Portal Privacy Policy

1. Information we collect

Information you provide to us

• Account & investor profile: login email, name, mailing address, phone number, and correspondence details for each investor entity you hold.
• Investment information: the notes you participate in, amounts, funding method and reference details (such as a wire reference or check number), and related documents such as loan agreements and acknowledgment letters.
• Beneficiary information you choose to provide: beneficiary names, relationship, date of birth, the last four digits of a Social Security number, address, and phone number.
• Tax & identity documents you upload or that we prepare for you.

Information we collect automatically

• Log and device data, including IP address, browser and device information, pages viewed, and timestamps.
• Cookies used to authenticate you and keep you signed in; disabling these may prevent you from using the Portal.

Payment & funding information. Investment funding is generally handled by wire transfer or check outside of the Portal. We record funding references (such as a wire reference or check number) but do not collect full bank account numbers through the Portal.

2. Why we collect it and how we use it

• Provide, operate, and secure the Portal and your account
• Administer your note participations and funding
• Communicate with you about your account, investments, and requests
• Prepare and deliver documents (e.g., loan agreements, acknowledgment letters, tax forms)
• Comply with legal, regulatory, tax, and recordkeeping obligations
• Detect, prevent, and address fraud, security, and technical issues

We do not sell or rent your personal information.

3. How we share your information

We share personal information only as needed to operate the Portal:

• Service providers who process data on our behalf under contract, including our database provider (Supabase), our application hosting provider (Vercel), and our customer-relationship and messaging provider (GoHighLevel / LeadConnector) used to send communications.
• Professional advisors such as accountants, auditors, and legal counsel.
• Legal & regulatory disclosures when required by law, regulation, or legal process, or to protect rights, safety, and property.
• Business transfers in connection with a merger, financing, acquisition, or sale of assets.

We do not sell or rent your personal information to third parties.

4. How long we keep it

We retain personal information for as long as your account is active and as needed to provide the Portal. Because we operate in a financial and lending context, we also retain certain records for longer periods to comply with legal, tax, regulatory, and recordkeeping requirements, and to resolve disputes and enforce agreements. When information is no longer needed, we delete or de-identify it.

5. Accessing, correcting, or deleting your information

You can update much of your profile directly within the Portal. To request access, correction, or deletion of your personal information, contact us at info@kindling.network. We will respond consistent with applicable law. Please note we may need to retain certain information to meet legal, tax, or regulatory obligations even after a deletion request.

Depending on where you live, you may have additional rights — for example, to request a copy of your data, to restrict or object to certain processing, or to lodge a complaint with a regulator.

6. Data security

We use administrative, technical, and physical safeguards designed to protect your information, including access controls and encryption in transit. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

7. Children's privacy

The Portal is intended for adults (18+). We do not knowingly collect personal information from children.

8. Changes to this policy

We may update this Privacy Policy from time to time. We’ll post the updated version here and revise the “Last updated” date at the top.

9. Contact us

Questions or requests about this Privacy Policy or your personal information? Contact us at:

Kindling
Email: info@kindling.network
[Mailing address]