Privacy Policy

1. About This Policy

EagleTrace, Inc. ("EagleTrace," "we," "us," or "our") operates the Financial Service Center platform ("FSC" or "Platform") - a technology product that helps small business owners discover, apply for, and manage financial services. This Privacy Policy describes how we collect, use, disclose, and protect your information when you use the Platform.

By using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the practices described herein. If you do not agree, please do not use the Platform.

2. Information We Collect

2.1 Information You Provide

• Account information: Name, email address, phone number
• Business information: Legal business name, DBA, entity type, EIN, address, industry, years in business, number of employees, annual revenue
• Principal/owner information: Owner name, date of birth, ownership percentage, personal address
• Financial information: Bank account details (routing and account numbers), processing statements, tax returns, and related financial documents
• Identity documents: Driver's license, articles of incorporation, business licenses
• Payment information: Credit/debit card details for subscription billing (processed and stored by Stripe; we do not store raw card numbers)

2.2 Information Collected Automatically

• Log data: IP address, browser type, pages visited, time spent, referring URLs
• Device information: Device type, operating system, unique device identifiers
• Cookies and similar technologies: Session cookies, preference cookies, and analytics identifiers (see Section 7)

2.3 Information from Third Parties

• Authentication providers: We use Clerk for identity management; information shared upon sign-in
• Credit bureaus: With your consent, we may obtain business and personal credit information to facilitate application evaluation by Service Providers
• Payment processors: Transaction and account status information from Stripe

3. How We Use Your Information

We use your information to:

• Create and manage your account and provide Platform services
• Facilitate and evaluate applications for financial products with Service Providers
• Connect you with appropriate licensed third-party Service Providers
• Send transactional communications (application updates, account notices, billing receipts)
• Send marketing communications where permitted and with the ability to opt out
• Improve, personalize, and develop new Platform features
• Detect and prevent fraud, abuse, and security incidents
• Maintain records required by law and enforce our Terms of Service
• Comply with applicable legal obligations and respond to legal process

4. How We Share Your Information

We do not sell your personal information. We share your information only in these circumstances:

4.1 Service Providers and Financial Partners

We share your business and financial information with licensed Service Providers (lenders, payment processors, insurance partners, and similar) when you initiate an application or request for their products. By submitting an application, you authorize this sharing. Service Providers have their own privacy policies governing their use of your data.

4.2 Technology Vendors

We use the following vendors who process data on our behalf:

• Clerk - Authentication and identity management
• Stripe - Payment processing and subscription management
• Amazon Web Services (AWS) - Cloud infrastructure and document storage
• Resend - Transactional email delivery
• Anthropic - AI-assisted document data extraction

4.3 Channel Partners

If you access the Platform through a channel partner (such as a franchise system or industry association that has licensed the Platform for their members), your enrollment status and basic account information may be shared with that partner organization as part of their member administration. The nature of information shared is limited to your membership status, account creation date, and whether you have completed onboarding. Your application and financial data is not shared with channel partners.

4.4 Legal Requirements

We may disclose your information when required by law, court order, government regulation, or subpoena, or when we believe disclosure is necessary to protect our rights, your safety, or the safety of others.

4.5 Business Transfers

In the event of a merger, acquisition, or sale of substantially all of our assets, your information may be transferred to the acquiring entity. We will notify you before your information becomes subject to a materially different privacy policy.

5. Data Security

We implement industry-standard security measures to protect your information:

• TLS 1.2+ encryption for all data in transit
• AES-256 encryption for data at rest on AWS infrastructure
• Field-level encryption for highly sensitive data (SSN, bank account numbers)
• Access controls and multi-factor authentication for administrative systems
• Regular security audits and vulnerability assessments

No method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security. In the event of a data breach that affects your rights or freedoms, we will notify you as required by law.

6. Data Retention

We retain your information for as long as your account is active or as necessary to provide services. After account closure, we retain data for up to 7 years to comply with financial recordkeeping requirements and legal obligations. You may request deletion of your data subject to these retention requirements and any applicable law.

7. Cookies and Tracking Technologies

We use cookies and similar technologies to operate the Platform, remember your preferences, and understand usage patterns. We use three categories of cookies:

• Essential cookies: Required for Platform operation (authentication sessions, security). Always active.
• Analytics cookies: Help us understand how users use the Platform so we can improve it. You may opt out.
• Marketing cookies: Used to deliver relevant promotional content. You may opt out.

When you first visit the Platform, we will request your consent for non-essential cookies via a cookie consent banner. You may change your preferences at any time by clicking "Cookie Settings" in the footer. Disabling essential cookies may affect Platform functionality.

8. Your Rights and Choices

You have the following rights regarding your personal information:

• Access: Request a copy of the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of your personal information (subject to legal retention requirements)
• Portability: Request your data in a structured, machine-readable format
• Opt-out of marketing: Unsubscribe from marketing emails via the unsubscribe link in any email
• Cookie preferences: Manage non-essential cookie consent at any time
• Do Not Sell: We do not sell personal information

To exercise any of these rights, contact us at privacy@eagletrace.ai. We will respond within 30 days. We may need to verify your identity before processing certain requests.

9. California Privacy Rights (CCPA/CPRA)

California residents have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

• Right to Know: Know what categories and specific pieces of personal information we have collected about you, where it comes from, how it is used, and with whom it is shared
• Right to Delete: Request deletion of your personal information, subject to certain exceptions
• Right to Correct: Request correction of inaccurate personal information
• Right to Opt-Out: Opt out of the "sale" or "sharing" of personal information (we do not sell personal information)
• Right to Limit Use of Sensitive Personal Information: Limit our use of sensitive personal information to what is necessary to provide services
• Right to Non-Discrimination: Not be discriminated against for exercising your privacy rights

To submit a verifiable consumer request, contact us at privacy@eagletrace.ai or write to us at the address in Section 12.

10. Users Outside the United States

The Platform is intended for use by U.S.-based business owners. If you are located outside the United States, please be aware that your information may be transferred to and processed in the United States, where data protection laws may differ from those in your jurisdiction. By using the Platform, you consent to such transfer. Users in the European Economic Area may have additional rights under the GDPR; contact us to inquire.

11. Children's Privacy

The Platform is intended for business owners and is not directed to individuals under 18 years of age. We do not knowingly collect personal information from minors. If you believe we have inadvertently collected such information, contact us immediately at privacy@eagletrace.ai.

12. Changes to This Policy

We may update this Privacy Policy periodically. We will notify you of material changes by email and by prominently posting a notice on the Platform before the changes take effect. The "Effective Date" at the top indicates when the policy was last revised.

13. Contact Us

For privacy-related inquiries, to exercise your rights, or to reach our Privacy Team:

© 2026 EagleTrace, Inc. Financial Service Center is a product of EagleTrace, Inc.