PRIVACY NOTICE

Effective: July 1, 2022

• Overview
• Information We Collect
  • How We Use Nonpublic Commercial Information
  • How We Obtain Nonpublic Commercial Information
  • Who We Share Nonpublic Commercial Information With
• Your Rights
• Your Choices
  • Communications Opt-Out
  • Cookies, Web Tracking, and Advertising
• Protecting Information
• Retention of Information
• Other Important Information
  • Children
  • Business Transfer
  • Do Not Track
• Modifications and Updates to this Privacy Notice
• Applicability of this Privacy Notice
• Additional Information and Assistance

Alternative Capital Solutions (and its affiliates, collectively, “ACS,” “we,” “us,” “our”) respects your privacy and is committed to protecting the information we collect, store, use, and hold related to our website users and applicants (collectively, “you” or “your”) that access our business financing products and services.  If you have questions, comments, or concerns about this Privacy Notice, please see the bottom of this Privacy Notice for information about how to contact us.

This Privacy Notice explains our practices with respect to information we collect and process about you. This includes information we collect through, or in association with, our website located at www.acsfund.com (the “Site”) and our apps that we may provide, our business financing products and services that we may offer from time to time via our website and/or related apps, our related social media sites, or otherwise through your interactions with us (the website, apps, products, services, and social media pages, collectively, the “Services”).

Please review the following to understand how we process and safeguard information about you. By using any of our Services, whether by visiting our website or otherwise, and/or by voluntarily information to us, you acknowledge that you have read and understand the practices contained in this Privacy Notice.  This Privacy Notice may be revised from time to time, so please ensure that you check this Privacy Notice periodically to remain fully informed.

Information We Collect

We may collect nonpublic commercial information from you, which includes but is not limited to: (i) company name; (ii) tax identification number; (iii) financial statements; and (iv) information about officers, directors, and other control persons.

1. 1. How We Use Nonpublic Commercial Information

In connection with your use of the Services, we collect certain nonpublic commercial information for the following purposes:

1. Providing, performing or facilitating transactions that you request.
2. Communicating with you for customer service, to provide you with updates or information relating to the Services.
3. Marketing our Services to you, including sending you messages about the Services we offer, which may include special offers for Services.
4. Complying with applicable laws, regulations, rules, and requests of relevant law enforcement and/or other governmental agencies, or for other purposes, as permitted or required by law.
5. As necessary or appropriate to protect the rights, property, and safety of our users, us, and other third parties.

1. 1. How We Obtain Nonpublic Commercial Information

We collect nonpublic commercial information from the following categories of sources:

• Directly from you. When you provide it to us directly whether online, by email, phone, or in-person, we may collect:
  • Information about your directors, officers, principals, and managers (including but not limited to, full name, address, title, email address, phone number);
  • Business information (including but not limited to, EIN, business name, business address, business email, business telephone number, company structure, business plans);
  • Assets, income and other financial information (including but not limited to, financial statements and account balances); and
  • Content in applications or other forms you provide to us.

•  
• Automatically or indirectly from you. For example, through logging and analytics tools, cookies, and as a result of your use of and access to the Services, or through your interactions with us on social media websites.

From our service providers. For example, credit-related information from credit reporting agencies and other service providers we engage about you and your officers, directors, and other control persons.

• From our affiliates. 

1. 1. Who We Share Nonpublic Commercial Information With

We may share nonpublic commercial information among and between all of its affiliates. We may share nonpublic commercial information with our nonaffiliated third parties such as service providers for routine business reasons. For example, we may disclose nonpublic commercial information to service providers and other third parties as necessary to facilitate a transaction, or to report to credit bureaus.

We may also share your nonpublic commercial information with other nonaffiliated third parties when permitted or required to do so by law; in response to a request from a law enforcement agency or authority or any regulatory authority; and/or to protect the integrity of the Services or our interests, rights, property, or safety, and/or that of our users and others.

Further, we may disclose nonpublic commercial information to our regulators without any prior notification or any other .

Your Rights

You have certain rights regarding the collection and processing of your information. You may exercise these rights, to the extent they apply to you, by contacting us at the information provided at the end of this Privacy Notice, or by following instructions provided in this Privacy Notice or in communications sent to you. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Your Choices

You have choices about certain information we collect about you, how we communicate with you, and how we process certain nonpublic commercial information. When you are asked to provide information, you may decline to do so; but if you choose not to provide information that is necessary to provide some of our Services, you may not be able to use those Services. In addition, it is possible to change your browser settings to block the automatic collection of certain information.

1. Communications Opt-Out. You may opt out of receiving marketing or other communications from us at any time through a given communications channel by following the opt-out link or other unsubscribe instructions provided in any email message received [or by contacting us as provided at the end of this Privacy Notice].
   
   Note that if you do business with us in the future, you may not, subject to applicable law, opt out of certain automated notifications, such as order confirmations, based on business transactions (e.g., e-commerce).
2. Cookies, Web Tracking, and Advertising. It is possible to change your browser settings to block the automatic collection of certain information. Please note that disabling or removing cookies may prevent the Services, or certain functionality on the Services, from working correctly or at all.

Protecting Information

We use reasonable and appropriate physical, technical, and organizational safeguards designed to promote the security of our systems and protect the confidentiality, integrity, availability, and resilience of nonpublic commercial information. However, no method of safeguarding information is completely secure. While we use measures designed to protect nonpublic commercial information, we cannot guarantee that our safeguards will be effective or sufficient. In addition, you should be aware that Internet data transmission is not always secure, and we cannot warrant that information you transmit utilizing the Services is or will be secure.

Retention of Information

We retain information to the extent we deem necessary to carry out the activities described above, including but not limited to compliance with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies, and to the extent we reasonably deem necessary to protect our and our partners’ rights, property, or safety, and the rights, property, and safety of our users and other third parties.

Other Important Information

1. Children under 18 years of age are not permitted to use the Services, and we do not knowingly collect information from children under the age of 18. By using the Services, you represent that you are 18 years of age or older, or are 18 years of age or older and have valid parental consent to do so.
2. Business Transfer. We may, in the future, sell or otherwise transfer some or all of our business, operations or assets to a third party, whether by merger, acquisition or otherwise. The information we obtain from or about you via the Services may be disclosed to any potential or actual third-party acquirers and may be among those assets transferred.
3. Do Not Track. We may use analytics systems to assess your online activities over time and across third-party websites or online services, and these systems and providers may provide some of this information to us. We do not currently process or comply with any web browser’s “do not track” signal or similar mechanisms.

Modifications and Updates to this Privacy Notice

This Privacy Notice replaces all previous disclosures we may have provided to you about our information practices with respect to the Services. We reserve the right, at any time, to modify, alter, and/or update this Privacy Notice, and any such modifications, alterations, or updates will be effective upon our posting of the revised Privacy Notice. Your continued use of the Services following our posting of any revised Privacy Notice will constitute your acknowledgement of the amended Privacy Notice.

Applicability of this Privacy Notice

This Privacy Notice is subject to the Terms and Conditions that govern your use of the Services. This Privacy Notice applies regardless of the means used to access or provide information through the Services.

This Privacy Notice does not apply to information from or about you collected by any third-party services, applications, or advertisements associated with, or websites linked from, the Services. The collection or receipt of your information by such third parties is subject to their own privacy policies, statements, and practices, and under no circumstances are we responsible or liable for any third party’s compliance therewith.

Additional Information and Assistance

If you have any questions or concerns about this Privacy Notice, please contact us at:

Crescendo ACS LLC
8 Wright Street
Suite 140
Westport, CT 06880
info@acsfund.com