Privacy Policy

4. How We Use Information
 

Resolute Direct Capital may use collected information for legitimate business purposes, including:
 

• Reviewing loan inquiries

• Evaluating commercial real estate transactions

• Determining whether a deal fits RDC’s lending parameters

• Communicating with borrowers, brokers, sponsors, developers, and advisors

• Requesting additional documents or clarification

• Conducting preliminary credit review

• Conducting underwriting and diligence

• Reviewing collateral, value, lien position, title, and use of proceeds

• Evaluating sponsor strength and repayment strategy

• Coordinating with legal counsel, title, escrow, appraisal, valuation, environmental, insurance, and other third-party providers

• Preparing preliminary terms, engagement letters, commitment letters, or transaction documents

• Managing broker relationships and broker submissions

• Preventing fraud, misrepresentation, unauthorized submissions, and improper use of the website

• Maintaining business records

• Improving our website, forms, content, and user experience

• Responding to inquiries

• Complying with legal, regulatory, contractual, or diligence obligations

• Protecting RDC’s rights, property, business interests, and legal position
   

5. How We Share Information
 

We do not sell borrower loan files as consumer data. However, in the ordinary course of reviewing, structuring, underwriting, documenting, or closing commercial real estate transactions, we may share information with appropriate parties when necessary or useful for transaction review.
 

We may share information with:
 

• RDC team members, employees, contractors, consultants, and representatives

• Affiliated or related companies

• Capital sources, lending partners, funding partners, or credit participants

• Legal counsel

• Title companies

• Escrow agents

• Closing agents

• Appraisers

• Valuation consultants

• Environmental consultants

• Insurance providers

• Background, litigation, or due diligence providers

• Servicing providers

• Accounting, compliance, or administrative service providers

• Technology vendors and website service providers

• CRM, email, hosting, storage, analytics, security, or form-processing providers

• Brokers, advisors, or borrower representatives involved in the transaction

• Government authorities, regulators, courts, or law enforcement when required or appropriate

• Other parties with your consent or as necessary to evaluate, structure, document, service, enforce, or close a transaction
   

Any such sharing is intended to support commercial loan review, underwriting, diligence, documentation, closing, servicing, compliance, fraud prevention, business operations, or legal protection.
 

6. Third-Party Service Providers
 

We may use third-party service providers to operate the website, collect form submissions, process document uploads, store files, send email, analyze traffic, protect against spam or abuse, manage business records, and support transaction review.
 

These providers may process information on our behalf. Their use of information may be governed by their own privacy policies, terms, and security practices.

Examples may include website hosting providers, form processors, file storage platforms, analytics providers, email systems, CRM tools, spam protection tools, and other business technology vendors.
 

7. Cookies, Analytics, and Tracking Technologies
 

Our website may use cookies, pixels, tags, analytics tools, or similar technologies to:
 

• Operate the website

• Remember user preferences

• Improve website performance

• Understand traffic and visitor behavior

• Measure marketing effectiveness

• Protect against spam or misuse

• Improve website content and user experience
   

You may be able to adjust your browser settings to block or delete cookies. However, some website features may not function properly if cookies are disabled.
 

If we use analytics or advertising tools, those third parties may collect information about your browser, device, and interactions with our website. Their collection and use of information may be subject to their own privacy policies.
 

8. Data Rooms and External File Links

Borrowers, brokers, or sponsors may provide data room links, cloud storage links, file-sharing folders, or external documents. RDC may access and review those materials for transaction evaluation.
 

You are responsible for ensuring that you have the authority to share any data room, file, or document with RDC. RDC is not responsible for the security, privacy, or access controls of third-party data room platforms or file-sharing services.
 

9. Confidentiality of Submitted Information
 

We understand that commercial real estate loan submissions may include sensitive business, financial, collateral, ownership, or transaction information. We use reasonable business practices to limit access to submitted information to people and parties involved in reviewing, evaluating, structuring, documenting, or closing a transaction.
 

However, submitting information through this website does not create an attorney-client privilege, fiduciary relationship, exclusive relationship, or formal confidentiality obligation unless separately agreed in a signed written agreement.
 

If your transaction requires a non-disclosure agreement or special confidentiality arrangement, that must be discussed and documented separately.
 

10. Information Security

We use reasonable administrative, technical, and organizational measures designed to protect information against unauthorized access, misuse, loss, alteration, or disclosure.

However, no website, email system, file transfer, data storage system, or internet transmission is completely secure. You submit information at your own risk.
 

If you need to provide highly sensitive information, consider contacting us first to determine the most appropriate method for transmission.
 

11. Data Retention
 

We may retain information for as long as reasonably necessary to:
 

• Review loan requests

• Maintain business records

• Document communications

• Support underwriting or transaction decisions

• Manage broker relationships

• Comply with legal, regulatory, contractual, accounting, tax, or operational obligations

• Resolve disputes

• Prevent fraud or misuse

• Protect RDC’s rights and interests
   

If a transaction does not proceed, we may still retain submission materials and related communications for business recordkeeping, compliance, legal protection, fraud prevention, and future reference unless deletion is required by applicable law.
 

12. Accuracy and Authorization
 

By submitting information to RDC, you represent that:
 

• The information is accurate and complete to the best of your knowledge

• You have authority to submit the information

• You are not violating any confidentiality obligation, law, agreement, or third-party right

• Any third-party information you provide is being submitted with appropriate authorization

• The transaction is being submitted for business-purpose commercial real estate financing

RDC may decline or discontinue review if information appears inaccurate, incomplete, misleading, unauthorized, or inconsistent.
 

13. Email and Business Communications
 

By submitting your contact information, you authorize RDC to contact you by email, phone, text message, or other reasonable communication methods regarding:

• Your loan inquiry

• Your broker submission

• Additional documentation

• Transaction review

• Follow-up questions

• Potential financing structure

• RDC services

• Business updates related to your inquiry
   

You may opt out of non-essential marketing communications, but we may still contact you regarding active inquiries, transaction review, legal matters, servicing, compliance, or administrative issues.
 

14. Children’s Privacy
 

This website is intended for adults and business-purpose commercial real estate market participants. It is not directed to children under the age of 13, and we do not knowingly collect personal information from children.
 

If we learn that we have collected personal information from a child without appropriate consent, we will take reasonable steps to delete that information.
 

15. California Privacy Notice
 

This section applies to California residents to the extent the California Consumer Privacy Act, as amended by the California Privacy Rights Act, or other applicable California privacy laws apply to RDC.
 

California privacy rules may give eligible California residents rights regarding personal information, including rights to know, access, delete, correct, and opt out of certain uses of personal information, depending on the business, context, and applicable legal thresholds.
 

A. Categories of Personal Information We May Collect

Depending on your interaction with us, we may collect the following categories of personal information:

• Identifiers, such as name, email address, phone number, business address, IP address, and online identifiers

• Commercial information, such as loan request details, transaction details, property information, broker relationship information, and submitted documents

• Professional or employment-related information, such as company name, job title, role, broker status, sponsor role, or business affiliation

• Financial information, such as loan amount, existing debt, payoff information, financial statements, bank statements, property income, operating statements, and transaction materials

• Internet or network activity, such as website usage, device information, browser information, and analytics data

• Geolocation information, such as approximate location inferred from IP address

• Inferences or internal notes related to commercial loan review, transaction evaluation, underwriting, or business communications
   

B. Purposes for Collection

We may collect and use this information for:

• Loan inquiry review

• Commercial loan underwriting

• Transaction diligence

• Broker relationship management

• Communication

• Fraud prevention

• Legal and compliance purposes

• Website operation and analytics

• Business recordkeeping

• Transaction documentation and closing support
   

C. Categories of Information We May Disclose

We may disclose the categories listed above to:

• RDC personnel and representatives

• Capital sources and lending partners

• Legal counsel

• Title and escrow providers

• Appraisers and diligence providers

• Consultants and service providers

• Technology vendors

• Brokers or transaction representatives

• Government or legal authorities where required or appropriate
   

D. Sale or Sharing of Personal Information

RDC does not sell borrower loan files for consumer marketing purposes. However, some website analytics, advertising, or tracking tools may be considered a “sale” or “sharing” under certain privacy laws if they involve cross-context behavioral advertising or certain third-party tracking activities.
 

If applicable law requires a separate opt-out mechanism, RDC will provide the required method for exercising those rights.
 

E. California Privacy Rights

Subject to applicable law and verification, eligible California residents may have the right to:

• Request access to personal information collected about them

• Request categories of personal information collected, used, disclosed, sold, or shared

• Request deletion of personal information

• Request correction of inaccurate personal information

• Opt out of certain sales or sharing of personal information

• Limit use of sensitive personal information, where applicable

• Not be discriminated against for exercising privacy rights
   

F. How to Submit a California Privacy Request

To submit a privacy request, contact us using the information below:

Resolute Direct Capital
Email: info@resolutedirectcapital.com
Phone: (510) 224-5433
Mail: 1999 Harrison St, Oakland, CA 94612
 

We may need to verify your identity and authority before processing a request. If you are submitting a request on behalf of someone else, we may request proof of authorization.
 

16. Other State Privacy Rights
 

Residents of certain states may have privacy rights under applicable state privacy laws, depending on the nature of the information, the relationship, and whether legal thresholds apply.
 

Where applicable, you may have the right to request access, correction, deletion, portability, or opt-out of certain processing activities. To exercise any available rights, contact us using the information listed in this Privacy Policy.
 

17. Financial Privacy Considerations
 

Because RDC reviews commercial real estate financing requests, submissions may include financial, property, entity, guarantor, ownership, and transaction information. This information may be shared as reasonably necessary with parties involved in underwriting, diligence, funding, legal review, documentation, servicing, or closing.
 

Any transaction-specific confidentiality or privacy obligations should be addressed in the applicable engagement letter, commitment letter, loan documents, non-disclosure agreement, or other written agreement.
 

18. Do Not Track and Global Privacy Controls
 

Some browsers offer “Do Not Track” signals. Because there is not a uniform industry standard for responding to these signals, our website may not respond to all Do Not Track requests.
 

Where required by applicable law, we will make reasonable efforts to recognize and honor legally required opt-out preference signals, such as Global Privacy Control, if applicable to our website and data practices.
 

19. International Visitors
 

Resolute Direct Capital is based in the United States and focuses on commercial real estate financing in the United States. If you access this website from outside the United States, you understand that information may be processed, stored, and used in the United States, where privacy laws may differ from those in your jurisdiction.
 

20. Links to Third-Party Websites
 

This website may contain links to third-party websites, platforms, data rooms, social media pages, analytics tools, payment processors, or other external resources. We are not responsible for the privacy practices, security practices, content, or policies of third-party websites or services.
 

You should review the privacy policies of any third-party website or platform you use.
 

21. Changes to This Privacy Policy
 

We may update this Privacy Policy from time to time to reflect changes in our business practices, website features, legal requirements, technology, or privacy procedures.

The updated version will be posted on this page with a revised “Last Updated” date. Continued use of the website after changes are posted means you acknowledge the updated Privacy Policy.
 

22. Contact Us
 

For privacy questions, requests, or concerns, please contact:

Resolute Direct Capital
Resolute Direct Capital Management LLC
1999 Harrison St
Oakland, CA 94612
Phone: (510) 224-5433
Email: info@resolutedirectcapital.com
Website: www.resolutedirectcapital.com
 

23. Final Notice

This Privacy Policy is intended to explain how RDC may collect, use, disclose, and protect information in connection with website use, commercial loan inquiries, broker submissions, and transaction review.
 

Submitting a loan request, form, document, or communication through this website does not constitute loan approval, a commitment to lend, a fiduciary relationship, or an official term sheet. All loan requests remain subject to underwriting, collateral review, sponsor review, title review, third-party diligence, legal review, final credit approval, and capital availability.