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Effective Date: December 23, 2019; Last Updated: August 5, 2025

Privacy Policy

Applicability

This policy describes how Genesis Capital, LLC, including Genesis Capital Real Estate Advisors, Inc. and Everguard Capital, LLC (each and collectively the “Company,” “we,” or “us”) and our subsidiaries and affiliated companies collect, use, disclose, and otherwise process information about you. This Privacy Policy applies to information we collect when you access or use our websites, portals, and mobile applications (collectively our “Services”) and also applies to information we collect from you when you interact with us as a customer or consumer such as through our customer support channels, or on social media. This policy does not apply to our job applicants, employees, or independent contractors.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy. If we make material changes, we will provide you with additional notice (such as by adding a statement to the Services or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

Notice At Collection

Information We Collect

The type of personal information we collect depends on your relationship with us. It also depends on how you interact with us. California law requires us to tell you if we share categories of information for cross-contextual behavioral advertising. Described below by category is the information we may collect and if we share that category of information for cross-contextual behavioral advertising. To learn how to modify your cross-contextual advertising preferences view our The type of personal information we collect depends on your relationship with us. It also depends on how you interact with us. California law requires us to tell you if we share categories of information for cross-contextual behavioral advertising. Described below by category is the information we may collect and if we share that category of information for cross-contextual behavioral advertising. To learn how to modify your cross-contextual advertising preferences view our Notice of Right to Opt-out of Sale/Sharing.

  • Contact information. We collect your name and email address. We also collect your physical address and phone number. We may also collect your company name. In some cases, we may share this information for the purpose noted above.
  • Demographic information. We may collect information like your age and date of birth. We may also collect your zip code and state. In some cases, we may share this information for the purpose noted above.
  • Financial information. We may collect information such as net worth and credit scores from individuals associated with applicants. We may collect other bank account related information from borrowers.
  • Employment information. We may collect resumes, education, and employment history from individuals associated with applicants. This includes information about your skills and qualifications for the project or position. We also collect this from job applicants.
  • Submitted information. We collect any other information you voluntarily provide to us. This may include information you submit as part of loan inquiry or application.
  • Site usage information. We may collect information about the browser you are using and your browser activity when you are visiting our site and related sites. We may also collect information about the sites you came from and where you visit when you leave us. We may also collect your operating system and IP address. We may also look at the areas of our site you visit and any actions you make. We also collect device identifiers. This might include your hardware model. In some cases, we may share this information for the purpose noted above.
  • We keep these categories of personal information as long as necessary or relevant for the purposes for which it was collected. We also keep information as required by law.

Use of Information

We use the categories of information for the business and commercial purposes outlined here:

  • We use information to communicate with you and process your application. We use information to evaluate your loan application and to facilitate ongoing transaction or account-related matters. We also use it to send you updates and to respond to your questions or to send you marketing communications (See below for more information about how to opt out of these communications at any times). We also use information to communicate with you about our policies and terms.
  • We use the information to improve products and services. We use information to improve our sites and services. This includes customizing your experience with us and developing, providing, and improving new products and services.
  • We use information for marketing purposes. We may use information to let you know about new developments or services. This may be about our offers or offerings of third parties. We also use information to provide you with newsletters or other content we think you may find interesting. We may do this by phone or email. We may also use your information to engage in interest-based advertising. This includes serving you with content on our platforms or on social media platforms. This may occur after you leave our sites or platforms and may encourage you to return. We may also serve ads that we think are relevant to you based on your browsing habits or online activities.
  • We use information to protect ourselves and others. We use information to detect, investigate, respond to, prosecute, and help protect against security incidents and other malicious, deceptive, fraudulent, or illegal activity, and help protect the rights and property of Genesis Capital, LLC and others. We may also use information to comply with our legal and financial obligations.
  • We use information as otherwise permitted by law (or as we may notify you).
More Information

For more information about our privacy practices, read below for the rest of our privacy policy.

We Collect Information In a Variety Of Ways

We collect information directly from you. We collect information if you contact us, submit an application, request customer support, or otherwise communicate with us directly or through third-party platforms. This could be in person, such as at events. It may also be over the phone or online or on a hard copy document.

We collect information automatically. We collect information about users including how you access our Services, including data about the device and network you use (such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type and app version) over time and across different websites and apps. We also work with third parties that collect personal information this way. We may use several common tracking tools to collect information such as your activity on our Services, including the route by which you access our Services, access dates and times, browsing behavior (such as pages viewed and links clicked) and information about your activity on specific pages. Tracking tools include browser cookies and web beacons. To learn more about cookies visit the FTC’s Online Tracking page. We may work with others to gather information on our platforms and elsewhere. We may do this on our websites and in emails that we send to you.

If you contact customer service by chat or by phone, we may monitor and retain those conversations, including for training purposes.

Some Genesis Capital, LLC facilities are equipped with surveillance equipment, such as cameras and CCTV, which may capture your image or information about your movements, and which may be used to protect the safety of Genesis Capital, LLC staff, visitors, and property, to monitor and troubleshoot issues with equipment or technology, or otherwise for any lawful purpose. We will ensure that any personal information generated by this monitoring is treated in accordance with this Notice.

AI Supported Systems: We may use AI supported systems for legitimate business purposes noted above, such as to improve the algorithms that power our AI systems, enabling better responses and more accurate predictions, and to monitor and prevent unauthorized or malicious activities. We may record meetings (where notice is provided) to enhance the functionality, accuracy, and reliability of our AI systems by analyzing meeting data, ensuring that our services meet high standards of quality and that interactions with our AI systems are consistent and effective, and to comply with legal obligations and ensure the security of our services. These recorded sessions may include, but are not limited to, textual data (conversations and interactions between users and our AI systems) and metadata (including information such as timestamps, user session IDs, and other related data that does not personally identify you.

We collect information about you from others. Business partners may provide information about you to us. We may also collect information from referrals or industry associations. We may collect information from data analytics providers, credit-rating services, public databases and property records.

We Combine Information

We combine information that we have collected offline with information that we collect online as permitted by law. We combine information we have collected across other third-party sites. We combine information collected across devices, such as computers and mobile devices. We also combine information that we get from a third party with information we already have.

Information We Derive

We may derive information or draw inferences about you based on the information we collect.

Analytics

We engage others to provide analytics services and perform related services across the web. To do this, Genesis Capital, LLC and these partners may use cookies, pixels, SDKs, and similar technologies to collect information about your use of our Services and other websites, including your device identifiers, IP address, web browser and mobile network information, pages viewed, time spent on pages, links clicked, order information, items added to cart, and conversion information. This information is used to analyze and track data, determine the popularity of certain content, and better understand your activity.

The activities described in this section may constitute “sharing,” or “selling” under certain privacy laws. See the Additional Information for Specific Jurisdictions section below for details.

We May Disclose Information

Below are situations when we may disclose personal information. We have also explained the categories of entities with whom we might disclose your personal information.

We also disclose aggregated or de-identified information that cannot reasonably be used to identify you. We maintain and use this information only in a de-identified fashion and will not attempt to re-identify such information, except as permitted by law.

Data Retention

We store personal information associated with your application or account for as long as your account remains active. We store other personal information for as long as necessary to carry out the purposes for which we originally collected it and for other business purposes explained in this Privacy Policy.

Your Choices

Account Information

You can access, correct, and delete certain information stored within your Genesis Capital, LLC account at any time by logging in and navigating to the User Profile menu.

Cookies and Similar Tracking Technologies

Genesis Capital, LLC uses cookies and similar tracking technologies, as described above. You can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect some of the functionality of our Services.

Communications Preferences

You may opt out of receiving promotional emails from Genesis Capital, LLC following the instructions in those communications. If you opt out, we may still send you non-promotional emails, such as those about your account.

State Level Privacy Protections

Many U.S. states, including California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, Virginia, and Washington have enacted consumer privacy laws that grant their residents certain rights and require additional disclosures (“State Privacy Laws”) in certain circumstances. As new State Privacy Laws are passed, we will extend necessary protections to our users. If you are a resident of one of these states, and that State Privacy Law applies to Genesis Capital, LLC, this section applies to you.

In the preceding 12 months, we have collected the following categories of personal information: identifiers, demographic information, commercial information, internet or other electronic network activity information, audio and visual data, and inferences. For details about the precise data points we collect and the sources of such collection, please see the Information We Collect section above.

We collect, use and disclose personal information for the business and commercial purposes described in the Use of Information section above.

In the preceding 12 months, we have made disclosures to the following categories of recipients:

Categories of Personal Information Categories of Recipients
Identifiers, such as your contact and account information Affiliates and subsidiaries, fraud prevention partners, data analytics providers, marketing partners, payment and financing processors, fulfillment partners, customer support partners, Internet service providers, operating systems and platforms, customer feedback platforms, and cloud service providers.
Demographic information Affiliates and subsidiaries, fraud prevention partners, data analytics providers, marketing partners, payment and financing processors, fulfillment partners, customer support partners, Internet service providers, operating systems and platforms, customer feedback platforms, and cloud service providers.
Financial Information Affiliates and subsidiaries, fraud prevention partners, data analytics providers, marketing partners, payment and financing processors, fulfillment partners, customer support partners, Internet service providers, operating systems and platforms, customer feedback platforms, and cloud service providers.
Employment information Employment information Affiliates and subsidiaries, fraud prevention partners, data analytics providers, marketing partners, payment and financing processors, fulfillment partners, customer support partners, Internet service providers, operating systems and platforms, customer feedback platforms, and cloud service providers.
Commercial information Affiliates and subsidiaries, fraud prevention partners, data analytics providers, marketing partners, payment and financing processors, fulfillment partners, customer support partners, Internet service providers, operating systems and platforms, customer feedback platforms, and cloud service providers.
Internet or other electronic network activity information Internet or other electronic network activity information Affiliates and subsidiaries, fraud prevention partners, data analytics providers, marketing partners, payment and financing processors, fulfillment partners, customer support partners, Internet service providers, operating systems and platforms, customer feedback platforms, and cloud service providers.
Inferences Advertising and marketing networks, data analytics providers

We collect information that is considered “sensitive” under State Privacy Laws but we do not use or disclose sensitive personal information for the purpose of inferring characteristics about you .

We do not engage in sales, sharing, or targeted advertising using personal information about consumers we know to be under the age of 16, or higher age where required by law.

As described in the Collection of Information section above, we collect personal information from various sources, including directly from you, automatically when you access or use our Services, and from third-party sources.

We retain personal information as described above

Your Rights under State Privacy Laws

Opt Out of Sales and Sharing
You may opt out of activities that we engage in that constitute “sharing,” or “sales” of personal information under the State Privacy Laws by emailing us at privacy@genesiscapital.com or calling our toll-free number at 1-800-663-2195.

Access, Correction, and Deletion
You have the right to (1) request to know more about and access your personal information, including in a portable format, (2) request deletion of your personal information, and (3) request correction of inaccurate personal information.

To request access, correction, or deletion of your personal information, please email us at privacy@genesiscapital.com or call our toll-free number at 1-800-663-2195. To authenticate your request, we may request additional information from you to verify your identity.

Nondiscrimination
You have the right not to be discriminated against for exercising any of your privacy rights.

Appeals
If we deny your request, you may appeal our decision by contacting us at privacy@genesiscapital.com or toll-free at 1-800-663-2195. If you have concerns about the result of an appeal, you may contact the attorney general in the state where you reside.

Authorized Agents
If you are an authorized agent seeking to make a request to opt out of sales, sharing, or targeted advertising on behalf of a consumer, please email us at privacy@genesiscapital.com or call our toll-free number at 1-800-663-2195.

If you reside in California, you may also designate an authorized agent to submit an access, deletion, or correction request on your behalf. We may ask authorized agents to submit proof of their authority to make a request, such as a valid power of attorney or proof that they have signed permission from the consumer who is the subject of the request. In some cases, we may contact the individual who is the subject of the request to verify their own identity or confirm the authorized agent has permission to submit the request. If you are an authorized agent seeking to make an access, correction, or deletion request on behalf of a California resident, please email us at privacy@genesiscapital.com or call our toll-free number at 1-800-663-2195.

Notice of Financial Incentives
We may provide rewards and other benefits to customers who join our loyalty program or participate in certain promotional campaigns. These offerings may constitute “financial incentives” or “bona fide loyalty programs” under State Privacy Laws (for simplicity, we refer to these offerings as financial incentives throughout this Privacy Policy).

If you decide to participate in a financial incentive, we collect relevant personal information from you, such as identifiers (like your email address or phone number) and commercial information (like your loan history).

How To Contact Us

If you have other questions about this Policy or our privacy practices please email us at privacy@genesiscapital.com.  You can also write to us at:

Genesis Capital
15303 Ventura Blvd. Suite 700
Sherman Oaks, CA 91403
Attn: General Counsel

We May Update This Policy

We may make changes or updates to this Policy. We will notify you of any material changes to this Policy as required by law. Changes will also be posted on our website. Please check our site periodically for updates.