Introduction

This website is owned and operated by Cerebro Capital, Inc. (“Company,” “we,” “us,” or “our”). We want you to understand what information we gather about you, how we use it, and the safeguards we have in place to protect it.

For purposes of this Policy, “you” or “your” means the person(s) using the website cerebrocapital.com and all of its subdomains (including www.cerebrocapital.com, go.cerebrocapital.com, platform.cerebrocapital.com, and any other subdomains), and any page thereof, including but not limited to any information transmitted and collected through your account (collectively, the “Website”), or any services offered or provided by the Company (the “Services”), including any employees or agents acting on your behalf.

This privacy policy (this “Policy”) applies to information that we collect through the Website, in conjunction with our provision of the Services (including via email, text, or other electronic message), or otherwise by the Company. This Policy does not apply to information collected by any third party (including third parties with whom you interact through the Website or in connection with the Services).

Please read this Policy carefully. By using the Website or the Services, you agree to this Policy. This Policy may change from time to time (see Changes and Updates to this Policy), and your continued use of the Website or Services following notice of any such changes is deemed to be acceptance of those changes.

Note: This Policy governs how we handle your Information in connection with our Website and Services. Cookie consent (which controls tracking technologies) is separate from your decision to provide information to us through web forms, phone calls, emails, documents, or our platform. When you provide us with your company and contact information through any of these channels, you are providing that information directly to us for use in delivering our Services, regardless of your cookie consent preferences. See “Information You Provide to Us Directly” below for details.

Table of Contents

Information We Collect

How We Collect Your Information

  – Information We Collect Automatically

  – Information You Provide to Us Directly

  – SMS and Text Messaging Consent

Cookies, Tracking Technologies, and Consent

Third-Party Data Collection Technologies

How We Use Your Information

Disclosure of Your Information

Your Choices Regarding Our Use and Disclosure of Information

Data Security

How Long We Keep Information

Right to Examine Information

State-Specific Rights

Direct Marketing and Communications

Children Under the Age of 18

Changes and Updates to this Policy

Miscellaneous

Information We Collect

The Company may collect personally identifiable information that can identify you such as your name, address, telephone number, email address, and EIN or Social Security Number (“Personally Identifiable Information” or “PII”). The Company may also collect information that does not identify you, such as demographic data, data about your online activity, information about your internet connection, or equipment you use to access the Website (“Non-Personally Identifiable Information” or “Non-PII”).

The Company may also collect and store information that you provide to it about other people (such as co-borrowers, guarantors, affiliates, parents, subsidiaries), including their respective names, addresses, telephone numbers, mobile devices, email addresses, and EINs or Social Security Numbers (any such information, along with PII and Non-PII, the “Information”).

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

SMS and Text Messaging Consent

Certain web forms on our Website include an option to consent to receiving SMS text messages from us. If you opt in, we may send you text messages related to your inquiry and our Services using a third-party SMS messaging platform. By opting in to SMS communications, you consent to receiving text messages at the mobile number you provided. You may opt out of SMS messages at any time by replying STOP to any message. Standard message and data rates may apply.

 Your mobile phone number and SMS opt-in consent will not be shared with or sold to any third parties or affiliates for their own marketing or promotional purposes. We may use third-party service providers (such as our text messaging platform) to facilitate delivery of SMS messages on our behalf, but these providers are contractually prohibited from using your information for any purpose other than delivering our messages.

How We Collect Your Information

The Company collects Information about you in the following ways:

• Directly from you in connection with inquiring about or otherwise utilizing the Website or the Services;
• Automatically as you navigate the Website, including through cookies, web beacons, pixels, and other internet technologies to collect information from your computer(s) and browser about your activities on our website; and
• From third parties with whom you interact via the Website or to whom the Company is authorized to disclose Information in performance of the Services.

Information We Collect Automatically

We also collect and store information that is generated automatically as you navigate the Website and the Services. For example, we may collect information about your computer’s connection to the Internet, which allows us, among other things, to improve the delivery of our web pages to you and to measure traffic on the Services. We may also collect certain information from your mobile device, such as device type, operating system, screen size, browser, and advertising identifier.

Information You Provide to Us Directly

When you provide us with your company and contact information — whether through a web form, over the phone, via email, through documents you share with us, or through our platform — you are voluntarily providing us with that information for use in delivering our Services. This is separate from cookie consent. Your decision to accept or decline tracking cookies does not affect how we use Information you affirmatively provide to us through any of these channels.

Cerebro Capital is a commercial lending marketplace. By providing your information to us, you acknowledge and agree that we may use your information to:

• Present your loan request or business profile (in anonymized form) to lenders on our marketplace platform;
• Facilitate introductions between you and lenders who express interest in your financing needs, which includes sharing your contact and company information with those lenders upon your consent or agreement to be introduced;
• Contact you by email, phone, or SMS (if you have opted in to SMS) to discuss your inquiry, provide loan assessments, and deliver our Services;
• Analyze your financing needs and match you with appropriate lenders; and
• Follow up on your inquiry, including re-engagement.

Once you agree to be introduced to a lender or become a customer of our Services, we will share your Information — including your name, company details, contact information, and financial data you have provided — with the relevant lender(s) on our platform. This applies regardless of how you provided the Information to us (web form, phone, email, documents, or platform). See “Note About Disclosure to Third Parties” below for additional details about how third parties may use your Information after disclosure.

Cookies, Tracking Technologies, and Consent

We use cookies, pixels, web beacons, and similar tracking technologies on our Website. Cookies are small data files placed on your device that enable us to remember your preferences and collect information about your website usage. Pixels and web beacons are small graphic files that help us understand how you interact with our site and measure the effectiveness of our advertising.

Consent for Tracking Technologies

In accordance with applicable privacy laws, including the California Invasion of Privacy Act (Cal. Penal Code § 638.51), no non-essential cookies or tracking technologies are loaded on your device until you provide explicit consent. When you first visit our Website, a consent banner will appear giving you the choice to:

• Accept all cookies: Consent to the use of all cookies and tracking technologies across all categories.
• Decline non-essential cookies: Only cookies strictly necessary for website functionality will be used. No advertising, analytics, or preference cookies will be loaded.

You may change or withdraw your consent at any time by visiting our Privacy Policy page and clicking “Manage Cookie Preferences,” or by using the “Detailed cookie preferences management” link to view the full cookie inventory and manage individual categories.

Our consent management is provided by a third-party consent management platform and applies across cerebrocapital.com and all of its subdomains.

Categories of Cookies

Necessary cookies: Required for basic website functionality such as page navigation, security, and access to secure areas. These cookies do not require consent and cannot be disabled.

Preference cookies: Enable the Website to remember information that changes how the Website behaves or looks, such as your preferred language or the region you are in.

Statistics cookies: Help us understand how visitors interact with the Website by collecting and reporting information. These cookies are used for analytics and performance tracking.

Marketing cookies: Used to track visitors across websites to display advertising that is relevant and engaging. These cookies support our advertising measurement and remarketing efforts.

A detailed list of all cookies in use on our Website, organized by category, is available at the bottom of this page via the “Detailed cookie preferences management” link. That list includes the cookie name, provider, purpose, storage duration, and type for each cookie.

Third-Party Data Collection Technologies

In operating our business, we use certain third-party services that may collect information about your activity on our Website. These services include, but are not limited to:

• Advertising and remarketing: Google Ads, Meta (Facebook) Pixel, LinkedIn Ads, Microsoft Advertising (Bing UET), and MNTN (connected TV)
• Analytics and performance: Google Analytics (GA4 and Universal Analytics), Mouseflow (website usage), and HubSpot
• Tag management and consent: Google Tag Manager and our consent management platform (identified in the cookie declaration)
• Security and infrastructure: Cloudflare
• Landing pages: Unbounce
• SMS communications: Third-party SMS messaging platform

None of these third-party services load or collect any data until you have provided explicit consent through our cookie consent banner, with the exception of services classified as “Necessary” (such as security and bot detection). We may add, remove, or change third-party service providers from time to time. For a current and complete list of cookies set by each provider, including their purpose and storage duration, see the cookie declaration at the bottom of this page via the “Detailed cookie preferences management” link.

In particular, Google Analytics Advertiser Features are enabled, including Remarketing with Google Analytics, Google Display Network Impression Reporting, and Google Analytics Demographics and Interest Reporting. These features use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as Google advertising cookies) together to gather data about your activities on our Website.

You may opt out of the automated collection of information by third-party ad networks by visiting the consumer opt-out page for the Self-Regulatory Principles for Online Behavioral Advertising at http://www.aboutads.info/choices/ or editing your Google Display Network ad preferences at http://www.google.com/ads/preferences/. You can also opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website at http://optout.networkadvertising.org/.

How We Use Your Information

The Company may use your Information to:

• Present the Website and deliver the Services to you, including providing customer support;
• Communicate with you about the Services or the Website, including any changes thereto;
• Inform you of additional services offered by us or our affiliates;
• Manage your relationship with the Company, including to carry out our obligations and enforce our rights arising from any contracts entered into between you and us;
• Analyze your use of the Services and the Website in order to optimize the Company’s business and performance;
• Compile aggregated statistics;
• Evaluate interest from third-party service providers with whom you may be interested in doing business, specifically regarding information that you affirmatively submit to us regarding potential services;
• Facilitate introductions between you and lenders on our marketplace platform, including presenting your loan request or business profile to prospective lenders;
• Share your Information with lenders upon your consent or agreement to be introduced, as described in “Note About Disclosure to Third Parties”;
• Contact you by email, phone, or SMS regarding your inquiry and our Services;
• Measure the effectiveness of our advertising campaigns;
• Comply with any legal obligation; and
• For any other reason described to you at the time of collection.

Disclosure of Your Information

We may disclose aggregated statistics (or other information that does not identify any particular individual or entity) about our users, the commercial lending industry, market analytics, and related topics without restriction.

We may disclose Information as follows:

• To our subsidiaries and affiliates;
• To contractors, service providers, and other third parties we use to support our business or that we believe may be a better fit for the services you are seeking;
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets;
• To fulfill the purpose for which you provide it, including but not limited to by making authorized disclosures to third parties for purposes of performing the Services (see Note About Disclosure to Third Parties below);
• For any other purpose disclosed by us when you provide the information;
• With your consent;
• To government or regulatory authorities as we reasonably believe is necessary;
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request;
• To investigate, prevent, or take other action regarding actual or suspected illegal activity or other wrongdoing;
• To enforce or apply our Terms of Use or any other agreement between you and the Company, including for billing purposes; and
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our agents and affiliates, our customers, or others.

Note About Disclosure to Third Parties

You specifically acknowledge that our provision of the Services may necessitate disclosure of Information to third parties. Cerebro Capital operates a commercial lending marketplace that connects businesses with lenders. The core function of our Services requires sharing your Information with lenders.

When you submit a web form, agree to a loan assessment, accept an introduction to a lender, or otherwise engage our Services, you consent to our sharing your Information — including your name, company details, contact information, and financial data — with lenders on our marketplace platform. Initially, your information may be presented to lenders in summary or anonymized form. Once you consent to an introduction or agree to proceed with a specific lender, your full Information may be disclosed to that lender. In some cases, limited Information may be shared with lenders prior to a formal introduction in order to assess fit and facilitate the matching process.

PLEASE NOTE that, once the Information is disclosed to a lender or other third party, such party’s use of the Information is outside the scope of this Policy. Such parties may use and may retain your Information whether or not you choose to transact business with such party. You should contact such party directly concerning its respective privacy and information-sharing practices and policies.

You should also be aware that the Website may contain links to other websites owned and operated by third parties. Should you submit any Information to such parties, whether directly or automatically by interacting with the link or website, such third parties’ use of such Information is outside the scope of this Policy.

Your Choices Regarding Our Use and Disclosure of Information

You have several options for controlling how your Information is collected and used:

Cookie consent: When you first visit our Website, you may accept or decline non-essential cookies and tracking technologies through our consent banner. You may change your preferences at any time by visiting our Privacy Policy page and clicking “Manage Cookie Preferences.”

Global Privacy Control (GPC): We honor Global Privacy Control signals sent by your browser. If your browser sends a GPC signal, we will treat it as a request to opt out of the sale or sharing of your personal information, as required by applicable law.

Communication preferences: If you wish to modify your preferences about the Company’s ability to contact you about additional services offered or other discretionary preferences, you may email privacy@cerebrocapital.com. All marketing emails sent by us include an unsubscribe link.

Browser settings: You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

Please note that, depending on your location, you may have specific privacy rights due to state-specific regulations. To make a request under any such regulation, please email us at privacy@cerebrocapital.com.

Data Security

We will keep your Information for as long as is necessary for you to obtain the benefit of the Services. Thereafter, we consider several factors to determine how long we keep your Information, including: the amount, nature, and sensitivity of the Information; your preferences regarding Information as communicated to us in writing; the potential risk of harm from unauthorized use or disclosure of your Information; the purposes for which we process your Information and whether we can achieve those purposes through other means; and our contractual and other legal requirements.

When we do destroy your Information, we will securely destroy it in accordance with applicable laws and regulations.

Right to Examine Information

You have the right to examine any of your PII that we collected over the previous twelve months. Should you wish to examine such information, please send us a written request to privacy@cerebrocapital.com. We reserve the right to charge you a reasonable administrative fee to access your information, as permitted by applicable law. In certain cases, we may not be able to provide you with access to all of your PII. We may decline to process requests that are frivolous, relating to information also pertaining to the PII of another individual, are unreasonable, or for which access is not otherwise required by local law.

State-Specific Rights

California

The California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), provides California residents with specific rights regarding their personal information. Additionally, the California Invasion of Privacy Act (Cal. Penal Code § 638.51) requires that tracking technologies used to monitor online activity may not be deployed without the user’s prior consent. Our cookie consent mechanism is designed to comply with this requirement by blocking all non-essential tracking technologies until you provide explicit opt-in consent.

As a California resident, you have the following rights:

• Right to Know: You may request that we disclose what personal information we have collected, used, shared, or sold about you, including the categories of personal information, specific pieces of personal information, the categories of sources from which we collected it, the purposes for which it is used, and the categories of third parties with whom it is shared.
• Right to Delete: You may request that we delete personal information we have collected about you, subject to certain exceptions.
• Right to Correct: You may ask us to correct inaccurate personal information that we maintain about you.
• Right to Limit Use of Sensitive Personal Information: You can request that we only use your sensitive personal information (for example, Social Security number, financial account information) for limited purposes, such as providing you with the Services you requested.
• Right to Opt Out of Sale or Sharing: You may request that we stop selling or sharing your personal information. You can exercise this right through our cookie consent preferences or by emailing us.
• Right to Non-Discrimination: You have the right to not receive discriminatory treatment for exercising your privacy rights.

To exercise any of these rights, please contact us at privacy@cerebrocapital.com or call (301) 798-9080. We will verify your identity before processing your request and will respond within the timeframes required by law. You may also designate an authorized agent to make a request on your behalf.

Nevada

Under Nevada Revised Statutes Chapter 603A, Nevada residents may opt out of the sale of certain covered information that we have collected or will collect about you. To exercise this right, please email privacy@cerebrocapital.com with the subject line “Nevada Opt-Out.”

Other States

Residents of Colorado, Connecticut, Virginia, Utah, Texas, Oregon, Montana, and other states with comprehensive privacy laws may have additional rights, including rights of access, correction, deletion, data portability, and the right to opt out of targeted advertising, sale of personal data, or profiling. To exercise any such rights, please email privacy@cerebrocapital.com.

Appeals

If we decline to take action on a privacy rights request, you may appeal that decision by contacting us at privacy@cerebrocapital.com or calling (301) 798-9080 within 60 days of receiving our response. Please include your original request, the date of our response, and a brief explanation of why you believe our decision was incorrect. We will respond to your appeal within the timeframe required by applicable law.

Direct Marketing and Communications

We may use your personal information to send you marketing communications about our products, services, and promotions that we believe may be of interest to you. We will obtain your consent before sending marketing communications where required by law.

We may contact you through the following channels, each with its own opt-out mechanism:

• Marketing emails (broadcasts, newsletters, promotional campaigns): Each marketing email includes an unsubscribe link that allows you to remove yourself from future marketing messages. Note that one-to-one business correspondence related to your active inquiry or engagement with our Services is not considered marketing email and may not include an unsubscribe link, consistent with CAN-SPAM Act provisions for transactional and relationship messages.
• SMS text messages: You may opt out of SMS messages at any time by replying STOP to any message you receive from us. See “SMS and Text Messaging Consent” above for additional details.
• Telephone calls: You may opt out of marketing calls by informing our representative during the call or by contacting us at privacy@cerebrocapital.com or (301) 798-9080 to request placement on our internal do-not-call list.
• Retargeting advertisements: You may opt out of retargeting ads by declining marketing cookies through our cookie consent banner, by visiting your cookie preferences on our Privacy Policy page, or by using the third-party opt-out tools described in the “Third-Party Data Collection Technologies” section.

You can also manage your overall communication preferences by contacting us at privacy@cerebrocapital.com.

Children Under the Age of 18

Neither the Website nor the Services is intended for children under the age of 18. The Company does not knowingly collect personal information from users under the age of 18. If we become aware that we have inadvertently received personally identifiable information from a user under the age of 18, we will delete such information from our records.

Changes and Updates to this Policy

The Company reserves the right to update or modify this Policy to reflect changes to how the Company collects, uses, and/or shares Information. This Policy will reflect the date it was last updated. If the Company makes any material changes to this Policy, you will be notified before their implementation either by a prominent posting of a notice of such changes on the Website or by electronic notification. Please check this Policy periodically to ensure that you are aware of any changes. Your continued use of the Website or the Services following notice of any changes will constitute your acceptance of those changes.

Miscellaneous

This Policy is intended to cover collection of information on the Website from residents of the United States. If you are visiting the Website from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where the Company’s servers are located and the Company’s central database is operated. The data protection and other laws of the United States might not be as comprehensive as those in your country. By using the Website or the Services, you understand that your information may be transferred to the Company’s facilities and those third parties with whom the Company shares Information, as described in this Policy.

This Policy does not create rights enforceable by third parties or require disclosure of any PII.

If you have any questions about this Policy or the Company’s information-handling practices generally, please contact the Company by email at privacy@cerebrocapital.com or by phone at (301) 798-9080.

Click “Manage Cookie Preferences” button below to reopen the cookie consent banner and change your cookie settings. Click “Detailed cookie preferences management” link below to view the full cookie inventory, your consent ID, consent date, and to withdraw or change your consent for specific cookie categories.