Privacy Policy

Last updated: 2026-09-13 Version: 2.0

Who we are

Fugio Funding Network, LLC ("Fugio," "we," "us") is a business capital strategy and funding brokerage firm. We help small businesses find and obtain financing from a network of lender partners. This Privacy Policy explains what information we collect through our client portal and how we use it.

If you have questions, contact us at privacy@fugiofundingnetwork.com.

Information we collect

When you use our portal, we collect:

• Identity & contact info: name, email address, phone number,

business name and address.

• Business information: legal entity, formation date, industry,

state of operation, ownership structure.

• Financial information: monthly revenue, annual revenue,

bank statements, profit-and-loss statements, balance sheets, outstanding debts, accounts receivable, equipment value, open purchase orders.

• Credit information: credit score band (you self-report; we

do not pull credit reports directly), bankruptcy or judgment history, time in business.

• Identity verification documents: driver's license, EIN

letter, articles of incorporation, voided check (when required by lender partners).

• Communications: emails you send us, SMS opt-in records,

notes from consultation calls.

• Usage data: which pages you view, when you sign in, IP

address, browser type. Used for security and product improvement only.

• Marketing attribution: when you arrive from one of our

marketing pages or an advertisement, we capture UTM parameters (source, medium, campaign, content, audience), the advertising click identifier if there is one (for example Google's `gclid` or Meta's `fbclid`), the page you landed on, the site that referred you, and the originating lead form.

• Referral link activity: when you arrive through a referral

link belonging to one of our referral partners, we record the partner's referral code, an optional campaign label the partner chose, the page you landed on, your browser type, a randomly generated visitor identifier, and a one-way hashed form of your IP address. We store the hash, never the address itself, and the visitor identifier is random — it is not derived from your name, email, device or IP.

This is the one category we collect before you give us anything. It is recorded the moment you click the link, whether or not you go on to create an account. If you never sign up, this is all we ever hold, and it does not identify you.

How we use your information

We use your information to:

1. Match you with appropriate funding products from our lender network. 2. Submit your application to lenders on your behalf, with your permission. 3. Communicate with you about your deals, offers, and account. 4. Send you transactional emails (account updates, document requests, signing notifications). 5. Comply with legal and regulatory obligations. 6. Improve our products and detect fraud or abuse. 7. Credit the referral partner who introduced you, and calculate any commission owed to them if your deal funds. 8. Measure which of our advertisements and campaigns lead to sign-ups, including by sharing limited identifiers with advertising platforms as described below.

We do not sell your personal information for money, and we never sell or rent your contact details to anyone for their own marketing. We do share limited identifiers with advertising platforms for conversion measurement — see "Advertising and measurement" below — which some privacy laws, including California's, treat as "sharing" and give you the right to opt out of. Contact privacy@fugiofundingnetwork.com to opt out.

How we share your information

We share your information with:

• Lender partners in our network — only with your explicit

authorization (via signed engagement agreement) and only the information needed to evaluate your funding application.

• Referral partners who introduced you to us. What a partner

can see depends on how you reached us, and the rule is that a partner never receives contact details they did not already have: - If a partner submitted your details to us directly — they filled in our form on your behalf or sent us your information from their own system — they already hold your contact information, and they can see the status of your deal as it progresses. - If you arrived through a partner's referral link or their sign-up page, the partner is credited with the introduction and can see counts only: how many people clicked, how many signed up, how many funded. They are not shown your name, email address, phone number or business name, and they are not told which of those numbers is you.

Partners are bound by agreement to protect any information they do receive and to use it only in connection with their referral relationship with us.

• DataMerch, a merchant risk-screening consortium used by

business funders. We check business and owner details against their database to assess risk, and records of that check may be retained by DataMerch and visible to other member funders.

• Service providers who help us operate the portal:

- GoHighLevel (CRM and communications platform) - Mailgun (transactional email delivery) - BoldSign (electronic signatures) - Cloudflare (object storage for uploaded documents) - Neon (database hosting) - Vercel (application hosting) - Sentry (error monitoring)

• Legal and regulatory authorities when required by law,

subpoena, or court order.

• Successor entities in the event of a merger or acquisition,

with notice to you.

Each service provider is bound by contractual obligations to protect your data and use it only for the purposes we specify.

Advertising and measurement

We advertise on Meta (Facebook and Instagram) and other platforms, and we need to know which advertisements actually lead to sign-ups. To measure that, we send Meta's Conversions API a record when someone signs up or reaches a milestone. That record contains:

• Your **email address, phone number, first name, last name and

account identifier — each one-way hashed** (SHA-256) before it leaves us. We do not send these in readable form.

• Your IP address and browser user-agent, and the identifiers

from Meta's own cookies if you have them, sent unhashed. Meta requires these in raw form to match the event; hashing them ourselves would prevent the match rather than protect it.

Meta uses this to tell us, in aggregate, which campaigns worked, and may also use it for its own purposes under its own terms. We send this for measurement, not to help anyone advertise to you by name.

Some privacy laws — California's CPRA in particular — treat this as "sharing" personal information for cross-context behavioral advertising, and give you the right to opt out even though no money changes hands. To opt out, email privacy@fugiofundingnetwork.com and we will exclude you. You can also limit this at the source through your Meta account settings and your browser's cookie controls.

How we protect your information

We use industry-standard practices to protect your information, including:

• HTTPS encryption for all portal traffic.
• Encryption at rest for stored data.
• Multi-factor authentication for staff access.
• Audit logging of every staff action affecting your account.
• Short-lived signed URLs for document downloads.
• Access controls limiting staff visibility to a need-to-know basis.

No system is perfectly secure; we cannot guarantee absolute security. If we discover a security incident affecting your data, we will notify you in accordance with applicable law.

How long we keep your information

• Active client data (Client, Deals, Documents, Notes): kept

while you have an active relationship with Fugio and for as long as needed to satisfy lender, regulatory, and contractual obligations.

• Funded loan records: kept for at least seven years following

loan payoff or write-off, consistent with SBA and IRS retention guidelines.

• Audit logs: kept for seven years from the date of the logged

event.

• Marketing-only contacts (no funded loan): may be retained

indefinitely unless you request deletion.

• Referral link click records: kept while the referring partner

relationship is active, so their reporting and any commission owed can be reconciled. If you ask us to delete your information, we strip the browser and hashed-IP details from these records and keep only the de-identified count, which no longer describes you.

Your rights

Depending on where you live, you may have the right to:

• Access the personal information we hold about you.
• Correct inaccurate information.
• Delete your information, subject to legal retention

obligations (we cannot delete records required to stay on file for regulatory purposes — funded loan records, etc.).

• Object to or limit certain uses of your information.
• Receive a copy of your information in a portable format.
• Opt out of marketing SMS or email at any time.

• Opt out of advertising measurement — see "Advertising and

measurement" above.

To exercise any of these rights, contact privacy@fugiofundingnetwork.com or use the request buttons on your portal account page. We will respond within 30 days.

When we delete your information, records we are required to keep — or that other people's records depend on, such as a referral partner's commission history — are de-identified rather than erased: your name, email, phone and business name are replaced with markers, and what remains cannot be traced back to you.

California residents have additional rights under the CCPA / CPRA. EU/EEA residents have rights under the GDPR. We honor these rights regardless of where you reside.

Children

The portal is not intended for individuals under 18. We do not knowingly collect information from children.

SMS messaging

If you opt in to SMS communications from us, you agree to receive text messages from Fugio at the phone number you provide. Standard message and data rates apply. You can opt out at any time by replying STOP. We will not share your phone number with third parties for their marketing purposes.

Cookies and tracking

The portal uses essential cookies for authentication and security — without them you cannot stay signed in.

It also sets a referral cookie when you arrive through a referral link. It is first-party, lasts 90 days, and cannot be read by any script on the page or by any other website. It holds the partner's referral code, the optional campaign label, and the random visitor identifier described above — no name, no email, no address. Because our marketing site and the portal are parts of one service, this single cookie covers both, so that a partner is still credited if you look around today and come back to apply next month. First touch wins: if the cookie is already there, a later link does not overwrite it.

If you block or clear cookies, everything still works. The only consequence is that the partner who introduced you may not be credited.

We do not use third-party advertising cookies inside the portal. Our marketing pages carry the Meta Pixel and analytics cookies, disclosed in that site's own cookie notice.

Changes to this policy

We may update this policy from time to time. When we do, we will update the "Last updated" date at the top and, for material changes, notify you through the portal or via email.

Contact

For questions or requests:

• Email: privacy@fugiofundingnetwork.com
• Mail: Fugio Funding Network, LLC