Privacy Policy

1. Introduction

Spectra Lending, LLC (“Spectra Lending”) and its affiliates, including its affiliate Spectra Holdings, LLC and Spectra Capital, LLC (collectively, “Spectra,” “we,” “us” or “our”), recognize that you may be concerned about our collection, use, and disclosure of your personal information. We respect your privacy and are committed to providing a transparent notice of our privacy practices. The following Privacy Policy is designed to inform you, as a visitor or user of our websites that display or link to this policy, including without limitation spectralending.com (the “Website”), of the types of information that we collect from you in connection with your use of the Website, and how that information may be used and disclosed.

This Policy governs your activities on the Website, information we may obtain from you through emails and phone, and any indirect sources. Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. This policy may change from time to time (see “Changes to this Privacy Policy”).

Borrower Portal

Borrowers, brokers, and sponsors may access our borrower portal, which is a private section of our Website. This Policy applies to our borrower portal.

2. Personal Information Collection and Use

We may collect several types of information from and about you, including:

• Information provided by you, such as name, address, email address, telephone number, and other personally identifying information; as well as information you provide when you communicate with us, such as by text messaging. For example, we collect information from you when fill out a webform on the Website.
• Information collected automatically as you navigate through the Website. Like most website, the Website gathers technical usage and other information from website visitors. Information collected automatically may include usage details, domain address, IP addresses, internet browser, operating system, your internet connection, the equipment you use to access our Website, and information collected through cookies.

Accordingly, we may use the information collected above for the following purposes:

• To allow you to participate in interactive features on our Website and to personalize our Website for you to ensure content from the Website is presented in the most effective manner for you and your device;
• To provide you with information or services that you request from us
• Allow the user to navigate or browse through the Website quickly and efficiently;
• Improve user experience, such as by personalizing content to the user’s interests;
• Monitor and analyze trends, usage, and activity in connection with our Website and services to improve the Website;
• Administer the Website and for internal operations, in order to conduct troubleshooting, data analysis, testing, research, statistical and survey analysis;
• Keep the Website safe and secure;
• Measure and understand the effectiveness of the content we serve to you and others, including developing reports regarding pages visited;
• To work with marketing partners to provide you with products or services that may be of interest to you;
• To enable communications with you regarding our services through email, text message, and phone;
• To provide you with notices about your account and to improve customer service;
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us;
• Verify the user’s eligibility to access the restricted areas of our Website;
• Provide users with customer support;
• To fulfill any other purpose for which you provide it and in any other way We may describe when you provide the information; and
• For any other purpose with your consent.

3. Cookies and other Tracking Technologies

Our Website may use first-party and third-party "cookies" and other tracking technologies to enhance user experience. These technologies are used for record-keeping purposes, for analytical purposes of our users, including how they use the website, and to provide interest-based advertising and other content our users may be interested in. Cookies are small files that a website places on a user’s hard drive through their web browser. Users may choose to set their web browser to refuse cookies, or to alert you when cookies are being sent. If you choose to refuse cookies, please note that some parts of the Website may not function properly as a result.

Further, if you log into the private section of our Website through the Investor Portal, we track your navigation with a session identification number within that section using an additional cookie.

4. Disclosure of Your Personal Information

General Disclosures

We may share your information with selected recipients for certain purposes, including:

• Subsidiaries and affiliates
• Business Partners for the purpose of administering the investor portal.
• Recruitment providers and consultants that use your personal information to assist us in candidate recruitment.
• Email management services to send you notifications about corporate events or other marketing-related communications (where you have asked to be notified).
• Service providers and other third parties that perform certain services on our behalf, such as:
  • Processing and storing data, including your personal information;
  • Tracking, analyzing, and modifying our website;
  • Marketing, advertising, and distribution;
  • Providing you with customer support; and
  • Supporting our IT and security efforts.

Our service providers are not permitted to sell, transfer, or use your personal information gathered on this Website other than in accordance with this Privacy Policy.

• All above exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
• To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.
• To fulfill the purpose for which you provide it. For example, to process your inquiry regarding a pre-qualification request.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may disclose aggregated information about our users and deidentified data or information that does not identify an individual.

Third-Party Lenders

If you submit information to us in connection with a request for a loan or other financing, and we cannot or choose not to fund your transaction, we may share your personal information with other lenders or financial institutions in order to explore alternative funding options on your behalf. In such instances:

1. We only share information relevant to evaluating your eligibility for financing.
2. We take reasonable measures to ensure that your personal information is handled securely and in accordance with this Privacy Policy.
3. Once your personal information is shared with a third-party lender, it will be governed by that lender’s privacy policy and data protection practices, which may differ from ours.
4. If you would prefer that we not share your information in this manner, please contact us at legal@spectracapital.com.

Fraud Prevention and other Preventative Measures

We may disclose user information when we believe disclosure is necessary to investigate, prevent, or respond to suspected illegal or fraudulent activity; to protect the safety, rights, or property of the company, our users, or others; or to exercise or protect our legal rights or defend against legal claims.

Law Enforcement and Litigation

To the extent permitted by law, any information collected over our Website or concerning its use may be disclosed to government authorities or third parties pursuant to a court order, legal or regulatory request, subpoena, or other legal process. We may also use or disclose your information as permitted by law to protect the rights or property of Spectra, our customers, our Website, its users, or third parties, or when we otherwise believe in good faith that the law requires it.

Change in Corporate Control

If Spectra undergoes a corporate change in control resulting from, for example, a sale or merger with another entity, or if all or a portion of our assets are sold, Spectra reserves the right to transfer your personal information to the new party in control or the party acquiring assets.

5. Links to Third-Party Sites

Third parties are under no obligation to comply with this Privacy Policy if you provide information directly to those third parties. Spectra neither owns nor controls third-party websites accessible through the Website. Therefore, before visiting a third-party website and before providing any Personal Information or other information to any third party, users should review the privacy policies and practices of the third party responsible for that website.

6. How Do We Protect Information Collected on This Site?

We have established certain reasonable electronic and administrative safeguards and take reasonable precautions to protect the personal information in our possession from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. However, no Internet transmission is ever 100% secure or error-free due to the inherent nature of the Internet as an open global communications vehicle. We cannot guarantee that information, during transmission through the Internet or while stored on our system or otherwise in our care, will be safe from unauthorized intrusion by third parties, such as hackers.

You transmit information to us at your own risk. While we strive to protect visitors’ personal information, we cannot ensure or warrant the security of any information you transmit.

If you submit your email address or other personal information to us via our Website while requesting information or contacting someone at Spectra, or by registering and logging in to the private section of the Website, we will use this information only to the extent necessary to respond to your request(s) and as described in this Privacy Policy. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

7. Where Do We Store Your Personal Information?

Please be aware that this Website is hosted in the United States, and some Spectra companies and contractors who process your personal information are located in the United States or in other countries.

8. How Long Do We Store Your Personal Information?

We will retain your personal information as follows:

• If you give us your Personal Information via the Contact Us page, we will keep your data on the Spectra email system for seven (7) years.
• Personal Information from cookies using Google Analytics will be kept for two (2) years.
• We retain information from other cookies for 24 hours.

9. Do Not Track

We do not respond to web browser “do not track” signals or other mechanisms. Other parties may collect personally identifiable information about your activities over time and across different websites when a consumer uses our Website.

10. Children

This Website is not intended for users under the age of 18. We do not knowingly collect any personal information from children under 18. If we become aware that an individual submitting information is under 18, we will attempt to delete the information as soon as possible.

11. Changes to This Privacy Policy

We reserve the right, in our sole discretion, to modify, alter, or otherwise update this Policy at any time. We will post the revised policy with the date it was revised on this page located at the top of this Policy. Any revised Privacy Policy will apply only to information collected after such time as the revised Privacy Policy takes effect, not to information collected under any earlier Privacy Policies. We encourage you to periodically review this Privacy Policy to stay informed about any changes.

12. How Can You Contact Us?

If you would like to contact us about this Policy or our Website, please reach out to us info@spectralending.com. You can also write to our legal team at legal@spectracapital.com.