This website is owned and operated by MLConsultant Services, LLC ("ML Services"). We atML Services respect and protect the privacy of visitors to our websites and the privacy ofour customers. We have developed this Privacy Policy to demonstrate our commitment toprotecting your privacy. Except where otherwise noted, this Privacy Policy applies to anddescribes our information handling practices when you access our services, which includeour content located on this website or any other websites, pages, features, or content weown or operate (collectively, the "Site(s)") or third-party applications relying on API, andrelated services (referred to collectively hereinafter as "Services").
These Sites are general audience websites and we do not knowingly collect personal orother information from children under the age of 18. If you are under the age of 18, please donot use our site. If we suspect that information provided to us is, in fact, personalinformation of an individual younger than 18 years of age, such information will be deleted,aggregated, or anonymized as soon as possible. Please notify us if you know of anyindividuals under the age of 18 using our services so we can take action to prevent access toour services.
ML Services is a small business marketplace to assist small businesses in accessing andmanaging capital. Our Privacy Policy applies to everyone who utilizes our Sites.
Important Privacy Commitment: We do not sell, share, or rent your personal informationto third parties for marketing or promotional purposes. This includes, but is not limited to,your phone number, SMS opt-in data, email address, and any mobile information collectedthrough our messaging program. Mobile information collected for the purpose of providingSMS or text message communications will not be shared with third parties or affiliates formarketing or promotional purposes under any circumstances.
We encourage you to review the ML Services Terms of Use. Where we require your consentto process your personal information, we will ask for your consent to the collection, use, anddisclosure of your personal information as described further below. We may provideadditional "just-in-time" disclosures or information about the data processing practices ofspecific Services. These notices may supplement or clarify our privacy practices or mayprovide you with additional choices about how we process your data.
We collect several types of information about you and your business when you access our Sites.
Our Sites collect information that identifies, relates to, describes, references, is reasonablycapable of being associated with, or could reasonably be linked, directly or indirectly, with aparticular consumer, household, or device ("Personal Information"). Personal Informationdoes not include:
To establish an account and access our Services, we will ask you to provide us with someimportant information about you. This information is either required by law (e.g. to verifyyour identity), necessary to provide the requested services (e.g. you will need to providethree (3) months of bank statements), or is relevant for certain specified purposes,described in greater detail below. As we add new features and Services, you may be askedto provide additional information.
Please note that we may not be able to serve you at all, or our Services may be degraded, ifyou choose not to share certain information with us.
The documents and information collected are securely stored and safeguarded. To fulfillour service obligations to you, you provide your permission to share any and all informationprovided to or obtained by ML Services on your behalf with lenders, with other businesseswho may need this information to fulfill their services to ML Services, for ML Servicesbusiness purposes, or to fulfill regulatory or other legal requirements. Under nocircumstances will we disclose, transmit, or share these documents without yourpermission, unless being disclosed pursuant to legal and regulatory requirements whichprohibit this notification.
We collect information about your computer's interactions with our Sites for a variety ofpurposes.
We receive and store certain types of information automatically whenever you interact withthe Sites or use the Services. This information helps us address customer support issues,improve the performance of our Sites and applications, provide you with a streamlined andpersonalized experience, and protect your account from fraud by detecting unauthorizedaccess. Information collected automatically includes:
We may automatically receive and record the following information on our server logs:
We may also use identifiers to recognize you when you access our Sites via an external link,such as a link appearing on a third-party site.
We may obtain the following types of information about you from third party sources asrequired or permitted by applicable law. These sources may include:
We may use data we have anonymized and aggregated for any business purpose.Anonymization is a data processing technique that removes or modifies personalinformation so that it cannot be associated with a specific individual. Except for thissection, none of the other provisions of this Privacy Policy applies to anonymized oraggregated customer data.
ML Services may use anonymized or aggregate customer data for any business purpose,including to better understand customer needs and behaviors, improve our products andservices, conduct business intelligence and marketing, and detect security threats. We mayperform our own analytics on anonymized data or enable analytics provided by thirdparties.
Types of data we may anonymize include transaction data, click-stream data, performancemetrics, and fraud indicators. Should you request that your information be deleted inaccordance with the policies set forth below, your information will be anonymized oraggregated, which complies with applicable law regarding deletion of personal information.
We obtain information about you during the application process, and also through yourinteractions with our Sites.
We obtain the categories of personal information listed below from the following sources:
During the Application Process: To process your initial application for funding, we mayrequire your name, address, phone number, email address, and other personal information.We may also require the name of your business, its address, its federal and state Tax ID, thetype of business, business location, average monthly sales, state of incorporation, and nameof landlord. Such information is used primarily to process your order or as otherwisedescribed herein. This is information you provide to us through our Sites.
Emails and Telephone Calls: We require an email address from you when you register forour services. We use your email for both transactional (e.g., application status, applicationupdates, application confirmation) and promotional (e.g., newsletters, new productofferings, event notifications, special third-party offers) purposes. Email messages we sendyou may contain code that enables our database to track your usage of the emails, includingwhether the email was opened and what links (if any) were clicked. If you would rather notreceive promotional emails from us, please see the section below labeled "Choice/Opt-Out".We reserve the right to send you certain communications relating to ML Services, such asservice announcements and administrative messages, without offering you theopportunity to opt out of receiving them. We may also contact you by telephone or textmessage (including to any wireless number you may provide to us) solely in connectionwith ML Services. If you would rather not receive telephone calls or text messages from us,you may change or delete your number from your account preferences page(s), or ask to beremoved from our contact list if you receive a call or text message from us. We fully complywith the requirements of the U.S. CAN-SPAM Act, the Telephone Sales Rule, and theTelephone Consumer Protection Act (TCPA).
Log Files: Any time you visit any of our Sites, our servers automatically gather informationfrom your browser (such as your IP address, browser type, Internet service provider (ISP),referring/exit pages, platform type, date/time stamp, and number of clicks) to analyzetrends, administer the site, prevent fraud, track visitor movement in the aggregate, andgather broad demographic information. We do not share the log files externally.
SMS Messaging Program and Sample Messages: By providing your phone number andopting in, you consent to receive both transactional and marketing SMS messages from MLServices regarding your application, account, and our services. Message frequency varies.Message and data rates may apply. You can reply STOP at any time to unsubscribe, or replyHELP for assistance. Examples of the types of messages you may receive include:
Transactional message examples:
Marketing message examples:
As stated elsewhere in this Policy, we do not sell, share, or rent your phone number or SMSopt-in data to any third party for marketing or promotional purposes.
Cookies: We use "cookies" to keep track of some types of information while you are visitingour Sites or using our Services. Cookies are very small files placed on your computer, andthey allow us to count the number of visitors to our Sites and distinguish repeat visitorsfrom new visitors. They also allow us to save user preferences and track user trends. We relyon cookies for the proper operation of our Sites; therefore if your browser is set to reject allcookies, the Sites will not function properly. Users who refuse cookies assume allresponsibility for any resulting loss of functionality. We do not link the cookies to anypersonally identifiable information.
Web Beacons: "Web beacons" (also known as "clear gifs" and "pixel tags") are smalltransparent graphic images that are often used in conjunction with cookies in order tofurther personalize our Sites for our users and to collect a limited set of information aboutour visitors. We may also use web beacons in email communications in order to understandthe behavior of our customers. We do not link the web beacons to any personallyidentifiable information.
Other Sources and Third Parties: We may obtain information about you from third partiesas described in Section 1.3 above. We combine this third-party data with information wealready have about you for the purpose of providing our Services, including matching yourbusiness with appropriate lenders. We do not use this combined data for cross-contextbehavioral advertising. If you provide information about others, or if others give us yourinformation, we will only use that information for the specific reason for which it wasprovided to us.
The Sites contain links to other websites that are maintained by third parties. These thirdparties are solely responsible for their own websites and we encourage you to reach out tosuch third parties for copies of and information regarding their security practices. We donot control, and are not responsible for, the privacy and security practices of these thirdparties.
We use your information for a variety of reasons, all of which support ML Services Sites and Services.
We may disclose your personal information as required by law, to provide the Services, andfor legitimate business purposes.
We may share your personal information by disclosing it to a third party for a businesspurpose. We only make these business purpose disclosures under written contracts thatdescribe the purposes, require the recipient to keep the personal information confidential,and prohibit using the disclosed information for any purpose except performing thecontract.
No Sale of PersonalInformation: We do not sell, share, or rent your personal information toany third party for marketing or promotional purposes. This includes your phone number,SMS opt-in data, email address, contact information, and mobile information collectedthrough our messaging program. This commitment applies regardless of any otherdisclosures in this Policy and is not subject to any exception or waiver for affiliates,partners, or service providers.
You acknowledge and agree that we may disclose information you provide if required to doso by law, at the request of a third party, or if we, in our sole discretion, believe thatdisclosure is reasonable to (1) comply with the law, requests or orders from lawenforcement, or any legal process (whether or not such disclosure is required by applicablelaw), and (2) protect or defend ML Services or a third party's rights or property.
By signing up for our Services or submitting a request for a business loan product or serviceoffered on the Sites, you signify your agreement to proceed and that you are consenting,acknowledging, and agreeing to the disclosure of your information with lenders and/orbrokers within our network. This includes all information you have provided to us, suchas Social Security Numbers, bank statements, and other sensitive financial informationnecessary to fulfill our services. We will not perform a credit check without yourauthorization.
Please be aware that the lenders, brokers, and/or other service providers with whom you arematched and with whom your information is shared may retain your information, even ifyou do not enter into an agreement for their products or services. Please contact each suchparty directly regarding their privacy and information policies. If you enter into anagreement with a lender, broker, or other service provider through ML Services and makechanges to the information you have provided to us, we may share the updated informationwith such lenders, brokers, and/or service providers.
Upon completing a profile on the Site and filling out the entirety of the application, we willshare your information with third party service providers (such as lenders and brokers)with whom you are matched, solely for the purpose of fulfilling the financing services youhave requested. A list of those partners can be found on our partners page. We are notresponsible for the material of the third parties or their actions. Your information may alsobe shared with third-party contractors that provide services to ML Services and are boundby this Privacy Policy. Your information will be treated as private and confidential by suchthird parties and not used for any other purpose than you authorize.
We do not share, sell, or rent your personal information (including email or mailingaddress) with any third party for that third party's own marketing or promotional purposes.If you do not wish to receive communications from ML Services or from the lenders andbrokers you have been matched with, you can change your email preferences at any time byfollowing the steps outlined in the "Choice/Opt-Out" section below.
We share information with service providers under contract who help with parts of ourbusiness operations. Our contracts require these service providers to only use yourinformation in connection with the services they perform for us, and prohibit them fromselling your information to anyone else. Examples of the types of service providers wemay share personal information with include:
We may share information with companies or other entities that we plan to merge with orbe acquired by. You will receive prior notice of any change in applicable policies.
We may use third party analytics providers (such as Google Analytics) to help usunderstand how visitors use our Sites. These providers collect de-identified informationsuch as page views, time on site, and referral sources. We do not share personal informationwith these analytics providers for advertising purposes, and we do not use their tools forcross-context behavioral advertising.
We share information with our professional advisors who provide banking, legal,compliance, insurance, accounting, or other consulting services in order to complete thirdparty financial, technical, compliance, and legal audits of our operations or otherwisecomply with our legal obligations.
We may disclose your personal information for any purpose with which you consent.
You may choose to update, access, or delete your data. However, we may be legally requiredto retain your information to comply with the law.
You may update or access your contact information at any time by logging into youraccount and making any change or update. Any changes made will be updatedimmediately.
If you want to stop using your account, you may deactivate it. When you deactivate anaccount, your information will not be sent to any further lenders, brokers, or other thirdparties, but the information will not be deleted. By deactivating your account, you will havethe ability to restore the account in its entirety.
You may delete your account from ML Services in certain circumstances upon submitting arequest to ML Services to delete your account. In certain circumstances, ML Services islegally required to continue to maintain the information in your account. In thesecircumstances, ML Services will place your account into a deactivated status, will opt youout of all communications, and will disable your access to the account.
In the event that ML Services is able to comply with your request to delete your account,data you provide to ML Services will be retained by ML Services in a commerciallyreasonable manner and to comply with relevant lending laws. Once your account is deleted,ML Services will not share your information and will only use your data for internalresearch and ML Services marketing. Data that is retained by ML Services will be retainedfor a commercially reasonable period of time as determined by ML Services inconformance with applicable law.
We store your personal information securely throughout the life of your ML Servicesaccount. We will only retain your personal information for as long as necessary to fulfill thepurposes for which we collected it, including for the purposes of satisfying any legal,accounting, or reporting obligations or to resolve disputes. Information about our typicalretention periods is described below:
Opting out of receiving electronic communications: If you no longer wish to receivepromotional email communications from us, please follow the instructions provided inSection 7 below.
Your California privacy rights: If you are a California resident, please review our CaliforniaPrivacy Notice in Section 10 to learn more about the personal information we collect, use,and disclose, as well as your privacy rights related to your personal information under theCalifornia Consumer PrivacyAct (CCPA) and its amendment, the California Privacy RightsAct (CPRA), as well as other state laws.
We have taken steps to protect your information in a commercially reasonable manner. Wehave extensive security measures in place to protect the loss, misuse, and alteration of theinformation stored in our database. These measures include the use of industry standardencryption methods and administrative access to site data, as well as other proprietarysecurity measures which are applied to all repositories and transfers of user information.We will exercise reasonable care in providing secure transmission of information betweenyour computer and our servers, but given that no information transmitted over the Internetcan be guaranteed 100% secure, we cannot ensure or warrant the security of anyinformation transmitted to us over the Internet, and hence accept no liability for anyunintentional disclosure.
In the event of a data breach at ML Services, we will notify you as soon as reasonablypracticable. We will notify you that a breach occurred and any additional informationneeded to fulfill our obligation with breach notification laws and regulations.
Do not share your account login and/or password with any other individual. Your accountlogin and/or password is sensitive and your sharing of this information may lead toadditional exposure to your account.
You may choose to discontinue your use of our Services.
You may choose to stop receiving our newsletter or marketing emails by following theunsubscribe instruction included in these emails, or you can contact us at ml@mlconsultingsolutions.com.
You can choose not to provide us with certain information, but this will likely result in theinability to use certain features of the Site and to obtain the services and products you areseeking. As a general matter, do not post personal information on public forums. You aresolely responsible for the posting of any personal information on public forums.
If, after signing up for our Services, you decide you no longer wish to receive our Services orfuture contact from lenders, brokers, or other third parties to which your information hasbeen referred, you may cancel your account as discussed herein. Upon canceling youraccount, your information will no longer be sent to lenders, brokers, or other third parties.This does not guarantee that these lenders, brokers, or other third parties will ceasecontacting you or using your information. Please be sure to reach out to all lenders, brokers,and/or other third parties to ensure they cease contacting you.
Certain federal and state regulations require that we maintain a record of your informationfor certain periods of time. Due to these regulations, we may be unable to completely deleteyour information from our database until the time requirements of these regulations have expired.
In addition to the rights provided above, the information contained in this section appliessolely to those individuals who reside in the State of California. We adopt this notice tocomply with the California Consumer PrivacyAct of 2018 and California Privacy Rights Actof 2020 (together, the "CCPA"). Any terms defined in the CCPA have the same meaningwhen used in this Policy.
Effective January 1, 2020, pursuant to the CCPA, California residents have certain rights inrelation to their personal information, subject to limited exceptions.
ML Services may collect, or has collected, the following categories of personal informationfrom California residents within the last twelve (12) months:
Because of the overlapping nature of certain categories above, some of the personalinformation we collect may be reasonably classified under multiple categories.
Sensitive PersonalInformation: Certain of the personal information that we collect, asdescribed above, may constitute "sensitive personal information" under California law, including:
ML Services will not retain any information we collect from you for longer than isreasonably necessary for the disclosed purpose. Our determination of precise retentionperiods will be based on (i) the length of time we have an ongoing relationship with you, (ii)whether there is a legal obligation to which we are subject, and (iii) whether retention isadvisable in light of our legal position.
ML Services may collect, use, or disclose personal information about California residentsfor purposes listed in Section 3 of this Privacy Policy. The sensitive personal informationdescribed in Section 8.1 above may be used for any of these purposes.
ML Services may collect personal information about California residents from thecategories of sources listed in Sections 1.3 and 2 of this Privacy Policy.
We may disclose your personal information to the categories of service providers and thirdparties identified in Section 4 of this Privacy Policy, and in ways that are described in thatsection.
This includes disclosure of your personal information to service providers for a businesspurpose. When we disclose personal information for a business purpose, we enter acontract that describes the purpose and requires the recipient to both keep that personalinformation confidential and not to use it for any purpose except performing the contract.In the preceding twelve (12) months, we have disclosed each category of personalinformation listed in Section 8.1, including the listed sensitive personal information, for abusiness purpose.
Important Disclosure Regarding "Sale" and "Sharing" of Personal Information:
ML Services does NOT "sell" or "share" personal information, as those terms are defined by the CCPA,for purposes of cross-contextual behavioral advertising or for any othermarketing or promotional purpose. We do not use third-party advertising pixels,behavioral advertising trackers, or similar technologies that would result in the sale orsharing of your personal information.
In the preceding twelve (12) months, ML Services has NOT sold or shared any personalinformation of California residents for cross-context behavioral advertising or any otherpurpose covered by the CCPA's definition of "sale" or "sharing."
This includes, without limitation:
Should ML Services ever change this practice in the future, we will update this PrivacyPolicy and provide you with clear notice and the ability to opt out before any such "sale" or"sharing" occurs.
The CCPA provides California residents with specific privacy rights regarding theirpersonal information. If you are a California resident, you have the right to make thefollowing requests under applicable California law in relation to your personal information,subject to certain exceptions:
You can exercise your rights by contacting us at ml@mlconsultingsolutions.com or bycontacting customer service at (888) 444-6527.
Any request you submit to us is subject to an identification and residency verificationprocess as permitted by the CCPA. We will not fulfill your request unless you have providedsufficient information that enables us to reasonably verify that you are the consumer aboutwhom we collected the personal information. In order to verify you, you must provide uswith first name, last name, and email address.
Requests by authorized agents. If you are a California resident, you may designate anauthorized agent to make a request to access or a request to delete on your behalf. We willrespond to your authorized agent's request if they submit proof that they are authorized toact on your behalf, or submit evidence you have provided them with power of attorneypursuant to California Probate Code section 4000 to 4465. We may deny requests fromauthorized agents who do not submit proof that they have been authorized by you to act ontheir behalf, or are unable to verify their identity
Household data. We currently do not collect household data. If we receive a requestsubmitted by all members of a household, we will individually respond to each request. Wewill not be able to comply with any request by a member of a household under the age of 18,as we do not collect personal information from any person under the age of 18.
Responses. We will respond to your request within forty-five (45) days after receipt of aVerifiable Consumer Request for a period covering twelve (12) months and for no morethan twice in a twelve-month period. ML Services reserves the right to extend the responsetime by an additional forty-five (45) days when reasonably necessary and providedconsumer notification of the extension is made within the first forty-five (45) days.
These rights are subject to various exclusions and exceptions under California law andother applicable laws.
Direct marketing by third parties. ML Services does not disclose personal information tothird parties for their own direct marketing purposes. However, California residentsadditionally have the right to request information regarding such practices underCalifornia's "Shine the Light" law. If you are a California resident and would like to inquirefurther, please email ml@mlconsultingsolutions.com.
ML Services does not currently "sell" or "share" personal information with third partiesfor purposes of cross-context behavioral advertising, as those terms are defined by the CCPA. As such, there is no active "sale" or "sharing" of personal information to opt out of atthis time.
California residents retain the legal right to opt out of any future "sale" or "sharing" of theirpersonal information. If ML Services ever begins engaging in any practice that wouldconstitute a "sale" or "sharing" under the CCPA, we will update this Privacy Policy withprior notice and provide a clear opt-out mechanism. In the meantime, if you wish to confirmyour opt-out preference on record or have any related questions, please send an email to ml@mlconsultingsolutions.com.
Vermont residents have access to additional limits on the sharing of their personalinformation, subject to certain exceptions.
Vermont law places additional limits on sharing information about Vermont residents solong as they remain residents of Vermont. In accordance with Vermont law, we will notshare information we collect about Vermont residents to companies outside of ML Servicesexcept: (1) as permitted by law; (2) to companies that perform marketing or other serviceson our behalf; (3) name, contact, and transaction and experience information to otherfinancial institutions with which we have joint marketing agreements; or (4) with theauthorization or consent of the Vermont resident. We also will not share non-transactionalinformation about Vermont residents received from others within the ML Services familyof companies except with the authorization or consent of the Vermont resident.
We reserve the right to update this Privacy Policy and will notify you if we do so; however,we encourage you to regularly review this policy for the latest information.
We may update this Privacy Policy to reflect changes to our information practices. If wemake any material changes, we will notify you by email (sent to the email address specifiedin your account) or by means of a notice on this Site. We encourage you to periodicallyreview this page for the latest information on our Privacy Policy. When we make changes tothis Privacy Policy, we will revise the revision date at the top of the Privacy Policy.
If you have any questions about this Privacy Policy or wish to exercise one of your privacyrights, please contact us using the following information:
MLConsultant Services, LLC
601 Brickell Key Drive,
Suite 700 Miami, Florida 33131
Telephone: (888) 444-6527
Email: ml@mlconsultingsolutions.com
