Privacy Policy

1. Introduction

RevolvFi LLC (“RevolvFi,” “we,” “us,” or “our”) is a Michigan limited liability company that originates and services commercial financing products, including merchant cash advances (“MCAs”) and commercial lines of credit, to businesses.

This Privacy Policy describes how we collect, use, disclose, and protect information in connection with:

• our website at revolvfi.com (the “Site”);
• our online application, client portal, and broker/ISO portal (collectively, the “Platform”);
• our mobile applications, if and when made available; and
• our financing, servicing, marketing, and related business activities (together with the Site and Platform, the “Services”).

Our products are offered to businesses for commercial purposes, not to consumers for personal, family, or household purposes. Even so, we necessarily collect and process information about individuals — business owners, principals, guarantors, authorized signers, and employees of our applicants, clients, and partners. This Policy explains how we handle that information.

By accessing the Services or submitting information to us, you acknowledge the practices described in this Policy.

2. Scope and Who This Policy Covers

This Policy applies to information about:

• Applicants and clients — businesses that apply for or receive financing from us, and the individuals associated with them;
• Owners, principals, guarantors, and authorized representatives of applicant and client businesses;
• Broker, ISO, and referral partners and their personnel who use our Platform or submit deals to us;
• Funding, syndication, and servicing counterparties and their personnel;
• Website visitors and prospective customers; and
• Job applicants who apply to RevolvFi LLC, to the extent described in Section 13.

This Policy does not apply to the practices of third parties we do not control, including brokers or ISOs who collect your information before submitting it to us, banks and data aggregators, credit bureaus, or third-party websites linked from the Services. Those parties maintain their own privacy policies.

3. Information We Collect

3.1 Information You Provide to Us

Business information. Legal and DBA name, entity type, state of formation, EIN, physical and mailing addresses, industry and NAICS/SIC classification, time in business, ownership structure, business phone and email, website, business licenses, and landlord or lease information.

Individual information about owners, principals, and guarantors.Full name, home address, personal phone number and email address, date of birth, Social Security number or other government identifier, government-issued identification (such as a driver’s license), ownership percentage, title or role, and personal financial information provided in connection with a personal guaranty.

Financial and transactional information. Bank account and routing numbers, business bank statements, processing statements and merchant account data, revenue and deposit history, accounts receivable and payable data, tax returns, financial statements, existing debt obligations and payoff or balance letters, UCC filings, and information about prior or concurrent advances or loans.

Application and account information. Requested amount and use of proceeds, offers and term sheets, executed agreements and disclosures, payment history, remittance and ACH authorization details, collections and default information, and correspondence with us.

Communications. Emails, text messages, chat messages, portal submissions, support requests, and — where permitted by law and where notice is given — recordings or transcripts of telephone calls with our sales, underwriting, servicing, or collections personnel.

Partner information. For brokers, ISOs, syndicators, and vendors: company details, contact and personnel information, agreements, commission and payment instructions, banking details, and tax identification and W-9/W-8 information.

3.2 Information We Obtain from Third Parties

Brokers, ISOs, and referral sources. Applications, supporting documents, and contact information submitted on your behalf.

Consumer and commercial credit reporting agencies. Consumer credit reports on owners, principals, and guarantors (where authorized), and commercial credit reports and scores on the business.

Banking data and financial data aggregators.Where you connect a bank account or authorize retrieval, we and our service providers (for example, Plaid) may access account balances, transaction history, account ownership and verification details, and related information. Your use of an aggregator is also governed by that aggregator’s own privacy policy.

Payment processors and merchant acquirers. Card processing volume and settlement data, where you authorize disclosure.

Identity verification, fraud, and background screening providers. Identity confirmation, OFAC/sanctions and watchlist screening, KYC/KYB results, fraud signals, judgments, liens, bankruptcies, and litigation records.

Public records and commercial data sources. Secretary of State filings, UCC-1 filings, court and lien records, property records, business directories, and licensed marketing and lead-generation data.

Servicing and syndication partners, and prior or concurrent funders. Balance, payoff, performance, and payment history information.

3.3 Information Collected Automatically

When you use the Site or Platform, we and our service providers may automatically collect:

• IP address, approximate location derived from IP, device identifiers, browser and operating system type and version, and device settings;
• pages and screens viewed, links and buttons clicked, session duration, referring and exit URLs, form interactions, and other usage and diagnostic data;
• log data, error reports, and security telemetry; and
• information collected through cookies, pixels, tags, SDKs, session-replay tools, and similar technologies, as described in Section 8.

4. How We Use Information

We use information for the following business purposes:

Underwriting and origination — evaluating applications; verifying identity, business existence, ownership, and bank and processing activity; assessing creditworthiness, risk, and capacity; determining pricing, structure, and eligibility; preparing offers, term sheets, and agreements; and issuing approvals or declinations.

Funding, servicing, and collections — disbursing funds; initiating and managing ACH debits and remittances; maintaining account records; processing renewals, modifications, buyouts, and payoffs; monitoring performance; and pursuing collection of amounts owed, including through counsel or third-party collection agencies.

Fraud prevention, security, and compliance — detecting and preventing fraud, misrepresentation, stacking, and unauthorized activity; conducting KYC/KYB, anti-money-laundering, and OFAC screening; protecting the integrity of the Services; and satisfying legal, licensing, regulatory, examination, audit, tax, and recordkeeping obligations.

Communications — responding to inquiries; providing account, transaction, servicing, and payment notices; and delivering operational and administrative messages.

Marketing and business development — informing you about products, offers, renewals, events, and updates, subject to Section 7; measuring campaign performance; and developing and maintaining relationships with brokers, ISOs, and partners.

Analytics and product improvement — understanding usage; maintaining, testing, and improving the Site, Platform, underwriting models, and internal tools; and producing aggregated or de-identified reporting and analysis.

Corporate purposes — managing our business, syndication and capital-markets activity, insurance, accounting, and evaluating or completing financings, sales, or other corporate transactions.

Other purposes — with your consent or as otherwise permitted or required by law.

We may create de-identified or aggregated information from the data we hold and use and disclose it for any lawful purpose. We will maintain and use such information in de-identified form and will not attempt to re-identify it, except as permitted by law.

5. How We Disclose Information

We do not disclose information about you except as described below.

Affiliates. Our current and future parents, subsidiaries, and affiliated entities, for the purposes described in this Policy.

Service providers and vendors. Companies that perform services for us, including hosting and cloud infrastructure, CRM and loan origination systems, e-signature and document management, data aggregation, identity verification and fraud screening, ACH and payment processing, communications and telephony, analytics, accounting, and IT support. These parties are contractually restricted to using information only to perform services for us.

Funding, syndication, and participation partners. Investors, syndicators, participants, warehouse and credit facility lenders, and their advisors and auditors, in connection with the funding, purchase, participation, pledge, or securitization of receivables or accounts, and related diligence and reporting.

Servicers, sub-servicers, and collection agencies. Where servicing or collection activity is outsourced or a receivable is sold or assigned.

Brokers, ISOs, and referral partners. Limited information about the status, approval, decline, funding, and commission treatment of deals they submitted. We do not disclose your information to brokers or ISOs who were not involved in your transaction.

Credit reporting agencies and industry databases. Account, performance, and payment information may be furnished to commercial credit bureaus, and, where applicable and authorized, to consumer reporting agencies.

Professional advisors. Attorneys, accountants, auditors, and consultants bound by duties of confidentiality.

Legal, regulatory, and safety disclosures. Regulators, licensing authorities, examiners, law enforcement, courts, and other parties where we believe disclosure is required by law, subpoena, court order, or legal process, or is reasonably necessary to enforce our agreements, exercise our rights or remedies, investigate suspected fraud or illegal activity, or protect the rights, property, or safety of RevolvFi LLC, our clients, or others.

Business transfers. In connection with, or during negotiation of, any merger, financing, acquisition, reorganization, sale of assets, receivership, or bankruptcy, information may be transferred or disclosed as a business asset, subject to reasonable confidentiality protections.

With your direction or consent. Including at your request to a third party you designate.

5.1 Sale and Sharing of Personal Information

RevolvFi LLC does not sell personal information, and does not share personal information for cross-context behavioral advertising, as those terms are defined under applicable state privacy laws. We do not sell, rent, or trade applicant or client lead data to other funders, brokers, or marketers.

6. Legal Basis and Nature of Our Relationship

Our financing products are extended to businesses for commercial purposes. Accordingly, certain consumer financial privacy requirements — including the privacy notice provisions of the Gramm-Leach-Bliley Act and Regulation P, which apply to financial products obtained primarily for personal, family, or household purposes — may not apply to our commercial financing relationships. We nonetheless maintain this Policy and the safeguards described in Section 9 as a matter of practice.

Where we obtain a consumer credit report on an owner, principal, or guarantor, we do so in reliance on your written authorization and the permissible purposes set out in the federal Fair Credit Reporting Act. If credit is denied or terms are adversely affected based in whole or in part on information in a consumer report, we will provide the notices required by the Fair Credit Reporting Act and the Equal Credit Opportunity Act and Regulation B, to the extent applicable.

7. Communications, Calls, and Text Messages

Email. We may send you operational, transactional, and marketing emails. You may opt out of marketing emails at any time using the unsubscribe link or by contacting us at privacy@revolvfi.com. You cannot opt out of transactional and servicing messages while you have an active account or application.

Telephone. By providing a telephone number, you consent to receive calls from us and our agents at that number regarding your application, account, and servicing matters, including calls placed using automated technology or prerecorded messages where permitted by law. You may withdraw consent for marketing calls by telling us or by contacting us at privacy@revolvfi.com.

Text messages (SMS/MMS). Where you opt in, we may send text messages regarding your application, account, or (if separately authorized) marketing. Message and data rates may apply. Message frequency varies. Reply STOP to opt out or HELP for help.

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Information sharing with subcontractors in support services, such as customer service and messaging platforms, is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Call recording and monitoring. Calls with our personnel may be recorded or monitored for training, quality assurance, dispute resolution, and compliance purposes. Where required by applicable state law, we will provide notice and obtain consent before recording.

8. Cookies and Tracking Technologies

We and our service providers use cookies, pixels, web beacons, tags, and similar technologies to operate the Site and Platform, remember your preferences, authenticate sessions, maintain security, analyze traffic and usage, and — where applicable — measure and deliver advertising.

Categories we use:

• Strictly necessary — required for authentication, session management, security, and core functionality.
• Performance and analytics — such as Google Analytics, to understand how the Services are used.
• Functional — to remember settings and preferences.

Most browsers let you refuse or delete cookies through their settings. Disabling cookies may impair portions of the Services. We do not currently respond to browser “Do Not Track” signals. We do honor the Global Privacy Control (GPC) signal as a valid opt-out request from residents of states where such signals must be recognized.

9. Data Security

We maintain administrative, technical, and physical safeguards designed to protect information against unauthorized access, use, alteration, disclosure, or destruction. These include access controls and role-based permissions, encryption of data in transit and, where appropriate, at rest, network monitoring and logging, vulnerability management and periodic security assessment of our Platform, vendor due diligence, and employee confidentiality obligations and training.

No system is completely secure, and we cannot guarantee the security of information transmitted to or from us. You are responsible for maintaining the confidentiality of your Platform credentials and for all activity under your account, and you agree to notify us promptly at security@revolvfi.com of any suspected unauthorized use.

10. Data Retention

We retain information for as long as necessary to fulfill the purposes described in this Policy, including for the life of your application or account and thereafter for the period required to satisfy our legal, regulatory, licensing, tax, accounting, audit, and recordkeeping obligations; to resolve disputes; to enforce our agreements; and to pursue or defend legal claims. Retention periods vary by record type and jurisdiction and are generally not less than seven (7) years following the final payoff, charge-off, or resolution of an account. When information is no longer needed, we delete it or de-identify it in a commercially reasonable manner.

11. Your Privacy Rights and Choices

11.1 All Users

You may:

• request to review or update the information you have provided to us;
• opt out of marketing emails, calls, and text messages as described in Section 7; and
• contact us at privacy@revolvfi.com with any question or concern about your information.

11.2 Important Limitation for Commercial Relationships

Most U.S. state privacy laws — including applicable state consumer privacy laws— apply only to individuals acting in an individual or household context and expressly exclude individuals acting in a commercial or employment context. In addition, many state privacy laws exempt information collected, processed, or disclosed under the Gramm-Leach-Bliley Act or the Fair Credit Reporting Act. Because RevolvFi LLC’s financing is commercial and much of the information we hold falls within these exemptions, many statutory rights may not apply to information collected in connection with a financing application or account. We nonetheless honor the requests described below where the law requires and consider them in good faith where it does not.

11.3 California Residents

California residents have rights under the California Consumer Privacy Act, as amended by the CPRA, with respect to personal information that is not otherwise exempt. Note that California’s business-to-business exemption has expired, so information about business representatives may be covered. Subject to verification and applicable exemptions, you may have the right to:

• Know / Access — request the categories and specific pieces of personal information we collected, the sources, the business purposes, and the categories of third parties to whom it was disclosed.
• Delete — request deletion of personal information we collected from you, subject to exceptions (including our need to complete a transaction, service an account, detect fraud, and comply with legal obligations).
• Correct — request correction of inaccurate personal information.
• Opt out of sale or sharing — direct us not to sell or share personal information for cross-context behavioral advertising. See Section 5.1.
• Limit use of sensitive personal information — direct us to limit use of sensitive personal information (such as Social Security number or financial account credentials) to permitted purposes. We use sensitive personal information only for permitted business purposes, including underwriting, servicing, identity verification, fraud prevention, and legal compliance.
• Non-discrimination — not receive discriminatory treatment for exercising these rights.

How to submit a request. Email privacy@revolvfi.com, call 989.529.9486, or write to the address in Section 16. We will verify your identity before responding, generally by matching information you provide against our records. An authorized agent may submit a request on your behalf with proof of authorization and verification of your identity.

11.4 Other State Privacy Laws

Residents of states with comprehensive privacy laws — including Colorado, Connecticut, Virginia, Texas, Oregon, Montana, and others as they take effect — may have rights of access, correction, deletion, portability, and opt-out of targeted advertising, sale, and certain profiling, together with a right to appeal a denied request. To exercise these rights or appeal a decision, contact us at privacy@revolvfi.com. These rights are subject to the entity- and data-level exemptions described in Section 11.2.

11.5 Nevada Residents

Nevada residents may submit a request that we not make certain sales of covered information by emailing privacy@revolvfi.com.

12. Third-Party Sites and Services

The Services may link to or integrate with third-party websites, applications, and services, including banks, data aggregators, payment processors, and partner platforms. We do not control those parties and are not responsible for their privacy or security practices. Review their policies before providing information.

13. Job Applicants

If you apply for employment with RevolvFi LLC, we collect the information in your application, resume, and related communications, along with information from references, background screening providers, and, where applicable, assessments. We use it to evaluate your candidacy, communicate with you, and comply with employment and recordkeeping laws.

14. Children’s Privacy

The Services are directed to businesses and are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If you believe a child has provided information to us, contact us at privacy@revolvfi.com and we will take appropriate steps to delete it.

15. Changes to This Policy

We may update this Policy from time to time. When we do, we will revise the “Last Updated” date above and post the revised Policy on the Site. If we make material changes, we will provide additional notice as required by law, which may include email notice or a prominent notice on the Site. Your continued use of the Services after the effective date of a revised Policy constitutes acknowledgment of the changes.

16. Contact Us

Email: privacy@revolvfi.com
Phone: 989.529.9486