Privacy Policy

Privacy Policy

Last Updated: October 30, 2017


All capitalized terms used, but not defined herein shall have the meaning ascribed to such terms in the Terms of Use that you have agreed to as a condition to your use of this Website and the services provided by the Company (the “Terms of Use”).


This Website is owned and operated by Cerebro Capital, Inc. (“Company”). The Company wants you to understand what information the Company gathers about you, how the Company uses it, and the safeguards the Company has in place to protect it. This privacy policy (this “Policy”) applies to information collected through this Website, the Services, or otherwise by the Company. By using this Website or the Services, opening an Account, creating a user profile, or through an advertisement or linking from a third party site, you consent to this Policy, including your consent to the Company’s use and disclosure of information about you as required under Applicable Laws, all in the manner described below in this Policy. For purposes of this Policy, “you” or “your” means the person(s) using this Website, and/or the Services, including any employees or agents acting on your behalf. 


Any disputes arising your use of this Website or the Services, is subject to this Policy as well as the Terms of Use and all of its dispute resolution provisions, including arbitration, limitation on damages, and choice of law.


This Website is a general audience site and the Company does not knowingly collect personal information from children under the age of 13. To find more information about the Children’s Online Privacy Protection Act (COPPA), view the FTC website at


1. Information the Company Collects. The Company may collect personally identifiable information that can identify you such as your name, address, telephone number, e-mail address and EIN or Social Security Number (“Personally Identifiable Information” or “PII”). The Company may also collect information such as demographic data and data about your online activity on its Website that does not identify you (“Non-Personally Identifiable Information” or “Non-PII”). PII and Non-PII are known together as “Information”. The Company may also collect and store Information that you provide to it about other people (such as co-borrowers, guarantors, affiliates, parents, subsidiaries, and family members), including their respective names, addresses, telephone numbers, mobile devices, email addresses and EINs or Social Security Numbers.


2. How We Collect Information You Provide.

The Company collects Information you provide to the Company in connection with inquiring about or otherwise utilizing this Website or the Services. The Information we collect from you will vary depending on your utilization of this Website or the Services.


The Company may obtain Information about you from third parties, including Information necessary for the Company to comply with federal, state and local laws. The Company will not disclose your PII to any Counterparty unless you have agreed to such disclosure. The Company knows that the secrecy of your information is important to you, and the Company endeavors to protect such information accordingly.


The Company may use cookies, web beacons and other internet technologies to collect information from your computer(s) and about your activities on our website. The Company may collect Non-PII from your browser when you visit this Website.


3. Use of Information

The Company may use your Information to:

• Deliver the Services;

• Communicate with you about the Services or the Website;

• Provide you with certain market analytics and other data and data analytics;

• Manage your relationship with the Company;

• Provide customer support to you and others;

• Research and analyze your Information; 

• Create general information about the commercial lending industry;

• Research and analyze your use the Services and the Website;

• Manage the Company’s business; and

• For any other reason described to you at the time of collection.


Depending on the Services, the Company may use your Information to match you with those certain Counterparties that you have indicated to the Company that you would like to be matched with. 


The Company may use your PII for the purpose of providing you with the Services. Except as described in this Policy, the Company will not disclose your PII to any Counterparties or other third parties unless otherwise agreed to by you.


When utilizing this Website or the Services, when you click on any button indicating an acceptance or agreement to terms, a continuance of processing or submission, or otherwise signifying your agreement to proceed, you are consenting, acknowledging, and agreeing to the disclosure of your PII, as described herein, to those Counterparties with whom, as you have indicated to the Company, you agree to share such PII with. PLEASE NOTE that the Counterparties to whom you have agreed to share Information, including PII, may retain or use such Information whether or not you choose to transact business with such Counterparty. You should contact such Counterparties directly concerning their 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. Before you disclose any Information to such third parties, you should contact such third parties directly concerning their respective privacy and information sharing practices and policies.


The Company may share your PII with certain service providers who provide the Company with services as part of the operation of the Company’s business. These third parties may have access to PII as may be required to perform their functions for the Company.


The Company may disclose your Information, including your PII, in order to comply with any subpoena or similar investigative demand, a court order or a request for cooperation from a law enforcement or other government agency or as the Company may otherwise be, or may reasonable believe to be, required under Applicable Law.


The Company may disclose your Information, including your PII, in order to establish or exercise the Company’s legal rights; to defend against legal claims.


The Company may disclose your Information, including your PII, in order to investigate, prevent or take other action regarding actual or suspected illegal activity or other wrongdoing; to protect and defend the rights, property or safety of the Company, the Company’s employees or agents, the Counterparties, or other third parties.


The Company may disclose your Information, including your PII, in order to enforce the Terms of Use, this Policy or the Company’s other agreements or policies.


The Company may disclose your Information, including your PII, as part of a substantial transaction or reorganization, including without limitation, the sale of the Company’s assets, equity, a divestiture, merger, consolidation, or in the event of bankruptcy or receivership of the Company.


When you provide any information, create an account (including your Account), create a user profile, use the Website or procure the Services, you hereby understand and agree that you have established a business relationship between you and the Company. Accordingly, the Company may send your non-identifiable information to its affiliates, Counterparty, or other third party partners as provided in this Policy. In addition, you agree that the Company may contact you with information and offers of services, including the Services, available through the Company, the Website or through any affiliates of the Company. By agreeing to this Policy, you hereby provide express written consent to any such communication and you agree to notify the Company by emailing directly if you no longer want to receive other forms of communications from the Company.


The Company may share Non-PII with third parties in our discretion.


You hereby acknowledge and agree that, though you own all of your Information that you provide the Company, the Company has the irrevocable right to use your Information and create and utilize Information derivative thereof, and all improvements thereon (the “New Information”).


You hereby acknowledge and agree that the Company owns all rights related to the New Information, including, without limitation, the right to develop, utilize, market, and sell the New Information, so long as the New Information does not contain any PII.


4. Your Rights

You have the right to restrict the sharing of your PII with the Company’s affiliates (entities the Company owns or controls) and third parties that the Company does business with; however, nothing in this Policy prohibits the Company from sharing any Information as may be, or may be reasonable believed to be, necessary for the Company to follow any Applicable Laws, or to Service your Account. To request restricted sharing of PII please email


5. Updating and Accessing Your Information

To access or update your Account information, contact information or payment information please follow the instructions indicated in your Account settings.


6. Protecting PII.

The Company utilizes security measures that are standard in the industry (including physical, electronic and procedural measures) to help safeguard your PII from unauthorized access and disclosure. In addition to the restrictions outlined above, we require employees to comply with information security safeguards, we use encryption in the transmission of your PII between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your PII.


Because no system can be completely secure, the Company cannot, and does not, guarantee that your PII or other Information will always remain secure. You should take care with how you handle and disclose your PII. Please refer to the Federal Trade Commission’s website for information about how to protect yourself against identity theft.


7. 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 your Account homepage or by sending you electronic notification of such changes. Please check this Policy whenever you use our access the Website or utilize the Services in order to ensure that you are aware of any changes in the Company’s practices. Your continued use of the Website or the Services will constitute your acceptance of the changes to this Policy.


8. 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 and other countries 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 share 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, or if you would like to request information about the Company’s disclosure of PII, please contact the Company by e-mail as follows: