Slickview Capital ("Slickview Capital," "Slickview," "we," "us," or "our") is a commercial real estate finance and technology company. We provide transactional funding, double-close financing, bridge funding, assignment funding, earnest money deposit ("EMD") funding, commercial real estate financing, and business lending, and we operate a technology platform that connects borrowers, real estate investors, capital providers, and transaction participants (collectively, the "Services").
1. Introduction
We understand that the information entrusted to us in connection with lending, funding, and real estate transactions is among the most sensitive information our customers hold. Financial records, identity documents, transaction contracts, and business information demand a heightened standard of care, and we have designed our privacy practices accordingly.
This Privacy Policy (this "Policy") describes how we collect, use, disclose, retain, and protect information about you when you visit our website at https://slickviewcapital.com (the "Site"), apply for or receive funding, register for or use our borrower or investor portals, communicate with us, or otherwise interact with the Services. It also describes the rights and choices available to you with respect to your information and how you may exercise them.
Please read this Policy carefully. By accessing the Site or using the Services, you acknowledge that you have read and understood this Policy. If you do not agree with our practices as described in this Policy, please do not use the Site or the Services. Where the law requires consent for a particular processing activity, we will obtain that consent separately, and this Policy is not a substitute for any such consent.
This Policy is not a contract and does not create contractual rights or obligations, except to the extent required by applicable law. Our handling of certain categories of financial information is also governed by federal financial privacy law, including the Gramm-Leach-Bliley Act, as described in Section 9. Where a separate privacy notice, product-specific disclosure, or agreement applies to a particular Service, that document governs to the extent of any conflict with this Policy.
2. Scope
This Policy applies to information we collect and process in connection with:
- the Site and any subdomains, landing pages, or successor websites we operate;
- our loan and funding application processes, including applications for transactional funding, double-close financing, bridge loans, assignment funding, EMD funding, commercial real estate loans, and business loans;
- our borrower portal, investor portal, and any other authenticated platform environments we make available to customers, counterparties, or transaction participants;
- our marketplace and matching functions connecting borrowers, investors, and capital providers;
- our communications with you, including email, telephone, SMS, chat, video conference, and in-person interactions;
- our marketing, advertising, and business development activities; and
- any other product, feature, tool, or offering that links to or references this Policy.
This Policy applies to the following categories of individuals and entities (each, "you"):
- Individual borrowers and applicants, including individuals who apply for or receive funding in their personal capacity;
- Business borrowers and applicants, including entities and the individuals who act on their behalf, such as officers, members, managers, employees, and authorized signatories;
- Personal guarantors and co-signers of business or commercial obligations;
- Beneficial owners and control persons of business applicants and borrowers;
- Investors and prospective investors, including accredited investors and institutional capital providers;
- Transaction participants, such as counterparties, sellers, buyers, assignors, and assignees involved in transactions we fund;
- Website visitors and individuals who interact with our content, advertising, or communications;
- Vendors, service providers, and business partners, and their personnel; and
- Prospective customers and individuals who inquire about the Services.
This Policy does not apply to:
- information collected by third parties through their own websites, applications, or services, even where we link to them or work with them, including title companies, escrow agents, closing attorneys, banks, and identity verification providers acting under their own privacy notices;
- information about our employees, contractors, and job applicants acting in that capacity, which is governed by separate internal notices where required by law; or
- information that has been de-identified, aggregated, or anonymized such that it can no longer reasonably be linked to an identifiable individual, which we may use and disclose for any lawful purpose. Where we rely on de-identified data, we maintain it in de-identified form, do not attempt to re-identify it except as permitted by law (for example, to test the effectiveness of de-identification), and contractually require recipients to do the same.
3. Definitions
For purposes of this Policy:
- "Personal Information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an identified or identifiable individual or, where applicable law so provides, household. Personal Information does not include de-identified or aggregated information, publicly available information as defined by applicable law, or information about entities that does not relate to an identifiable individual.
- "Sensitive Personal Information" means Personal Information afforded heightened protection under applicable law, which may include Social Security numbers and other government identifiers, financial account credentials, precise geolocation, biometric identifiers processed for identification purposes, and account log-in credentials in combination with access credentials.
- "Nonpublic Personal Information" or "NPI" means personally identifiable financial information within the meaning of the Gramm-Leach-Bliley Act and its implementing regulations, including information you provide to obtain a financial product or service, information resulting from a transaction involving a financial product or service, and information we otherwise obtain in connection with providing a financial product or service.
- "Business Information" means information relating to a legal entity, including its formation, ownership, governance, operations, and finances. Business Information may include Personal Information where it relates to identifiable individuals, such as beneficial owners or authorized signatories.
- "Processing" means any operation performed on information, whether or not by automated means, including collection, recording, organization, structuring, storage, retrieval, use, disclosure, combination, restriction, erasure, and destruction.
- "Service Provider" or "Processor" means a person or entity that processes information on our behalf and pursuant to our instructions under a written contract.
- "Controller" means the person or entity that determines the purposes and means of processing Personal Information. Except where we act on behalf of another party, Slickview Capital is the controller of Personal Information processed under this Policy.
- "Applicable Privacy Laws" means the privacy and data protection laws that apply to our processing of your Personal Information, which may include the Gramm-Leach-Bliley Act ("GLBA"), the Fair Credit Reporting Act ("FCRA"), the California Consumer Privacy Act as amended by the California Privacy Rights Act ("CCPA/CPRA"), other U.S. state privacy laws described in Section 19, and, where applicable, the EU and UK General Data Protection Regulation ("GDPR").
The information we collect depends on who you are, how you interact with us, and which Services you use. A website visitor reading our educational content provides far less information than a borrower completing a funding application or an investor completing accreditation onboarding. We collect only what we reasonably need for the purposes described in this Policy, and we describe those categories below.
- Full legal name, prior names, and aliases;
- Date of birth;
- Residential and mailing addresses, and address history;
- Email addresses, telephone numbers, and other contact details;
- Government-issued identification documents and numbers, including driver's licenses, state identification cards, passports, and visas, together with the data elements they contain (photograph, document number, issuance and expiration dates, and machine-readable zone data);
- Social Security numbers, individual taxpayer identification numbers, and other government identifiers;
- Signatures, including electronic signatures and associated audit trails; and
- Photographs or images submitted for identity verification, and, where you consent or as otherwise permitted by law, biometric data derived from identity verification processes, such as facial geometry used for document-to-selfie matching and liveness detection (see Section 8).
For business applicants, borrowers, investors, and counterparties, we collect information about the entity and the individuals associated with it, including:
- Legal entity name, trade names, and DBAs;
- Entity type, state of formation, and formation date;
- Employer Identification Number ("EIN") and other tax identification numbers;
- Corporate and organizational documents, including articles of incorporation or organization, operating agreements, partnership agreements, bylaws, resolutions, certificates of good standing, and certificates of authority;
- Ownership and capitalization information, including capitalization tables, membership schedules, and equity structures;
- Beneficial ownership information, including the identity, ownership percentage, and identifying information of beneficial owners and control persons, consistent with applicable customer due diligence requirements;
- Information about officers, directors, members, managers, and authorized signatories;
- Business licenses, registrations, and permits; and
- Business contact information, business addresses, and principal place of business.
- Bank account numbers, routing numbers, and account ownership details;
- Bank statements and transaction histories;
- Wire transfer instructions and ACH authorization details;
- Payment card or payment account information where you use a payment method with us;
- Income, revenue, asset, and liability information, including tax returns, W-2s, 1099s, K-1s, profit and loss statements, and balance sheets;
- Proof of funds documentation;
- Credit history, credit scores, and consumer or commercial credit reports obtained as described in this Policy;
- Existing debt obligations, payoff statements, and lien information;
- Investor financial information, including net worth, income, liquidity, and accreditation documentation; and
- Records of payments, disbursements, draws, payoffs, defaults, and collections relating to your account with us.
Because our Services center on real estate transactions, we collect detailed information about the transactions we evaluate and fund, including:
- Property addresses, parcel numbers, and legal descriptions;
- Purchase and sale agreements, assignment contracts, and amendments;
- Double-close transaction documentation for both legs of the transaction (A-to-B and B-to-C);
- Earnest money deposit documentation;
- Settlement statements, closing disclosures, and disbursement summaries;
- Title commitments, title reports, title insurance policies, and related title documents;
- Deeds, mortgages, deeds of trust, promissory notes, and recorded instruments;
- Escrow instructions and escrow account details;
- Appraisals, broker price opinions, valuations, inspection reports, and property condition information;
- Insurance binders and policies relating to funded properties;
- Rent rolls, leases, and property operating information for income-producing properties; and
- Information about other transaction participants, including buyers, sellers, assignors, assignees, agents, brokers, title companies, escrow officers, and closing attorneys.
For investors and prospective investors, we collect:
- Accreditation status and supporting verification documentation;
- Suitability information, investment objectives, experience, and risk tolerance;
- Subscription documents, investor questionnaires, and related agreements;
- Distribution instructions and payment details;
- Tax forms and withholding certifications (for example, W-9 and W-8 series forms); and
- Entity documentation for institutional or entity investors, as described in Section 4.2.
- Employer name, occupation, title, and employment history where relevant to an application or verification;
- Professional licenses and designations (for example, real estate or brokerage licenses); and
- Business affiliations relevant to a transaction or relationship.
When you access the Site or our portals, we and our service providers automatically collect:
- IP address and approximate geographic location derived from IP address;
- Device identifiers, device type, hardware model, and operating system;
- Browser type, version, language, and settings;
- Cookie identifiers and similar technology identifiers (see Section 11);
- Referring and exit pages, URLs, clickstream data, pages viewed, links clicked, features used, and the dates and times of access;
- Session information, including session duration, scroll activity, and interaction patterns; and
- Crash reports, error logs, and diagnostic information.
- The contents of emails, chat messages, SMS messages, support tickets, and other communications you exchange with us;
- Recordings and transcripts of telephone calls and video conferences, where permitted by law and with any notice or consent that applicable law requires;
- Voicemails;
- Feedback, survey responses, and testimonials you choose to provide; and
- Records of your communication preferences, consents, and opt-outs.
When you upload documents or files to our Site or portals — for example, contracts, identification documents, bank statements, or entity records — we collect the files themselves and associated metadata, such as file names, file types, timestamps, hash values, and information about the device or account used to upload them.
To protect our customers, our capital partners, and the integrity of the Services, we collect and generate:
- Fraud signals and indicators, including device fingerprints, velocity signals, network signals, and anomalies in application data;
- Identity verification outcomes, match scores, and watchlist screening results (see Section 8);
- Internal and third-party risk scores and risk assessments relating to identity, fraud, credit, and transaction risk;
- Records of suspected or confirmed fraudulent, abusive, or unlawful activity; and
- Security logs, authentication records, and access histories for our systems and portals.
4.11 Approximate Geolocation
We collect approximate geolocation inferred from your IP address for security, fraud prevention, analytics, and compliance purposes. We do not collect precise GPS-level geolocation from your device unless you separately and expressly consent through your device settings in connection with a specific feature that requires it.
4.12 Inferences
We may derive inferences from the information described above — for example, assessments of application completeness, transaction risk, or likely interest in particular Services — to operate, secure, and improve the Services as described in this Policy.
We collect information you provide when you:
- browse the Site or submit inquiries, requests, or forms, including funding inquiries and contact forms;
- complete a loan, funding, or credit application, whether online, by email, by telephone, or through a representative;
- register for, log into, or use the borrower portal, investor portal, or other authenticated environments, including when you upload documents, complete tasks, e-sign documents, or communicate through the platform;
- complete investor onboarding, subscription, or accreditation processes;
- communicate with our team by email, telephone, SMS, chat, or video conference, including with customer support, sales, underwriting, and servicing personnel;
- participate in marketing activities, webinars, events, or surveys; or
- act as a vendor, partner, or transaction participant and provide information in that capacity.
Providing certain information is voluntary; however, if you decline to provide information we need to verify your identity, evaluate an application, or comply with law, we may be unable to provide some or all of the Services.
We and our service providers use cookies, pixels, software development kits, log files, and similar technologies to automatically collect the device, technical, and usage information described in Section 4.7 when you interact with the Site, our portals, our emails, and our advertising. Section 11 (Cookies) and Section 12 (Analytics) describe these technologies and your choices in more detail.
In connection with underwriting, verification, fraud prevention, compliance, servicing, and business operations, we collect information from sources other than you, including:
- Identity verification and fraud prevention providers, which supply identity verification results, document authentication outcomes, synthetic identity and fraud risk signals, device intelligence, and watchlist screening results;
- Bank account verification and financial data providers, which, with your authorization, supply account ownership verification, account and routing details, balances, and transaction data from your financial institutions;
- Consumer reporting agencies and commercial credit bureaus, which supply consumer reports, credit scores, and commercial credit information where permitted by the FCRA and other applicable law and, where required, with your authorization;
- Public records and government sources, including county recorder and assessor records, court records, UCC filings, tax records, and property records;
- Multiple listing service (MLS) and real estate data sources, including listing data, sales comparables, and property characteristics, where licensed or lawfully available;
- Business registries and corporate data sources, including secretary of state filings and beneficial ownership data sources;
- Government databases and watchlists, including sanctions lists maintained by the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") and other government screening resources;
- Transaction participants, including title companies, escrow agents, closing attorneys, brokers, agents, counterparties, and referral partners, who may provide contracts, payoff information, settlement documentation, and contact information;
- Capital partners and co-lenders participating in a transaction with us;
- Our service providers, including cloud, communications, analytics, and support vendors, in the course of providing services to us; and
- Marketing and lead sources, including advertising platforms, event organizers, and publicly available professional information.
Where we obtain a consumer report about you, we do so only for a permissible purpose under the FCRA and, where the FCRA or other applicable law requires it, with your written authorization. Where a third party provides us information about you, we rely on that party to have collected and shared it lawfully.
If you provide us information about another person — for example, a business partner, co-guarantor, beneficial owner, spouse, or transaction counterparty — you represent that you are authorized to do so and that you have provided that person any notice, and obtained any consent, required by applicable law. We process that information as described in this Policy.
We use the information described in Section 4 for the following purposes:
6.1 Providing the Services
- Evaluating funding inquiries and processing applications for transactional funding, double-close financing, bridge loans, assignment funding, EMD funding, commercial real estate loans, and business loans;
- Underwriting applications and making funding and credit decisions;
- Verifying identity, authority, ownership, bank accounts, and transaction details;
- Coordinating closings with title companies, escrow agents, attorneys, and counterparties, and disbursing and receiving funds;
- Originating, servicing, and administering loans and funding transactions, including billing, payment processing, payoff processing, and collections;
- Operating the borrower and investor portals, including document management, e-signature, task tracking, and status updates;
- Onboarding investors, verifying accreditation, administering investments, and processing distributions; and
- Operating marketplace functions that connect borrowers, investors, and capital providers.
6.2 Compliance and Legal Obligations
- Complying with anti-money laundering ("AML"), know-your-customer ("KYC"), know-your-business ("KYB"), customer due diligence, beneficial ownership, sanctions, and related obligations;
- Complying with lending, licensing, consumer protection, tax, and reporting obligations;
- Responding to lawful requests from courts, regulators, law enforcement, and other government authorities;
- Establishing, exercising, and defending legal claims; and
- Maintaining records as required by applicable law and our retention policies.
6.3 Fraud Prevention, Risk Management, and Security
- Detecting, investigating, preventing, and remediating fraud, identity theft, misrepresentation, and other unlawful or abusive activity;
- Assessing and managing credit, counterparty, transaction, and portfolio risk;
- Authenticating users, securing accounts, and monitoring for unauthorized access;
- Protecting the safety, rights, and property of Slickview Capital, our customers, our capital partners, and others; and
- Maintaining audit trails and investigating incidents.
6.4 Communications and Support
- Responding to inquiries and providing customer support across email, telephone, SMS, and chat;
- Sending transactional and servicing communications, such as application status updates, document requests, closing coordination, payment notices, and account alerts; and
- Maintaining records of communications for quality assurance, training, dispute resolution, and compliance, including call recordings where permitted by law.
6.5 Marketing and Business Development
- Sending marketing communications about our products, services, events, and content, subject to the choices described in Section 13;
- Personalizing content and offers, measuring campaign performance, and managing advertising, including through the technologies described in Sections 11 and 12; and
- Developing and maintaining business relationships with partners, referral sources, and vendors.
6.6 Analytics, Improvement, and Development
- Understanding how the Site and Services are used and measuring their performance;
- Improving, testing, and troubleshooting the Site, portals, and Services;
- Developing new products, features, and services, including future lending products, platform capabilities, and integrations; and
- Producing de-identified and aggregated data for benchmarking, reporting, and research.
6.7 AI-Assisted Operations
- Using artificial intelligence and machine learning tools to assist with customer support, document intake and organization, fraud detection, risk assessment, underwriting support, and service improvement, subject to the commitments described in Section 22.
6.8 Other Uses
We may use information for other purposes that are disclosed to you at the time of collection, that you direct or consent to, or that are otherwise permitted or required by applicable law. Where Applicable Privacy Laws require that a new use be compatible with the purposes described here, or that we obtain your consent, we will comply with those requirements.
7. Automated Decision-Making and Profiling
We use automated tools throughout the lending and funding lifecycle to make our processes faster, more consistent, and more secure. This section explains how.
7.1 Automated Underwriting and Risk Scoring
Our underwriting processes may use automated systems and models that analyze application data, financial information, transaction documentation, third-party verification results, credit information, and property data to assess eligibility, evaluate risk, and inform pricing and structuring. These systems may generate risk scores, flags, and preliminary determinations.
7.2 Automated Fraud Detection
We use automated fraud detection systems that analyze identity signals, device intelligence, behavioral patterns, document authenticity signals, bank account signals, and transaction characteristics to flag potential fraud, identity theft, and misrepresentation. A fraud flag may result in additional verification requirements, a delay, or, where warranted, denial or termination of Services.
7.3 Human Review
Material decisions about applications and funding — including denials — are subject to human involvement and oversight appropriate to the decision. Automated outputs inform our personnel; they do not replace the judgment of our underwriting and risk teams for decisions with significant effects on applicants. Where applicable law grants you rights with respect to decisions based solely on automated processing that produce legal or similarly significant effects, we honor those rights, including, where required, the right to obtain human review of the decision, to express your point of view, and to contest the decision.
7.4 Adverse Action and Credit Rights
Where the FCRA, the Equal Credit Opportunity Act, or other applicable law requires it, we provide adverse action notices that identify the principal reasons for a denial or other adverse decision and, where a consumer report contributed to the decision, the identity of the consumer reporting agency and your rights to obtain a copy of the report and dispute its accuracy.
7.5 State Profiling Rights
Residents of certain U.S. states have the right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects, as described in Section 19. Where an opt-out applies, certain automated features of the Services may be unavailable, and processing times may be longer.
8. Identity Verification and Compliance Screening
As a provider of financial services, we maintain a compliance program designed to verify the identity of the individuals and businesses we work with and to prevent our Services from being used for money laundering, terrorist financing, sanctions evasion, fraud, or other unlawful activity.
8.1 KYC and KYB
Before and during our relationship with you, we conduct know-your-customer and know-your-business procedures, which may include collecting and verifying:
- your legal name, date of birth, address, and government identification number;
- your government-issued identification documents;
- for entities, formation documents, good standing, registered status, EIN, business addresses, and the identity of authorized representatives; and
- other information reasonably necessary to form a sufficient understanding of who you are and the nature of your business.
8.2 Beneficial Ownership
For entity customers, we identify and verify beneficial owners and control persons, consistent with applicable customer due diligence standards. This includes collecting identifying information about individuals who directly or indirectly own a significant equity interest in the entity or who exercise significant control over it, and verifying that information against documents and independent sources.
8.3 Sanctions, Watchlist, and PEP Screening
We screen customers, beneficial owners, authorized representatives, and, where appropriate, transaction participants against government sanctions and watchlists, including lists maintained by OFAC, and against politically exposed person ("PEP") and adverse media data sources. We conduct this screening at onboarding and on an ongoing basis. We may decline, suspend, freeze, or terminate a relationship or transaction, and may make required reports to government authorities, based on screening results. Applicable law may prohibit us from disclosing that a report was made.
8.4 Document Verification, Liveness Detection, and Biometric Data
We use document verification technology to authenticate government-issued identification documents, including analysis of security features, fonts, and machine-readable data. Where we use selfie-based verification, the process may compare a live image of you to your identification document and use liveness detection to confirm that a real person is present. These processes may involve the creation and processing of biometric identifiers, such as facial geometry.
Where biometric identifiers are processed, we (and the verification providers acting on our behalf) do so only for identity verification, fraud prevention, and security purposes; we do not sell biometric identifiers; and we retain them no longer than permitted by applicable biometric privacy laws, after which they are destroyed. Where applicable law requires notice and consent before biometric data is collected — such as under state biometric privacy statutes — we or our verification provider will provide that notice and obtain that consent at the time of collection.
8.5 Ongoing Monitoring
We monitor accounts, transactions, and relationships on an ongoing basis for unusual or suspicious activity and periodically refresh due diligence information. We may request updated information or documentation from you at any time, and continued access to the Services may be conditioned on your providing it.
9. Financial Privacy and the Gramm-Leach-Bliley Act
Slickview Capital provides financial products and services. As a result, certain information we collect about individuals who obtain or apply for financial products or services from us primarily for personal, family, or household purposes constitutes Nonpublic Personal Information governed by the GLBA and its implementing regulations, including applicable safeguards and privacy rules.
Where the GLBA applies:
- we provide the privacy notices, and honor the opt-out rights, that the GLBA and its implementing regulations require;
- we maintain an information security program with administrative, technical, and physical safeguards designed to protect NPI, consistent with the GLBA Safeguards Rule, as described in Section 15; and
- we limit the disclosure of NPI to the disclosures permitted by the GLBA, including disclosures to service providers, disclosures necessary to effect or administer a transaction you request or authorize, disclosures for fraud prevention and security, and disclosures required by law.
Interaction with state privacy laws. Most U.S. state privacy laws — including the CCPA/CPRA and the other state laws described in Section 19 — exempt, in whole or in part, information collected, processed, or disclosed subject to the GLBA. Accordingly, some of the rights described in Section 19 may not apply to financial information we process subject to the GLBA. Where an exemption applies, we nonetheless maintain the safeguards and practices described in this Policy, and we apply state privacy rights to the Personal Information that remains within their scope.
Commercial-purpose data. Much of the information we process relates to commercial lending and business-purpose transactions. Information about businesses, and information about individuals acting in a commercial or employment capacity, may fall outside some Applicable Privacy Laws or within business-to-business provisions of those laws. We nonetheless handle that information with the care described in this Policy.
We do not sell your Personal Information for money. We share information only as described in this Policy, as permitted or required by law, or as you direct or authorize. The categories of recipients are:
10.1 Transaction Participants
Completing a real estate or lending transaction requires coordinated disclosure among the parties to that transaction. Depending on the transaction, we share relevant information with:
- Title companies and title agents, including for title searches, commitments, policies, and closing coordination;
- Escrow agents and settlement agents, including for escrow instructions, deposit handling, and disbursements;
- Closing attorneys and other counsel involved in the transaction;
- Counterparties and their representatives, such as buyers, sellers, assignors, assignees, and their agents and brokers, to the extent necessary to document and close the transaction; and
- Recording offices and county officials, in connection with recording deeds, mortgages, and other instruments, which become public records.
10.2 Capital and Funding Partners
- Banks and financial institutions that provide, hold, or move funds in connection with the Services;
- Warehouse lenders, credit facilities, and funding partners that finance or participate in the loans and fundings we originate;
- Institutional investors, co-lenders, participants, and loan purchasers, including in connection with participations, syndications, whole-loan sales, and securitizations, and their administrators, trustees, custodians, servicers, rating agencies, and diligence providers; and
- Capital providers and investors on our platform, to the extent necessary to evaluate, fund, and administer a transaction in which they participate.
Where we share information with these parties, we do so under confidentiality obligations appropriate to the relationship and, where the GLBA applies, consistent with its permitted-disclosure provisions.
10.3 Service Providers
We share information with service providers that process it on our behalf under written contracts that restrict their use of the information to providing services to us. These include providers of:
- identity verification, KYC/KYB, document verification, and biometric verification services;
- bank account verification and financial data connectivity services;
- fraud prevention, device intelligence, and risk scoring services;
- payment processing, money movement, ACH, and wire services;
- cloud hosting, storage, and infrastructure services;
- email delivery, SMS delivery, telephony, and communications services;
- e-signature and document management services;
- analytics, monitoring, and error-tracking services;
- customer support, ticketing, and CRM services; and
- professional, administrative, and back-office services.
10.4 Consumer Reporting Agencies and Verification Sources
Where permitted by the FCRA and other applicable law, we share information with, and receive information from, consumer reporting agencies, commercial credit bureaus, and verification data sources in connection with underwriting, verification, fraud prevention, and, where applicable, the furnishing of account information.
10.5 Professional Advisors
We share information with our lawyers, accountants, auditors, insurers, brokers, and other professional advisors where necessary for them to provide their services and subject to duties of confidentiality.
10.6 Legal, Regulatory, and Safety Disclosures
We disclose information where we believe in good faith that disclosure is necessary or appropriate to:
- comply with applicable law, regulation, legal process, or a lawful government request, including subpoenas, court orders, and examinations by regulators or licensing authorities;
- make reports required by AML, sanctions, tax, or other laws;
- enforce our agreements and policies;
- detect, prevent, or address fraud, security, or technical issues; or
- protect the rights, property, or safety of Slickview Capital, our customers, our partners, or the public.
10.7 Corporate Transactions and Successors
If we are involved in a merger, acquisition, financing, reorganization, joint venture, bankruptcy, receivership, or sale or transfer of all or a portion of our business or assets (including a loan portfolio), information may be disclosed to counterparties and their advisors in connection with diligence, and may be transferred to a successor or acquirer as part of the transaction, subject to Section 23.
10.8 Affiliates
We may share information with our current and future affiliates — entities under common ownership or control with Slickview Capital — for the purposes described in this Policy, subject to the limits of Applicable Privacy Laws, including any affiliate-sharing opt-outs required by the FCRA or GLBA.
10.9 With Your Direction or Consent
We share information with other parties when you direct us to or consent to the sharing — for example, when you ask us to coordinate with your attorney, accountant, broker, or business partner.
10.10 Advertising and Analytics Partners
As described in Sections 11 and 12, third-party advertising and analytics partners may collect information through cookies and similar technologies on the Site. Under some state privacy laws, disclosures to advertising partners for cross-context behavioral or targeted advertising may be treated as a "sale" or "sharing" of Personal Information, even without an exchange of money. You may opt out of such disclosures as described in Section 19.
We may share de-identified or aggregated information — such as aggregate funding volumes, market statistics, or performance metrics — that cannot reasonably be used to identify you, for any lawful purpose.
11. Cookies and Similar Technologies
11.1 What We Use
We and our partners use cookies, pixels, tags, local storage, and similar technologies (collectively, "cookies") on the Site and in our emails. Cookies fall into the following categories:
- Strictly necessary cookies. Required for the Site and portals to function — for example, cookies that maintain your session, keep you logged in, route traffic, remember security state, and support fraud prevention. These cannot be disabled through our cookie controls because the Services will not work without them.
- Functional and preference cookies. Remember your choices and settings — for example, language, region, and display preferences — so that the Site behaves the way you expect.
- Performance and analytics cookies. Help us understand how visitors use the Site — which pages are visited, how users navigate, where errors occur — so we can measure and improve performance. See Section 12.
- Advertising cookies. Set by us or our advertising partners to deliver and measure advertising, cap ad frequency, and build audiences, including for interest-based advertising on other websites and platforms.
11.2 Your Choices
You can control cookies in several ways:
- Cookie preferences. Where we provide a cookie banner or preference center, you may accept, decline, or customize non-essential cookies, and revisit your choices at any time.
- Browser controls. Most browsers let you block or delete cookies through their settings. Blocking cookies may impair Site functionality, and blocking strictly necessary cookies may prevent the portals from working.
- Opt-out preference signals. We honor opt-out preference signals, such as the Global Privacy Control, as required by applicable state law, treating them as a request to opt out of targeted advertising and any "sale" or "sharing" for the browser or device sending the signal.
- Industry opt-outs. You may opt out of interest-based advertising by participating companies through the Digital Advertising Alliance (optout.aboutads.info) and the Network Advertising Initiative (optout.networkadvertising.org).
- Email pixels. You can limit email tracking by disabling image loading in your email client.
Because cookie-based opt-outs are stored on your browser or device, you may need to renew your choices if you clear cookies, use a different browser, or use a different device.
12. Analytics
We use analytics services to understand and improve the Site and Services. These currently include or may include:
- Google Analytics, which uses cookies and similar identifiers to measure Site traffic and usage. You can learn how Google collects and processes data at google.com/policies/privacy/partners and opt out of Google Analytics through the browser add-on available at tools.google.com/dlpage/gaoptout.
- Microsoft Clarity, which captures session interaction data — such as clicks, scrolling, and navigation — and produces heatmaps and session replays to help us diagnose usability issues. We configure such tools to avoid capturing sensitive form fields where feasible.
- Meta Pixel, which measures the effectiveness of advertising on Meta platforms and supports audience building for our campaigns.
- LinkedIn Insight Tag, which provides campaign measurement and audience analytics for advertising on LinkedIn.
We may add, replace, or remove analytics and advertising providers over time; any such providers will be engaged consistent with this Policy, and material changes to our tracking practices will be reflected in updates to this Policy or our cookie disclosures. Your choices regarding these technologies are described in Sections 11 and 19.
13. Marketing Communications
13.1 Email
We send marketing emails about our products, services, content, and events. You may opt out at any time by using the unsubscribe link included in every marketing email or by contacting us as described in Section 25. We honor opt-out requests within the time required by the CAN-SPAM Act. Opting out of marketing email does not stop transactional or servicing communications — such as application updates, document requests, closing coordination, payment notices, and legal notices — which we send as part of providing the Services.
13.2 SMS and Text Messages
Where you provide a mobile number and any consent required by law, we may send SMS messages, which may include servicing messages (for example, status updates and verification codes) and, only with the consent required by the Telephone Consumer Protection Act ("TCPA") and applicable state law, marketing messages. Consent to marketing texts is not a condition of obtaining any funding or service. You may opt out of SMS at any time by replying STOP to any message, and you may reply HELP for assistance. Message and data rates may apply. Mobile opt-in data and SMS consent are not shared with third parties for their own marketing purposes.
13.3 Telephone
We may call you regarding your inquiries, applications, and accounts. Where the TCPA or state telemarketing laws require prior express consent for particular kinds of calls — including calls made with an automatic telephone dialing system or an artificial or prerecorded voice — we obtain that consent, and it is not a condition of obtaining any funding or service. You may request that we stop marketing calls at any time, and we maintain an internal do-not-call list and honor the National Do Not Call Registry as required by law. Calls may be recorded or monitored for quality, training, and compliance, with any notice or consent that applicable law requires.
13.4 Interest-Based Advertising
We advertise on third-party platforms and may use the technologies described in Sections 11 and 12, as well as hashed contact information matched by advertising platforms, to reach current and prospective customers. You may exercise the opt-out rights described in Sections 11 and 19.
14. Data Retention
14.1 General Approach
We retain information for as long as reasonably necessary to fulfill the purposes described in this Policy, and we calibrate retention to the nature of the information and the requirements that apply to it. The criteria we use include:
- the duration of your relationship with us and the status of your account or transaction;
- our legal, regulatory, tax, accounting, and licensing obligations, including record-retention requirements applicable to lenders and financial service providers;
- statutes of limitations applicable to potential claims arising out of our relationship or transactions;
- the needs of fraud prevention, security, and dispute resolution; and
- the operational need for the information, including backup and disaster recovery cycles.
14.2 Illustrative Retention Practices
- Application and transaction records — including applications, underwriting files, contracts, closing documents, settlement statements, and servicing records — are retained for the life of the transaction plus the period required by applicable law and appropriate to the relevant limitations periods.
- KYC, AML, and sanctions records are retained for the periods required by applicable financial crime laws, typically at least five years following the end of the relationship or the transaction, and longer where required.
- Fraud records — including information about suspected or confirmed fraud — may be retained for extended periods to protect us, our customers, and our partners from repeated fraudulent activity.
- Biometric identifiers, where processed, are retained only as long as permitted by applicable biometric privacy laws and are then destroyed, as described in Section 8.4.
- Call recordings, communications, and support records are retained for periods appropriate to quality assurance, dispute resolution, and compliance.
- Website and analytics data is retained for shorter periods appropriate to its purpose or is aggregated or de-identified.
14.3 Legal Holds
Where litigation, an investigation, an audit, or a regulatory matter is pending or reasonably anticipated, we suspend deletion of relevant information until the hold is released, notwithstanding otherwise applicable retention schedules.
14.4 Disposal
When information is no longer needed, we delete it, de-identify it, or securely destroy it in accordance with our data disposal practices and applicable law, including disposal requirements applicable to consumer report information.
15. Security
We maintain a written information security program with administrative, technical, and physical safeguards designed to protect the security, confidentiality, and integrity of the information we hold, appropriate to our size, the nature of our activities, and the sensitivity of the information, and consistent with the GLBA Safeguards Rule where applicable. Our program includes:
- Administrative safeguards, including a designated individual responsible for the security program, written policies and procedures, risk assessments, workforce training, confidentiality obligations for personnel, vendor due diligence and contractual security requirements, and periodic program review;
- Technical safeguards, including encryption of sensitive information in transit and at rest, network and application security controls, firewalls, secure software development practices, logging and monitoring, endpoint protection, and vulnerability management, including periodic security testing and assessments consistent with recognized frameworks such as SOC 2;
- Access controls, including role-based access on a need-to-know basis, unique credentials, multi-factor authentication for administrative and sensitive access, and prompt de-provisioning; and
- Physical safeguards, including controls over physical access to facilities and reliance on data center providers that maintain industry-standard physical security certifications.
Incident response. We maintain an incident response plan designed to detect, contain, investigate, and remediate security incidents. If a security incident affects your Personal Information, we will notify you and applicable regulators as required by law.
Your role. You are responsible for maintaining the confidentiality of your portal credentials, using strong and unique passwords, enabling available security features, and notifying us promptly at the contact in Section 25 if you suspect unauthorized access to your account. Be alert to wire fraud: verify wire instructions by telephone using an independently confirmed number before sending funds, and treat unexpected changes to payment instructions as presumptively fraudulent.
No guarantee. No method of transmission over the internet and no method of electronic storage is completely secure. While we work diligently to protect your information using measures appropriate to the risk, we cannot and do not guarantee absolute security, and any transmission of information to us is at your own risk to the extent permitted by law.
16. International Data Transfers
Slickview Capital is based in the United States, and the Site and Services are operated from, and directed to users in, the United States. Information we collect is stored and processed in the United States and may be processed in other countries where we or our service providers operate. Data protection laws in these countries may differ from, and be less protective than, the laws of your home jurisdiction.
If we process Personal Information of individuals located in the European Economic Area, the United Kingdom, or Switzerland, and that processing is subject to the GDPR or equivalent law, we transfer such information internationally only using lawful transfer mechanisms, such as the European Commission's Standard Contractual Clauses, the UK International Data Transfer Addendum, adequacy decisions, or another valid mechanism, together with supplementary measures where appropriate. You may contact us as described in Section 25 for more information about our transfer mechanisms.
By using the Services from outside the United States, you understand that your information will be transferred to and processed in the United States as described in this Policy.
17. Children's Privacy
The Site and Services are intended for individuals who are at least 18 years of age (or the age of majority in their jurisdiction, if higher) and are not directed to children. We do not knowingly collect Personal Information from anyone under 18, and no one under 18 may apply for funding, register for an account, or invest through the Services. Consistent with the Children's Online Privacy Protection Act ("COPPA"), we do not knowingly collect Personal Information from children under 13. If you believe that a child has provided us Personal Information, please contact us as described in Section 25, and we will delete the information as required by law.
18. Third-Party Websites and Services
The Site and our communications may contain links to third-party websites, tools, and services — for example, title company portals, e-signature platforms, banking websites, government resources, and social media pages. We do not control these third parties, and this Policy does not apply to their practices. Any information you provide to a third party is governed by that party's privacy notice, which we encourage you to review. A link from our Site is not an endorsement of a third party's privacy or security practices.
19. U.S. State Privacy Rights
This Section describes rights available to residents of U.S. states with comprehensive privacy laws, including California, Colorado, Virginia, Connecticut, Utah, Texas, Oregon, Delaware, New Jersey, Montana, Nebraska, Iowa, and Tennessee, and it will apply to residents of additional states as new comprehensive privacy laws take effect. These rights apply to Personal Information within the scope of the applicable law; as explained in Section 9, information processed subject to the GLBA or FCRA, and certain business-to-business and commercial information, may be exempt in whole or in part. Where an exemption applies, we will explain the basis for our response when you make a request.
19.1 Rights Available to State Residents
Subject to the conditions and exceptions of your state's law, you may have the right to:
- Know / Access. Confirm whether we process your Personal Information and obtain access to it, including, where required, the categories of Personal Information we have collected, the categories of sources, the purposes of processing, and the categories of third parties to which Personal Information has been disclosed.
- Portability. Obtain a copy of Personal Information you provided to us in a portable and, to the extent technically feasible, readily usable format.
- Correct. Request correction of inaccurate Personal Information, taking into account the nature of the information and the purposes of processing. Note that for credit report information furnished by consumer reporting agencies, disputes are handled under the FCRA, and we will direct you to the appropriate process.
- Delete. Request deletion of Personal Information, subject to exceptions — for example, we may retain information needed to complete a transaction, comply with legal obligations (including lending, AML, and record-retention requirements), detect and prevent fraud and security incidents, exercise or defend legal claims, and support internal uses compatible with your expectations.
- Opt out of "sales" and "sharing" / targeted advertising. Opt out of (i) the "sale" of Personal Information, (ii) the "sharing" of Personal Information for cross-context behavioral advertising (California), and (iii) the processing of Personal Information for targeted advertising (other states). We do not sell Personal Information for money; however, our use of third-party advertising cookies and pixels may constitute a "sale," "sharing," or targeted advertising under some state laws, and you may opt out as described below.
- Opt out of certain profiling. Opt out of profiling in furtherance of decisions that produce legal or similarly significant effects concerning you, where your state's law provides this right (see Section 7).
- Limit use of Sensitive Personal Information (California). California residents may request that we limit the use and disclosure of Sensitive Personal Information to the purposes permitted by the CCPA/CPRA. We collect Sensitive Personal Information — such as government identifiers and financial account information — to provide the Services, verify identity, prevent fraud, ensure security, and comply with law, which are permitted purposes under the CCPA/CPRA; we do not use Sensitive Personal Information to infer characteristics about you.
- Consent for sensitive data (other states). In states that require opt-in consent to process sensitive data outside of statutory exemptions, we obtain that consent where required.
- Non-discrimination. Not receive discriminatory treatment for exercising your rights. We will not deny you Services, charge you different prices, or provide a different level or quality of Services because you exercised a privacy right, except as permitted by law (for example, where the information is necessary to provide the Service).
19.2 How to Exercise Your Rights
You or your authorized agent may exercise these rights by:
To opt out of targeted advertising and any "sale" or "sharing" effected through cookies, you may also use our cookie preference controls where available and enable an opt-out preference signal such as the Global Privacy Control in your browser, which we honor as required by applicable law for the browser or device from which it is sent.
19.3 Verification
To protect your information, we must verify your identity before fulfilling access, correction, deletion, and similar requests. Verification may include matching information you provide against information we maintain, asking you to confirm control of an email address or telephone number on file, or, for portal users, requiring you to submit the request through your authenticated account. For requests involving particularly sensitive information, we may require additional verification. We will not require you to create an account to submit a request, but requests submitted through an existing account assist verification. If we cannot verify your identity to the degree of certainty required, we will tell you and explain what additional information, if any, would allow verification. Opt-out requests generally do not require verification, though we may ask for information necessary to locate your data or to confirm the request's authenticity if we suspect fraud.
19.4 Authorized Agents
Where your state's law permits, you may designate an authorized agent to submit requests on your behalf. We may require the agent to provide proof of your written authorization, require you to verify your own identity directly with us, or, for California requests, require a valid power of attorney. We may deny requests from agents who do not provide adequate proof of authorization.
19.5 Timing and Responses
We will respond to verifiable requests within the time required by your state's law — generally 45 days, with a permitted extension of an additional 45 days where reasonably necessary, in which case we will notify you of the extension. Opt-out requests are honored within the shorter periods state law requires. We will provide responses free of charge up to the frequency permitted by law; for manifestly unfounded, excessive, or repetitive requests, we may charge a reasonable fee or decline the request as permitted by law.
19.6 Appeals
If we decline to act on your request, residents of states that provide an appeal right (including Colorado, Virginia, Connecticut, Texas, Oregon, Delaware, New Jersey, Montana, Nebraska, Iowa, and Tennessee) may appeal our decision by replying to our response or contacting us at hello@slickviewcapital.com with the subject line "Privacy Appeal." We will respond to appeals within the period required by your state's law and explain our reasons. If your appeal is denied, you may contact your state Attorney General; we will provide a mechanism for doing so in our appeal response where required.
19.7 California-Specific Disclosures
For California residents, and as required by the CCPA/CPRA, we disclose the following with respect to the preceding 12 months:
- Categories collected. We have collected the categories of Personal Information described in Section 4, including identifiers; personal information categories listed in Cal. Civ. Code § 1798.80(e); commercial information; internet or other electronic network activity information; approximate geolocation data; audio and electronic information; professional or employment-related information; inferences; and Sensitive Personal Information (including government identifiers, financial account information, and, where applicable, biometric information processed for identity verification).
- Sources, purposes, and recipients. The categories of sources are described in Section 5; the business and commercial purposes are described in Section 6; and the categories of recipients are described in Section 10.
- "Sales" and "sharing." We do not sell Personal Information for money. Our use of third-party advertising cookies and pixels may constitute "sharing" (or a "sale" as broadly defined) of identifiers, internet activity, and commercial information with advertising partners. We do not knowingly sell or share the Personal Information of consumers under 16 years of age.
- Retention. Our retention criteria and practices are described in Section 14.
- Shine the Light. California Civil Code § 1798.83 permits California residents to request certain information regarding disclosure of personal information to third parties for their direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing purposes without consent.
19.8 Nevada
Nevada residents may direct us not to sell certain covered information as defined by Nevada law. We do not sell covered information within the meaning of Nevada law; Nevada residents may nonetheless submit a request to be treated as opted out by contacting us as described in Section 25.
19.9 Future State Laws
As additional state privacy laws take effect, we extend the rights and processes described in this Section to residents of those states as their laws require, without the need to amend this Policy for each new state, and we will update this Policy periodically to reflect material developments.
20. Rights of Individuals in the European Economic Area, United Kingdom, and Switzerland
The Services are designed for the U.S. market. However, if and to the extent the GDPR, the UK GDPR, or the Swiss Federal Act on Data Protection applies to our processing of your Personal Information, this Section applies, and Slickview Capital is the controller of that information unless otherwise stated.
20.1 Legal Bases for Processing
We process Personal Information under the following legal bases:
- Contract. Processing necessary to take steps at your request before entering into a contract and to perform our contract with you — for example, processing applications, verifying identity as part of onboarding, funding transactions, operating the portals, and servicing accounts.
- Legal obligation. Processing necessary to comply with our legal obligations — for example, AML/KYC, sanctions screening, tax, and record-retention requirements.
- Legitimate interests. Processing necessary for our legitimate interests or those of third parties, where not overridden by your interests and fundamental rights — for example, securing the Services, preventing fraud, managing risk, enforcing agreements, operating and improving our business, and conducting direct marketing to business contacts. You may request information about our balancing assessments by contacting us.
- Consent. Processing based on your consent — for example, certain marketing communications, non-essential cookies, and, where required, biometric verification. You may withdraw consent at any time, without affecting the lawfulness of processing before withdrawal.
- Legal claims and vital interests. Processing necessary to establish, exercise, or defend legal claims, or, in rare cases, to protect vital interests.
20.2 Your Rights
Subject to conditions and exceptions under applicable law, you have the right to:
- Access your Personal Information and receive information about our processing;
- Rectify inaccurate or incomplete Personal Information;
- Erase Personal Information in certain circumstances (the "right to be forgotten");
- Restrict processing in certain circumstances;
- Data portability — receive Personal Information you provided in a structured, commonly used, machine-readable format and transmit it to another controller where technically feasible;
- Object to processing based on legitimate interests, and object at any time to processing for direct marketing, in which case we will stop the marketing processing;
- Withdraw consent where processing is based on consent; and
- Not be subject to a decision based solely on automated processing, including profiling, that produces legal or similarly significant effects, except as permitted by law, in which case you have the right to obtain human intervention, express your point of view, and contest the decision.
To exercise these rights, contact us as described in Section 25. We will respond within one month, extendable by two further months for complex or numerous requests, in which case we will notify you.
20.3 Complaints
If you believe our processing violates applicable data protection law, you have the right to lodge a complaint with a supervisory authority, including in the EU member state of your habitual residence, place of work, or the place of the alleged infringement; with the UK Information Commissioner's Office; or with the Swiss Federal Data Protection and Information Commissioner. We would appreciate the opportunity to address your concerns first, and you may contact us at any time as described in Section 25.
21. Do Not Track Signals
Some browsers transmit "Do Not Track" ("DNT") signals. No uniform industry standard for responding to DNT signals has been adopted, and, like most companies, we do not respond to DNT signals at this time. We do, however, honor recognized opt-out preference signals, such as the Global Privacy Control, as described in Sections 11 and 19, and we will update our practices if a DNT standard is established that applicable law requires us to follow.
22. Artificial Intelligence
We use artificial intelligence and machine learning technologies to make the Services faster, safer, and more useful. Our current and anticipated uses include:
- Customer support assistance, such as drafting responses, routing inquiries, and summarizing conversations for our support team;
- Fraud detection, including pattern recognition across identity, device, document, and transaction signals;
- Document intake and organization, such as classifying uploaded documents, extracting data fields from contracts and statements, and flagging missing or inconsistent items;
- Underwriting support, such as organizing application files, surfacing relevant data for underwriters, and generating preliminary analyses; and
- Service improvement, such as analyzing usage patterns and support themes to improve the platform.
We maintain human oversight of AI-assisted processes where the law requires it and where decisions have significant effects on individuals, as described in Section 7. We evaluate AI tools and vendors for security, confidentiality, and data handling before use, and we contractually restrict our AI service providers from using your Personal Information to train their generally available models except as permitted by our agreements and applicable law. Where Applicable Privacy Laws grant rights regarding automated decision-making or profiling, Sections 7, 19, and 20 describe those rights and how to exercise them.
23. Business Transfers
If Slickview Capital or any of its assets, business lines, or portfolios are involved in an actual or contemplated merger, acquisition, consolidation, reorganization, financing, securitization, loan sale or participation, joint venture, bankruptcy, receivership, dissolution, or other corporate transaction, information described in this Policy may be reviewed by counterparties and their advisors under confidentiality obligations and may be transferred to a successor, acquirer, or assignee as one of the transferred assets. Any successor's use of Personal Information remains subject to this Policy as it existed at the time of transfer, unless and until the successor provides notice of changes consistent with Section 24 and applicable law. Where applicable law requires notice or choices in connection with such a transfer, we will provide them.
24. Changes to This Privacy Policy
We may update this Policy from time to time to reflect changes in our practices, the Services, technology, or applicable law. When we make changes, we will revise the "Last Updated" date above and post the updated Policy on the Site. If we make material changes, we will provide more prominent notice — such as a notice on the Site, an email to the address on file, or a notification in the portals — and, where applicable law requires, we will obtain your consent before applying material changes to previously collected Personal Information. We encourage you to review this Policy periodically. Your continued use of the Site or Services after an updated Policy takes effect constitutes your acknowledgment of the updated Policy to the extent permitted by law.
If you have questions or concerns about this Policy or our privacy practices, or if you wish to exercise your privacy rights, please contact us:
Slickview Capital
Attn: Privacy Office
9633 Old St Augustine Rd
Jacksonville, FL 32257
Email: hello@slickviewcapital.com
Phone: (347) 450-7071
Website: https://slickviewcapital.com
If you are submitting a privacy rights request, please include your name, the state or country of your residence, the right you wish to exercise, and sufficient information for us to locate your records and verify your identity as described in Sections 19 and 20. If you have an unresolved privacy concern that we have not addressed satisfactorily, you may contact your state Attorney General or, where applicable, the supervisory authorities described in Section 20.3.