Privacy Policy

Introduction. CAPITAL CONNECTIONS USA, LLC, CAPITAL CONNECTIONS USA ("CAPITAL CONNECTIONS USA", "our", "us" or "we") takes steps intended to meet privacy principles and requirements under applicable privacy legislation with respect to personal information. Personal information is information about an identifiable individual, as more particularly described under applicable privacy legislation. The purpose of this Privacy Policy is to inform our registered users and other individuals we deal with ("you" or "you're" or "your",) how we collect, use, disclose and protect personal information. This Privacy Policy does not apply to information about our employees or to information that is not personal information.

Personal Information We Collect. CAPITAL CONNECTIONS USA and its agents and representatives collect personal information about you from CAPITAL CONNECTIONS USA's sources (including, without limitation, from credit reporting agencies, creditors, and businesses and financial institutions with which you have had a financial relationship) and in a number of circumstances in the course of the retail lending services we provide on the CAPITAL CONNECTIONS USA loan marketplace (the "loan marketplace"). Personal information we collect includes, without limitation:

• Your name, address, e-mail address, Internet Protocol address, telephone number, and other contact information; • your business name, address, tax id number, business inception date, business bank statements, telephone number and address; • financial information, such as your bank name and your bank account number, credit bureau reports concerning you, credit reports prepared by personal information agents, and other reports concerning your credit history and experience; • other financial or personal information about you, such as your percent ownership in the business, your liabilities, and your financial condition; • your social security number; • information that we may compile in connection with your activity on the loan marketplace, such as transaction or usage history and statistic log information or community discussions; and • such other information we may collect with your consent or as permitted or required by applicable law. Use of Personal Information. We generally use personal information for the following purposes: • to verify your identity in connection with our new user registration process; • to manage and administer your account with CAPITAL CONNECTIONS USA; • to facilitate the transactional process between financial institutions and between us and our registered users; • if you are a registered business, to determine your credit grade, suggested interest rate and maximum loan amount; • to prevent fraud, identity theft or illegal activities; • to maintain our business records for reasonable periods and to generally manage and administer our business; and • to meet legal, regulatory, insurance, audit, processing and security requirements imposed on us, which may include establishing and verifying your identity and checking your identity against money laundering, terrorist financing or similar watch lists established by regulatory agencies or similar bodies in the United States. We may also use your personal information in other manners with your consent or as permitted or required by applicable law.

We reserve the right to disclose your personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served on our Web site.

Disclosure of Your Personal Information. We may disclose your personal information to our affiliates for internal audit, management, billing or administrative purposes. In addition, we may disclose your personal information in the following circumstances:

Service Providers. We may disclose personal information to outside agents, representatives and service providers (including affiliates of CAPITAL CONNECTIONS USA acting in this capacity) that perform services on our behalf, such as website systems operators, credit reporting agencies, banks and collection agencies, or otherwise to collect, use, disclose, store or process personal information on our behalf for the purposes described in this Privacy Policy. We take reasonable steps to ensure that personal information we disclose to these outside agents, representatives and service providers is protected and not used or further disclosed for purposes other than as directed by us or as required by applicable law.

Legal, Regulatory, Etc. We may disclose your personal information as necessary to meet applicable legal, regulatory, industry self-regulatory, insurance, audit and security requirements and obligations, including as required by our outside agents, representatives and service providers.

Business Transactions. Personal information may be used by us and disclosed to third parties in connection with certain business transactions, including, without limitation, in connection with a proposed or actual financing of CAPITAL CONNECTIONS USA or a sale, assignment or other disposed of all or part of our business or assets. In that case, personal information may be disclosed to third parties for the purpose of, among others, evaluating and consummating the proposed transaction, or fulfilling reporting, due diligence, inspection or audit requirements or obligations to those parties. Assignees or successors of CAPITAL CONNECTIONS USA or any part of our business or assets may use and disclose your personal information for similar purposes as those described in this Privacy Policy.

General. We may otherwise disclose your personal information with your consent or as permitted or required by applicable law.

Disclosure of Certain Credit Data and Registered Borrower Loan Status Information. If you elect to register as a borrower on the loan marketplace and successfully complete our underwriting process, you will be eligible to make a posting on the loan marketplace for a registered borrower loan. Your posting will be displayed publicly on the loan marketplace, although certain information is only viewable by registered lenders. However, your posting will appear under your CAPITAL CONNECTIONS USA screen name and not your real name, and you are not permitted to use your real name or other personally identifiable information in your posting. In order to protect your privacy, you should choose CAPITAL CONNECTIONS USA screen name that does not closely resemble your real business or personal name.

Information in your posting that will be displayed publicly on the loan marketplace includes the following:

• Your requested loan amount and loan term; • your credit grade; • your suggested interest rate and annual percentage rate for the loan; • your self-reported intended use of proceeds; • your business's average monthly income; • your business type; • the number of registered lenders who have placed bids to purchase Business Payment Dependent Notes ("Notes") that are dependent for payment on payments we receive on your registered business loan; and • total funding that has been committed by registered lenders to purchase Notes that are dependent for payment on payments we receive on your registered business loan. Information in your posting that will be displayed only to registered lenders includes the following credit history information from your credit report that we will obtain from a consumer reporting agency: • your earliest credit line; • your number of open credit lines; • your total number of credit lines; • your revolving credit balance; • your revolving line utilization; • the number of credit inquiries received by the consumer reporting agency within the past three months; • the number of reported delinquencies in the past two years; • the length of time (in months) since your last reported delinquency; • the number of 30, 60 and 90+ days’ past due delinquencies in the credit file in the last 24 months. If your registered business loan is closed and funded, we will display your registered business loan status information for registered lenders who purchased Notes that are dependent for payment on payments we receive on your registered business loan. We will notify such registered lenders when you become one-day delinquent in a loan payment on your registered business loan.

The Internet and Our Website. We operate and control the loan marketplace through our website at www.CAPITALCONNECTIONSUSA.com

Cookies. We may use “cookie” files to enhance the use of our website and the loan marketplace for our registered users and other users. A "cookie" is a small text file placed on a computer’s hard drive by our web page server in order to recognize that a user has previously visited our website and to apply the configuration preferences that the user has chosen. Other than the information provided by a user, cookie files do not contain information that can be used to identify an individual user. You can disable cookies using your Internet browser’s settings and you should consult your browser’s help function for information on how to disable cookies. Please note that if you disable cookies, certain features of our website may not function properly. We do not require anyone to accept cookies in order to use our website or the loan marketplace.

Third Party Cookies. The use of cookies by our tracking utility company and service providers is not covered by our privacy statement. We do not have access or control over these cookies. Our tracking utility company and service providers use session ID cookies to make it easier for you to view your business address, and provide us with usage tracking for the platform.

E-mail Policy. Once you complete new user registration and your CAPITAL CONNECTIONS USA account is created, we will use your e-mail address to contact you regarding your CAPITAL CONNECTIONS USA account and transactions you engage in on the loan marketplace. We will also use your email address to contact you for other registered user service and support purposes. In addition, we will use your e-mail address to answer your e-mail and registered user service and support inquiries and requests. In order to provide consistent and high-quality registered user service and support, we may store any correspondence with you in a file specific to you. Furthermore, we will use your e-mail address to provide you with e-mail updates regarding changes to our Privacy Policy and changes or enhancements to the loan marketplace.

No Third-Party Marketers. We do not sell, rent or trade your personal information to third parties or marketing firms for their promotional purposes. We do send communications periodically to inform you of the status of transactions or events related to your CAPITAL CONNECTIONS USA account and your use of our website and the loan marketplace. Some of these communications are required in connection with transactions you are considering or have concluded through the loan marketplace.

You’re Consent. Your consent to the collection, use, and disclosure of personal information may be given in various ways. Your consent can be express (e.g., orally, electronically or on a form you may sign describing the intended uses and disclosures of personal information) or implied (e.g., when you provide information necessary for a service or transaction you have requested). In certain circumstances, you may provide your consent where notice has been provided to you regarding our intended use of your personal information and you have not withdrawn your consent for the intended use (e.g., when you do not elect an "opt-out" option). Your consent may also be given by your authorized representative, such as your legal guardian or a person having a power of attorney.

Generally, by providing us with your personal information, we will assume that you consent to our collection, use and disclosure of such information for the purposes identified or described in this Privacy Policy, if applicable, or otherwise at the time of collection.

You may withdraw your consent to our collection, use and disclosure of personal information at any time, subject to contractual and legal restrictions and reasonable notice. Please note that if you withdraw your consent to certain uses of your personal information, we may no longer be able to provide certain of our services and you may not be eligible to participate in the loan marketplace as a registered user. In addition, please note that where we have provided (or are providing) services to you, your consent will be valid for so long as necessary to fulfill the purposes described in this Privacy Policy or otherwise at the time of collection, and you may not be permitted to withdraw consent to certain necessary uses and disclosures (e.g., maintaining reasonable business and transaction records and reporting on credit information after credit has been granted, if applicable).

We collect, use and disclose your personal information with your consent, except as permitted or required by applicable law. We may be required or permitted under certain statutes or regulations to collect, use or disclose personal information without your consent, including, without limitation, to comply with a court order, local or federal regulations or a legally permitted inquiry by a government or law enforcement agency, or to collect a debt owed to us, our agents, representatives and service providers, or another registered user.

Security. We take reasonable steps to protect your personal information using physical, electronic or procedural security measures appropriate to the sensitivity of the information in our custody or control, which may include secure web pages, encryption, password intrusion detection systems and firewalls as described below:

Secure Web Pages. All of the pages on our website that ask for your personal information are transferred to your browser through HTTPS, a secure server communications protocol. You can verify this encryption by checking for the key (Netscape) or lock (Internet Explorer) icon on your browser. If your browser’s security feature has been turned on, a pop up box will notify you when you enter a secure page.

Encryption. When you send your personal information to us, it is protected by SSL (Secure Sockets Layer) Technology. SSL does not allow anyone to read your personal information. When you transmit your information to us, SSL encrypts it (translates the data into a string of gibberish characters) and only we can decode the encryption.

Firewall Protection. Your financial information is encrypted and backed up every day. In the unlikely event that our website is "hacked", your data will remain secure.

Password Protection. To retrieve information about your status as a registered user on the loan marketplace and your transactions, you are required to enter both a password and your user name.

These safeguards are used to protect against loss or theft, as well as unauthorized access, disclosure, copying, use or modification of your personal information. In addition to the security features, we have implemented in our systems, the security of your personal information relies on you safeguarding your password. Accordingly, you may not share your password with anyone.

Our authorized employees, agents, and parties to a contract of work or services with us who require access to your personal information in order to fulfill their job requirements or contracts will have access to your personal information.

Access, Correction and Contacting Us. You can access, delete or review the personal information you submit to us at any time through your CAPITAL CONNECTIONS USA account. To make changes to your personal profile information, log in to your CAPITAL CONNECTIONS USA account using your username and password. Click on "My Info" in the "My Profile" section and make changes to your profile as necessary.

We may establish and maintain a file of your personal information for the purposes described in this Privacy Policy, which will be accessible by you at our operational offices. You may request access to your file or correction of any inaccuracies in your personal information in our possession, or held by the personal information agent who prepared a credit report on you. Your right to access or correct your personal information is subject to applicable legal restrictions. If you wish to request access or correction of your file, or to make inquiries or complaints or have other concerns about our personal information practices, you may e-mail us via our Contact Us page or write to us at the above address, Attention: Privacy Department.

Data Retention. We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services, contact us at Contact Us. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Note Regarding Children Under 18. Users of our website and loan marketplace must be U.S. residents that are 18 years of age or older. Additional requirements apply to registered users.

Helpful Tips on Protecting Your Personal Information. Set forth below are several tips intended to help you protect your personal information:

CAPITAL CONNECTIONS USA Screen Name. Your CAPITAL CONNECTIONS USA screen name is what users of our website and loan marketplace use to identify you. In order to protect your privacy, you should choose a screen name that does not closely resemble your real name.

Password Protection. It is a good practice to select a password for your CAPITAL CONNECTIONS USA account that is a unique combination of letters, numbers, and symbols. Your password should not be predictable or easy to guess. A good practice is to change your password periodically, such as every 90 days.

Discussion Forums. If you use the Discussion Forums on our website, you should be aware that any personally identifiable information you submit on a Discussion Forum can be read, collected, or used by other users of the Discussion Forum, and could be used to send you unsolicited messages. We do not monitor or mask personally identifiable information that may appear on the Discussion Forums, so if you choose to put personal information on a Discussion Forum you do so at your own risk.

Identity Theft. If you think your identity has been stolen, contact all three credit-reporting agencies listed below to put a fraud alert on your credit report:

• TransUnion (www.transunion.com) Phone: 1-800-680-7289 E-mail: fvad@transunion.com Mail: TransUnion P.O. Box 6790 Fullerton, CA 92834 • Equifax (www.equifax.com) Phone: 1-888-766-0008 E-mail: fraudalerts.equifax.com Mail: Equifax Credit Information Services, Inc P.O. Box 740241 Atlanta, GA 30374 • Experian (www.experian.com) Phone: 1-888-397-3742

After you contact all three credit reporting agencies, you should check your credit report again in 30 to 60 days for any new signs of identity theft or records that still need to be removed. You should also file a police report with your local enforcement agency. A police report is helpful when dealing with creditors as you challenge inquiries to your credit report or accounts opened fraudulently in your name. You should also keep records of all actions you have taken and letters you have written regarding your identity theft.

Customer Testimonials/Comments/Reviews. We post customer testimonials/comments/reviews on our website which may contain personally identifiable information. We do obtain the customer's consent via email prior to posting the testimonial to post their name along with the testimonial. To request removal of your personal information from Testimonials or comments please contact us at Contact Us.

Blogs. If you use a bulletin board, chat room, blog or forum on this Web site, you should be aware that any personally identifiable information you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit in these forums.

Changes in this Privacy Statement. We may update this privacy policy to reflect changes to our information practices. If we make any change in how we use your personal information we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

CAPITAL CONNECTIONS USA has been awarded TRUSTe's Privacy Seal signifying that this privacy policy and practices have been reviewed by TRUSTe for compliance with TRUSTe's program requirements including transparency, accountability, and choice regarding the collection and use of your personal information. The TRUSTe program covers information collected through this Web site, www.businessgrowthcapital.com. TRUSTe's mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy Trustmark and innovative trust solutions. If you have questions or complaints regarding our privacy policy or practices, please contact us. If you are not satisfied with our response you can contact TRUSTe here.

If you have questions or concerns regarding this statement, you should first contact CAPITAL CONNECTIONS USA and submit your questions or concerns to CAPITAL CONNECTIONS USA. You can also send written questions or comments to us at

INFO@CAPITALCONNECTIONSUSA.COM

Attention: Privacy Department. If you do not receive acknowledgment of your inquiry or your inquiry has not been satisfactorily addressed, you should contact TRUSTe at http://watchdog.truste.com/pvr.php?page=complaint&url=. TRUSTe will then serve as a liaison with us to resolve your concerns.