Privacy Policy

Last updated: [DATE]

Crowdlender AI, LLC (“Crowdlender,” “we,” “us,” or “our”) operates the website at crowdlender.ai and the investor platform at app.crowdlender.ai (together, the “Platform”). This Privacy Policy explains what personal information we collect, how we use and share it, how we protect it, and the choices and rights you have. By using the Platform, you agree to the practices described here.

This Policy is intended to be read together with our Terms of Use and any offering-specific disclosures.

1. Who We Are

Crowdlender provides a technology platform through which verified, accredited investors can review and participate in private commercial real estate investment offerings made available under Regulation D, Rule 506(c) of the Securities Act of 1933. Our principal place of business is in the United States.

For privacy questions, contact us at [email protected].

2. Information We Collect

We collect the following categories of information:

Identity and verification information. When you register and complete identity verification (KYC), we and our verification provider collect your name, date of birth, government-issued identification details, and identity document images. We retain only the last four digits of your Social Security Number where required to support payment-account setup; we do not store your full Social Security Number.

Accreditation information. To verify accredited-investor status as required by Regulation D Rule 506(c), we collect the documentation and information you provide, such as income figures, supporting tax documents (which may be partially redacted), and related verification materials.

Financial and payment information. When you fund an investment, we and our payment providers collect bank-account verification data and limited bank-account details (such as institution name and the last four digits of the account), together with records of transactions and transfers.

Account and profile information. Your email address, phone number, login credentials managed by our authentication provider, and, where applicable, your digital wallet address.

Investment activity. Your commitments, subscriptions, holdings, and related communications.

Technical and usage information. Device, browser, IP address, and usage data collected automatically when you access the Platform, including through cookies and similar technologies.

3. How We Use Your Information

We use personal information to:

Create and manage your account and verify your identity and accredited-investor status;
Facilitate, process, and record investments, funding, and distributions;
Comply with legal and regulatory obligations, including securities, anti-money-laundering (AML), “know-your-customer” (KYC), and tax requirements;
Operate, secure, maintain, and improve the Platform;
Communicate with you about your account, transactions, offerings, and service updates; and
Detect, prevent, and respond to fraud, security incidents, and misuse.

4. How We Share Your Information

We do not sell your personal information. We share information only as follows:

Service providers. We share information with vendors that perform services on our behalf, under contractual confidentiality and data-protection obligations, including: identity verification (Persona), authentication (Clerk), bank-account verification (Plaid), payment and ACH processing (Dwolla), database and hosting infrastructure (Supabase and Vercel), and transactional email delivery (Resend).

Issuers, sponsors, and administrators. Where you invest in an offering, we share information necessary to administer your investment with the relevant issuing entity and its administrators.

Legal and compliance. We may disclose information to regulators, law enforcement, or other parties where required by law, regulation, legal process, or to protect rights, safety, and the integrity of the Platform.

Business transfers. In connection with a merger, acquisition, financing, or sale of assets, information may be transferred as part of that transaction, subject to this Policy.

5. Cookies and Tracking

We use cookies and similar technologies to keep you logged in, remember preferences, secure the Platform, and understand usage. You can control cookies through your browser settings; disabling some cookies may affect Platform functionality.

6. Data Security

We protect personal information using administrative, technical, and physical safeguards. Data is encrypted in transit using industry-standard TLS (1.2 or higher) and encrypted at rest by our infrastructure providers. We apply least-privilege access controls, verify the integrity of integrations, and limit the most sensitive data we store. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

7. Data Retention

We retain personal information only as long as necessary for the purposes described in this Policy and to meet our legal obligations. Certain records — including identity, accreditation, investment, and transaction records — are subject to multi-year retention requirements under securities and AML laws. Where a legal retention obligation applies, that obligation governs and may require us to retain records even after you request deletion. When data is no longer required, we delete or anonymize it.

8. Your Privacy Rights

Depending on your state of residence, you may have rights to access, correct, delete, or obtain a copy of your personal information, and to limit certain uses. For California residents, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA/CPRA), provides rights to know, access, delete, and correct personal information, and the right not to be discriminated against for exercising these rights. We do not sell personal information.

To exercise any right, contact us at [email protected]. We will verify your identity before acting on your request. Where a legal obligation requires us to retain specific records, we will explain that basis.

9. Children’s Privacy

The Platform is intended only for accredited investors who are adults. We do not knowingly collect personal information from anyone under 18. If we learn we have collected such information, we will delete it.

10. Changes to This Policy

We may update this Policy from time to time. Material changes will be posted on this page with a revised “Last updated” date. Your continued use of the Platform after changes take effect constitutes acceptance.

11. Governing Law and Contact

This Policy is governed by the laws of the State of California and applicable United States federal law, without regard to conflict-of-laws principles.

Questions about this Policy or our privacy practices may be directed to:

Crowdlender AI, LLC Email: [email protected]