficial ownership, sanctions screening, source-of-funds information, subscription documents, and transaction records.

TCL does not request that prospective investors submit sensitive verification materials through a general website contact form. Accredited-investor verification and transaction documentation should be handled through an approved secure process.

Device and usage information

We may automatically collect IP address, browser and device type, operating system, referring pages, pages viewed, approximate location derived from IP address, timestamps, interactions, and cookie or similar-technology identifiers.

Communications

We may retain emails, telephone records where lawfully maintained, messages, form submissions, documents, and other communications with TCL.

We may collect information:

• Directly from you;
• From your authorized representatives, advisers, brokers, attorneys, accountants, or business partners;
• From service providers supporting identity verification, accredited-investor verification, underwriting, title, escrow, appraisal, analytics, hosting, communications, compliance, or transaction administration;
• From public records, property records, regulatory filings, sanctions lists, and commercially available databases; and
• Automatically through the Site and associated technologies.

We may use information to:

• Respond to inquiries and communicate with you;
• Evaluate proposed financing and investment transactions;
• Conduct underwriting, due diligence, identity verification, eligibility review, fraud prevention, and sanctions screening;
• Prepare, administer, service, monitor, modify, enforce, or report transactions;
• Maintain investor, borrower, noteholder, loan, and compliance records;
• Process subscriptions, payments, distributions, interest, and tax reporting;
• Operate, secure, troubleshoot, and improve the Site;
• Protect TCL, its users, investors, borrowers, affiliates, and transaction participants;
• Comply with legal, regulatory, audit, accounting, tax, insurance, and record-retention obligations; and
• Establish, exercise, or defend legal rights.

We may disclose personal information to:

Service providers

Providers supporting hosting, cybersecurity, analytics, email, document management, electronic signatures, identity and accredited-investor verification, compliance, accounting, tax reporting, payment processing, escrow, title, appraisal, insurance, loan servicing, construction monitoring, legal services, and similar functions.

Transaction participants and professional advisers

Borrowers, lenders, investors, property owners, guarantors, collateral agents, servicers, escrow holders, title companies, appraisers, insurers, contractors, brokers, attorneys, accountants, consultants, and other persons involved in evaluating, documenting, closing, administering, or enforcing a transaction, when appropriate.

Affiliates

TCL may disclose information to affiliated entities when reasonably necessary to evaluate, document, administer, or report an affiliated transaction, manage shared operations, comply with law, or protect legal rights. Affiliate access is subject to applicable confidentiality and legal requirements.

Governmental and legal recipients

Regulators, courts, law-enforcement agencies, tax authorities, self-regulatory organizations, or other persons when required or permitted by law, subpoena, court order, regulatory request, or to protect legal rights and safety.

Business successors

A prospective or completed purchaser, successor, lender, investor, merger partner, or other participant in a corporate transaction involving TCL, subject to appropriate confidentiality protections where applicable.

TCL does not sell personal information for monetary consideration. TCL does not knowingly share personal information for cross-context behavioral advertising.

TCL may disclose information to service providers, affiliates, and transaction participants for the business and transaction purposes described in this Policy. Those disclosures are not intended to constitute a “sale” or “sharing” under California privacy law.

The Site may use cookies and similar technologies necessary for security, functionality, performance, and analytics. Browser settings may allow you to block or delete cookies, but doing so may affect Site operation.

Where required by applicable law, TCL will honor legally recognized browser-based opt-out preference signals. Because TCL does not presently sell personal information or share it for cross-context behavioral advertising, an opt-out mechanism may not be displayed unless those practices change.

Certain personal information collected in connection with a financial product or service may be subject to the federal Gramm-Leach-Bliley Act, the California Financial Information Privacy Act, or other financial-privacy requirements. Where applicable, TCL will provide any additional transaction-specific privacy notice required by law. Such a notice will govern the covered financial information.

TCL retains personal information for as long as reasonably necessary for the purposes described in this Policy, including transaction evaluation, servicing, investor and borrower records, dispute resolution, fraud prevention, tax and accounting requirements, and legal or regulatory retention obligations.

Retention periods vary based on the type of information, whether a transaction closes, applicable limitation periods, contractual obligations, and regulatory requirements. Information may be retained after a relationship ends when reasonably necessary or legally required.

TCL uses reasonable administrative, technical, and physical safeguards designed to protect personal information. No website, email system, transmission method, or storage system can be guaranteed to be completely secure.

Do not send Social Security numbers, bank passwords, authentication codes, complete account credentials, or unrequested sensitive documents through ordinary email or the general Site contact form. TCL will provide an approved secure process when such information is legitimately required.

To the extent applicable, California residents may have the right to:

• Know the categories and specific pieces of personal information TCL has collected;
• Know the categories of sources, purposes, and recipients associated with that information;
• Request correction of inaccurate personal information;
• Request deletion of personal information, subject to legal exceptions;
• Receive a portable copy of qualifying information;
• Opt out of the sale or sharing of personal information, if those practices occur;
• Limit certain uses of sensitive personal information, where applicable; and
• Not receive discriminatory treatment for exercising privacy rights.

These rights may be limited by exceptions, including information governed by financial-privacy laws, information needed to complete or administer a transaction, security and fraud-prevention records, and information TCL must retain under other laws.

Requests may be submitted to privacy@thorntoncapitallending.com. TCL may need to verify your identity and authority before responding. An authorized agent may submit a request where permitted by law, subject to verification of the authorization.

The Site is intended for adults and business users. TCL does not knowingly collect personal information from children under 13 and does not knowingly sell or share personal information belonging to individuals under 16.

The Site may link to third-party websites or services. Their privacy practices are governed by their own policies, and TCL is not responsible for those practices.

TCL may update this Policy by posting the revised version and changing the “Last updated” date. Material changes will be communicated when required by law.

Privacy questions and requests may be directed to:

Thornton Capital Lending LLC
Email: privacy@thorntoncapitallending.com
Website: thorntoncapitallending.com/contact