Privacy Policy for Seraph Capital LLC (seraph.capital)

Last Updated: April 7, 2025

1. Introduction

Seraph Capital LLC ("we," "us," or "our") operates the website seraph.capital (the "Site"). We are committed to protecting the privacy of our users ("you" or "your"). This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you visit our Site, including any other media form, media channel, mobile website, or mobile application related or connected thereto.

Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please do not access the site.

2. Information We Collect

We may collect personal information from you in a variety of ways. The information we may collect on the Site includes:

  • Personal Identifiable Information: Such as your name, email address, phone number, physical address, and mailing address, which you voluntarily give to us when you fill out forms on the Site, such as when requesting information, applying for funding, or expressing interest in buying or selling notes.
  • Business Information: Such as your company name, when provided in relation to funding applications or note transactions.
  • Financial Information: Such as the amount of funding requested, details related to notes you wish to sell (including property address and borrower information), or other financial details necessary to evaluate applications or facilitate transactions. We collect this information when you voluntarily provide it through relevant forms on the Site.
  • Derivative Data: Information our servers automatically collect when you access the Site, such as your IP address, browser type, operating system, access times, and the pages you have viewed directly before and after accessing the Site. This may be collected via server logs (e.g., Nginx).
  • Third-Party Data: Information collected by third-party services we use for Site functionality and security, such as Cloudflare and Cloudflare Turnstile. This may include IP addresses, user interaction data, and other information necessary for security screening and CAPTCHA verification.

3. How We Collect Information

We collect information about you through:

  • Web Forms: When you voluntarily submit information through forms on our Site (e.g., contact forms, funding applications, note transaction inquiries).
  • Server Logs: Automatically collected technical information stored by our web server (Nginx).
  • Third-Party Integrations: Services like Cloudflare (for security and performance) and Cloudflare Turnstile (for CAPTCHA) may automatically collect data when you interact with our Site. We also use Amazon Simple Email Service (SES) to transmit the data submitted via forms; SES may employ tracking pixels in emails for deliverability metrics.

4. How We Use Your Information

Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may use information collected about you via the Site to:

  • Respond to your inquiries and provide customer support.
  • Process your applications for funding and evaluate your eligibility.
  • Facilitate the buying and selling of notes, including performing necessary due diligence.
  • Communicate with you regarding your account, applications, transactions, or inquiries.
  • Monitor and analyze usage and trends to improve Site functionality and user experience.
  • Protect the security and integrity of our Site, prevent fraudulent transactions, monitor against theft, and protect against criminal activity (e.g., via Cloudflare/Turnstile).
  • Comply with legal and regulatory requirements.
  • Fulfill any other business purpose stated at the time of collection.

5. How We Share Your Information

We may share information we have collected about you in certain situations. Your information may be disclosed as follows:

  • By Law or to Protect Rights: If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation.
  • Third-Party Service Providers: We may share your information with third parties that perform services for us or on our behalf, including website hosting, data analysis, email delivery (Amazon SES), security and performance services (Cloudflare), and CAPTCHA services (Cloudflare Turnstile).
  • Business Transactions (Funding & Notes): If you apply for funding, we may share your information with potential lenders we broker for to facilitate your application.
    • If you express interest in selling notes, we may share relevant information with potential investors.
    • If you express interest in buying notes, we may share your information with potential sellers.
    • We may share necessary information with loan servicers to manage transactions.
  • Other Third Parties: We may share your information with lawyers, auditors, or other advisors in connection with the purposes outlined above.

We do not sell your personal information in the traditional sense. However, certain sharing activities, particularly under California law, might be considered "sharing" for cross-context behavioral advertising (though we don't currently engage in this) or a "sale." Please see the California Residents section for more details.

6. Data Retention

We will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will determine the appropriate retention period based on several factors, including:

  • The need to maintain and manage our relationship with you or fulfill the services you requested.
  • Our legal and regulatory obligations (e.g., record-keeping requirements).
  • The potential for litigation or disputes.
  • The need to maintain and manage our relationship with you or fulfill the services you requested.
  • Our legal and regulatory obligations (e.g., record-keeping requirements).
  • The potential for litigation or disputes.
  • Our legitimate business needs.

Retention periods will vary depending on the type of information and the context.

7. Data Security

We use administrative, technical, and physical security measures to help protect your personal information. These include:

  • Using SSL/HTTPS encryption for data transmitted over the internet.
  • Using secure server infrastructure.
  • Employing encrypted email services for relevant communications.
  • Implementing access controls.
  • Providing staff training on data security practices.
  • Conducting regular security reviews.
  • Partnering with reputable third-party vendors with strong security practices.

While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse.

8. Cookies and Tracking Technologies

We currently do not place our own cookies for analytics, advertising, or user preferences on the Site. However, our third-party service providers may use cookies or similar technologies:

  • Cloudflare/Turnstile: May use necessary cookies or scripts to provide security, CDN services, and CAPTCHA functionality. These are generally essential for the Site's operation and security.
  • Amazon SES: May use tracking pixels within emails sent after form submissions to monitor email deliverability and performance.

You can usually manage cookies through your browser settings. However, disabling necessary cookies (like those used by Cloudflare) may impact the functionality and security of the Site.

9. Your Privacy Rights

Depending on your jurisdiction, you may have certain rights regarding your personal information. These may include the right to:

  • Access: Request copies of your personal information.
  • Correction: Request that we correct any information you believe is inaccurate or complete information you believe is incomplete.
  • Deletion: Request that we erase your personal information, under certain conditions.

To exercise these rights, please contact us at [email protected]. We will respond to your request in accordance with applicable laws.

10. Your California Privacy Rights (CCPA/CPRA)

If you are a resident of California, you have specific rights regarding your personal information under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

  • Right to Know: You have the right to request information about the categories and specific pieces of personal information we have collected about you, the categories of sources from which the information was collected, the purposes for collecting the information, and the categories of third parties with whom we share personal information.
  • Right to Delete: You have the right to request the deletion of your personal information that we have collected, subject to certain exceptions.
  • Right to Correct: You have the right to request the correction of inaccurate personal information that we maintain about you.
  • Right to Opt-Out of Sale/Sharing: You have the right to opt-out of the "sale" or "sharing" of your personal information. While we do not sell personal information for monetary value, sharing information with third parties like lenders or potential investors/sellers as described in Section 5 might be considered a "sale" or "sharing" under CCPA/CPRA in certain contexts. To exercise this right, please contact us.
  • Right to Limit Use of Sensitive Personal Information: You have the right to limit the use and disclosure of your sensitive personal information (e.g., financial details) to that which is necessary to perform the services or provide the goods reasonably expected by an average consumer. To exercise this right, please contact us.
  • Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights.

To exercise any of these rights, please contact us at [email protected]. We may need to verify your identity before processing your request.

11. Children's Privacy

Our Site is not intended for or directed at children under the age of 13. We do not knowingly collect personal information from children under 13. If we become aware that we have inadvertently collected personal information from a child under 13, we will take steps to delete such information promptly.

12. International Data Transfers

We operate primarily in the United States. However, we utilize third-party service providers (like Cloudflare and AWS) that operate globally. Therefore, if you access the Site from outside the United States, your information may be transferred to, stored, and processed in the United States and other countries where our servers or service providers are located. Data protection laws in these countries may differ from those in your country of residence. By using the Site, you consent to the transfer of your information to countries outside your residence, including the United States.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date at the top. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. We will not actively notify users of changes via other means.

14. Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at:

Seraph Capital LLC Email: [email protected]