4D FINANCING PRIVACY POLICY

Effective Date: 06/01/2025

A. Introduction

4D Financing LLC, together with its subsidiaries, affiliates, and any entities doing business under the 4D Financing name (collectively, "Company," "we," "our," or "us") respects the privacy of your information and is committed to safeguarding it. This Privacy Policy ("Policy") is intended to help you, any natural person acting on behalf of a U.S. business (collectively, "you" or "your"), understand what information we collect, why we collect it, how we use it, with whom we share it, and what choices you have regarding your information.

This Policy applies to visitors to and users of our website located at 4DFinancing.com, any of our other sites, sub‑sites or interfaces that links to this Policy (collectively, the "Sites"), as well as the products and services we provide, including our pre‑application form, merchant application for financing, merchant portal, customer service channels, and brokering activities (collectively, the "Services"). Please also review our Terms of Use, which govern your use of the Sites and Services and are expressly incorporated herein.

By accessing the Sites or using our Services you: (i) acknowledge that you have read and understood this Policy; (ii) represent that you are at least 18 years of age and acting on behalf of a bona‑fide U.S. business; and (iii) consent to the collection, use, processing, and disclosure of your information in accordance with this Policy. If you do not agree with any part of this Policy, do not use the Sites or Services.

We may modify this Policy at any time at our sole discretion. If we make any material updates to this Policy, we will give notice as required by applicable law and post the revised version on this page; unless otherwise indicated, the update will take effect immediately upon posting. The "Effective Date" above reflects when this version was last issued.

We provide commercial financing only. Because we do not extend credit to natural persons for personal, family, or household purposes, many federal and state consumer privacy laws do not directly apply to our Services. Nevertheless, we strive to follow leading privacy practices and give you clear choices about your information.

How to Contact Us

If you have any questions, concerns, or complaints regarding this Policy or our privacy practices, please contact us:

Email: privacy@4dfinancing.com

Phone: +1 (434) 303-4334

Mail:

4D Financing

Attention: Privacy

117 NE 1st Ave

9th Floor #1027

Miami, FL 33132

B. Information We Collect

Information You Provide Us Directly

In connection with our Services, we collect information you provide directly, such as your business and contact details, financial data, and application materials, and additional data from third‑party sources. This may include:

Basic user identifiers. Your name, email, phone number, address, and unique account information.

Business Details. Business name, structure, industry classification, years in operation, and revenue ranges.

Financial Data. EIN, bank account and routing numbers, bank statements, details of existing MCA or loan obligations, average balances, and related financial statements.

Beneficial Ownership Info. Owners’ names, dates of birth, Social Security numbers, ownership percentages, and government‑issued IDs.

Supplemental Materials. Documents you upload (e.g., PDFs, images) and any co‑applicant or guarantor information you provide.

Communications & Support Interactions. Information you provide during live chat sessions, emails, and other support channels, including message content, transcripts, and related metadata.

We collect this information to meet legal and regulatory obligations, verify identities, evaluate financing eligibility, prevent fraud, process your application effectively, and service your account.

Information From Third Parties

When you apply for financing, we may obtain additional information about you or your business from third‑party sources to support your application and our ongoing relationship. These sources include credit reporting agencies; identity verification and fraud detection services; government registries and public records; and business or broker partners (such as loan brokers and lead generation partners). Typical data we receive may include but is not limited to:

Identifiers and contact details. Your name, email, phone number, address, date of birth, and account identifiers.

Business registrations. Legal business name, website, company phone number, structure, industry classification, date of incorporation, and ownership information.

Public records and filings. UCC filings, liens, judgments, litigation history, and other government or regulatory records.

Financial metrics. Commercial credit history or scores, payment performance, bank transaction summaries, and other financial statements.

Trade and vendor references. Information provided by vendors or business partners regarding your performance and relationships.

We use this third‑party data to verify identities, determine financing eligibility, underwrite your application, assess ongoing risk, prevent fraud, and improve decision‑making throughout our relationship. 

We do not obtain personal credit reports or consumer credit scores from consumer reporting agencies. Should this practice change, we will update this Policy.

Information Collected From Activity on the Sites

We use technologies to understand how you interact with our Sites and Services, maintain security, detect fraud, and optimize performance, including but not limited to:

Usage and interaction data. Pages you visit, buttons clicked, forms submitted, session duration, and navigation paths.

Device and system information. Your IP address (including approximate geolocation), referral source, browser type and version, operating system, device identifiers, screen resolution, and connection details.

Cookies and similar tools. Cookies, HTML5 local storage, web beacons, pixels, tags, and scripts to recognize you on return visits, authenticate sessions, store preferences, and measure and improve advertising effectiveness.

You may manage or disable cookies and related tracking technologies via your browser or device settings. However, certain features of the Sites and Services, such as keeping you logged in or saving your application progress, may not function properly if you block these technologies.

C. How We Use Your Information

We use the information described above for the following business purposes, and for any compatible purpose that is disclosed to you at the time of collection or otherwise permitted by law:

1. Process and qualify your business' application, generate conditional offer ranges, verify identities, perform due diligence, confirm beneficial ownership, and analyze the risk and eligibility of your business.
2. Facilitate account servicing and collections, draft and transmit merchant agreements, fund accounts, process automatic ACH debits, and handle renewals.
3. Operate, maintain, and enhance the Services for you, and to conduct our business operations, including offering our products to you and referring you to third-party financing partners;
4. Provide customer support, respond to inquiries, provide status updates, send legally‑required notices, and deliver customer support.
5. Send marketing communications, newsletters, promotions, and offers that may interest you.
6. Monitor the Sites performance, debug issues, conduct surveys, develop new features, and improve credit models using aggregated or de‑identified data.
7. Detect, investigate, and mitigate fraudulent or malicious activity; enforce our Terms of Use; protect the security and integrity of the Sites, our business, and our customers, and otherwise defend our legal rights.
8. Satisfy legal, compliance, and other record-keeping obligations; respond to lawful requests and legal process, defend or exercise legal claims, and comply with applicable laws and regulations.
9. Solicit, review, and share your feedback; conduct tests, research, and analyses to better understand and serve you; and communicate any updates or changes to our Sites and Services.

D. How We Disclose Your Information

We may disclose the categories of information listed in Section B to the following parties for the purposes described:

Affiliates and funding partners. Internal staff, subsidiaries, parent companies, and finance partners that co‑originate, service, or manage financing contracts under the Company brand.

Service providers. Third‑party vendors acting under contract to operate our business and Services, including cloud hosting, CRM platforms, e‑signature and document storage, payment processors, email/SMS delivery, analytics, fraud‑screening, call‑recording, customer support, and marketing services.

Other commercial finance providers. With your explicit consent, we may share your complete application package, including business details, ownership information, and financial records, with selected lenders, banks, investors, factoring companies, or other financing partners to solicit competing offers on your behalf.

Co‑applicants and guarantors. Business owners, authorized agents, or assignees named on the same application; we share relevant application data among co‑applicants or guarantors to facilitate joint or backstop funding arrangements.

Credit and trade reporting agencies. Commercial credit bureaus and trade‑reporting services if and when we elect to report payment performance, account status, or other credit metrics (this is not performed by default).

Legal and regulatory authorities. Courts, regulators, auditors, taxation authorities, and law enforcement when disclosure is required or appropriate to comply with legal obligations, respond to subpoenas or court orders, defend legal claims, or protect the rights and safety of the Company and its customers.

Corporate transaction parties. Prospective buyers, investors, advisors, or acquirers in connection with any merger, acquisition, financing transaction, equity sale, asset sale, bankruptcy, or reorganization involving the Company.

Your consent. Any other third party when you direct or explicitly authorize us to share your information, such as public testimonial platforms or preferred service partners

We may also use or disclose your Personal Information for any additional purposes we notify you of at the time of collection, or as otherwise necessary to protect the health, safety, or legal rights of individuals.

No sale of personal information. We do not sell or rent your personal information to third parties for their own marketing purposes, nor do we share it for cross‑context behavioral advertising under the CPRA.

SMS opt‑in data. Text messaging originator opt‑in data and consent are not shared with any third parties except to facilitate messaging you have authorized.

E. Your Privacy Choices & Rights

Although we operate exclusively in the business‑to‑business space, we provide several ways for authorized representatives to exercise control over their information:

Access and correction. Email us at privacy@4dfinancing.com to request a copy of the information associated with your account or to correct inaccuracies.

Marketing opt‑out. Click the “unsubscribe” link in a marketing email, reply “STOP” to a marketing SMS, adjust preferences in the portal, or email us at privacy@4dfinancing.com. Opting out will not affect transactional communications.

Do‑Not‑Call. To be added to our internal do‑not‑call list for marketing voice calls, email us at privacy@4dfinancing.com. Opting out will not affect transactional communications.

Testimonials and public posts. If you wish to update or remove a testimonial or comment displayed on our Sites or social media, contact us and we will accommodate where feasible.

State‑law requests. If you believe you have rights under a specific U.S. privacy statute, please email us at privacy@4dfinancing.com and we will respond as required by that law.

F. Security

We implement robust administrative, technical, and physical safeguards to secure your information against accidental or unlawful loss, misuse, unauthorized access, disclosure, alteration, and destruction. These protections include encrypting data in transit and at rest, enforcing strict physical security at our data facilities, deploying network firewalls and intrusion detection systems, and applying role‑based access controls with periodic security reviews.

As a prerequisite to accessing or using the Sites, you agree not to:

1. Access or retrieve any data or content for which you lack authorization;
2. Invade the privacy of, identify, or collect personal information about other users;
3. Probe, scan, or test the security or authentication measures of the Sites or our networks without prior authorization;
4. Disrupt or degrade the operation of the Sites, servers, or networks by introducing malicious software, generating excessive traffic, spamming, flooding, mail bombing, or other denial-of-service tactics; or
5. Send unsolicited communications, including promotional or advertising messages, without the recipient’s consent.

Any unauthorized or malicious activity may violate applicable laws and expose you to civil or criminal penalties.

G. Accessibility

This Policy is designed to be accessible to individuals with disabilities, and we are committed to ensuring this Policy follows the Web Content Accessibility Guidelines. To receive this Policy in an alternative format, please contact us as described in the How to Contact Us section.

H. Children’s Privacy

The Sites and Services are directed only to adults acting on behalf of U.S. businesses. We do not knowingly collect personal information from anyone under the age of 18. If we become aware that we have inadvertently received such information, we will delete it from our records. Parents or guardians who believe their child has provided us information may contact us at privacy@4dfinancing.com.

I. Third‑Party Websites & Links

The Sites may contain links to websites or services operated by third parties ("Third‑Party Sites"). We do not control, endorse, or assume responsibility for the privacy practices of Third‑Party Sites. Any information you provide to or collected by Third‑Party Sites is governed by their respective privacy notices, which we encourage you to review.

J. International Use

We market and provide Services exclusively to businesses located in the United States. Our servers and service providers are located in the United States. If you access the Sites from outside the United States, you understand that your information will be transferred to, stored, and processed in the United States, where privacy laws may be less stringent than those in your country of residence.

K. Notice to Residents of California 

Under the California Consumer Privacy Act and the California Privacy Rights Act (together, the "CCPA/CPRA"), California residents have the right to receive certain information at or before the point of collection of their personal information. Capitalized terms not defined here have the meanings given elsewhere in the Privacy Policy.

This section applies only to natural persons who are California residents.

We do not “sell” personal information and we do not “share” it for cross-context behavioral advertising as those terms are defined by the CCPA/CPRA.

1. Notice at Collection of Personal Information

Through use of the Sites and Services, we currently collect, and may have collected in the last 12 months, the following categories of personal information about California residents who are website visitors, users, and businesses:

Identifiers. Legal name, postal address, email, telephone, IP address, device identifiers, cookies, social security number (SSN), driver’s-license or passport number, signature

Customer Records. Bank-account and routing numbers, bank account and credit-card statements, tax ID, account credentials, financial-statement data,

Commercial Information. Products or services purchased, considered, or financed; payment and transaction history; revenue trends

Internet / Electronic Activity. Browsing and search history within our sites or apps; clickstream data; interaction with ads or emails

Geolocation. Approximate or precise location derived from devices or IP addresses

Professional / Employment. Job title, employer, income, employment history

Sensory Data. Call recordings, voicemail, chat transcripts

Protected Classifications. Age (40+), or other legally protected traits voluntarily provided

Inferences. Profiles reflecting preferences, behavior, creditworthiness, or similar characteristics

We obtain this information (i) directly from you, (ii) automatically from your devices, and (iii) from third-party sources such as referral partners, brokers, credit bureaus, fraud-prevention vendors, and analytics providers.

2. Use of Personal Information

We use personal information for the following business or commercial purposes, each of which is reasonably necessary and proportionate to our relationship with you:

Account and financing operations. Evaluate eligibility, underwrite, provide, service, and collect on MCA or similar financing.

Customer support and communications. Respond to inquiries, send transactional notices, and provide requested materials.

Security and fraud prevention. Detect, investigate, and mitigate fraud, spam, malware, or other unlawful activities.

Analytics and product improvement. Debug, enhance, test, and improve our websites, applications, and services.

Regulatory and legal compliance. Satisfy audit, tax, reporting, and record-retention obligations; respond to lawful requests.

3. Disclosure of Personal Information

We disclose Personal Information only for the purposes above and only to the categories of recipients below:

Service Providers & Contractors. Cloud hosting, customer-support platforms, payment processors, document-storage vendors, analytics tools

Financial Institutions. Banks, ACH networks, card networks, and insurers that facilitate funding and repayment

Credit & Fraud Agencies. Credit bureaus, identity-verification and anti-fraud vendors

Professional Advisors. Law firms, auditors, accountants, and consultants under confidentiality duties

Government & Regulators. As required by subpoenas, court orders, or supervisory examinations

We contractually prohibit these recipients from using Personal Information for their own purposes and require them to keep it confidential.

Shine the Light Law Disclosure: We do not disclose Personal Information obtained through our Sites or our Services to third parties for their own direct-marketing purposes.

4. Sensitive Personal Information

We do not use or disclose Sensitive Personal Information (e.g., SSN, driver’s-license number, precise geolocation) for any purpose other than those expressly permitted by Cal. Civ. Code § 1798.121(a); therefore, the right to limit does not apply.

5. Retention

We retain each category of Personal Information for the longer of (i) the life of the customer relationship plus seven (7) years or (ii) any period required by applicable law, regulation, contractual obligation, or internal policy.

6. Your CCPA/CPRA Rights

California residents have the rights to:

1. Right to Know / Access. California residents may request the categories and specific pieces of Personal Information we collected, the sources of that information, the business or commercial purposes for the collection or disclosure, and the categories of third parties to whom we disclosed it in the preceding 12 months.
2. Right to Delete. California residents may request that we delete Personal Information we collected from you, subject to statutory exceptions (e.g., to comply with law, complete a transaction, detect fraud).
3. Right to Correct. California residents may request that we correct inaccurate Personal Information we maintain about you.
4. Right to Opt-Out of Sale or Sharing. California residents may direct us not to sell or share your Personal Information. We do not sell or share Personal Information as those terms are defined by the CCPA/CPRA, but you may still submit an opt-out request for confirmation.
5. Right to Limit Use of Sensitive Personal Information. If we ever use or disclose Sensitive Personal Information for purposes outside those permitted by law, California residents may may limit such use and disclosure. Please note that we use Sensitive Personal Information only for permissible purposes.
6. Right to Non-Discrimination. California residents will not receive discriminatory treatment for exercising any privacy right (e.g., denial of services, different pricing, or lower quality). Please note that we do not discriminate against any user of our site, irrespective of residency.

As permitted by the CCPA/CPRA, we may offer certain financial incentives that can result in different rates, prices, or service offerings. These financial incentives may include gift cards, credits, and other monetary consideration; if applicable, terms will be provided to you at the time of offering. Participation in an incentive program is voluntary and requires your consent, which you may revoke at any time.

7. Submitting a Request

How to submit a request.

You may submit a request by email to privacy@4dfinancing.com, or by mail to the address listed in the How to Contact Us section above. Please describe your request in sufficient detail and provide information we can match to our records, such as your name, business name, last four digits of SSN or Tax ID, and recent transaction details, to validate and authenticate your request.

How requests are verified.

For non-sensitive or category-level requests, we seek a reasonable degree of certainty by matching your provided verification information to at least two reliable data points we have previously collected from you.

For requests involving sensitive data or specific-piece disclosures, we require a reasonably high degree of certainty, by matching your provided verification information to at least three data points we have previously collected from you, plus a signed declaration under penalty of perjury.

We will respond within 45 days notifying you (i) if we were able to successfully verify your request, (ii) if we require additional information to validate your request, or (iii) if we require additional time to respond to your request.

Authorized agents.
You may designate an agent registered with the California Secretary of State to act on your behalf. The agent must provide (i) written permission signed by you, or (ii) a valid power of attorney, and proof of their own identity. We may contact you directly to verify authorization.