Privacy Policy

1. Introduction

Intrepid Finance, LLC ("Intrepid Finance" or "Intrepid") values and respects the privacy of its users. This Privacy Policy (the "Policy") explains how Intrepid collects, uses, discloses, and safeguards information when users interact with www.intrepidfinance.io, the Intrepid Portal, and related websites, portals, and services operated by Intrepid (collectively, the "Site"). By using the Site, you consent to this Policy, as well as any future updates made here.

This Policy is referenced in, and forms part of, Intrepid's Terms of Service (the "Terms"). Capitalized terms used but not defined in this Policy have the meanings given to them in the Terms. In the event of a conflict between this Policy and the Terms with respect to the treatment of personal information, this Policy controls.

1.1 Scope of This Policy

This Policy applies to personal information that Intrepid collects for its own purposes (acting as a "business" or "controller") when you visit the Site, communicate with us, or apply for or use Intrepid's services.

This Policy does not apply to information that Intrepid processes on behalf of its financial-institution, advisory, and other business clients — including borrower or customer data submitted through white-labeled or client-branded portals and platforms (collectively, "Client Data"). Intrepid processes Client Data as a service provider or processor under the written agreements between Intrepid and the applicable client, and the client's own privacy policy governs that data. If you submitted information through a portal operated for one of Intrepid's clients, please direct privacy inquiries and requests to that institution; Intrepid will refer any such requests it receives to the applicable client and will assist the client as its agreement requires.

1.2 Summary of Key Points

• What we collect: Contact, business, and financial information you provide with your application, plus limited usage data collected automatically (Section 2).
• Why we use it: To provide and improve services, support customers, prevent fraud, and — only with your consent — for marketing (Section 3).
• Text messages: Portal-security texts are separate from marketing texts, and SMS consent is never shared with third parties or affiliates for marketing purposes (Section 3.1).
• Sharing: We use vetted service providers, and we disclose applicant information to lenders, funders, and financing partners only at your direction to obtain financing for you (Section 4).
• No sale or sharing: We do not sell personal information and do not share it for cross-context behavioral advertising (Section 8.1).
• Your rights: You may request access, correction, deletion, and a portable copy of your data; additional state-specific rights may apply (Section 8).
• Contact: getcapital@intrepidfinance.io or 833.366.6396 (Section 14).

This summary is provided for convenience only; the full sections of this Policy control.

2. Information We Collect

2.1 Information Collected Directly from You

Intrepid may collect personal information directly from you, including:

• Basic Identifying Information: Name, legal physical street address, email address, telephone number (including mobile phone number), and any other contact details you provide.
• Business Information: Business name, type, legal physical street address, ownership structure, and other identifiers to verify business credentials.
• Financial Information: Where applicable, data required to assess funding needs, such as bank statements, credit reports, or annual revenue.

Intrepid requests only the information essential for providing services or fulfilling legal, regulatory, compliance or additional requirements.

2.2 Sensitive Information

Certain services may require the collection of sensitive information, such as financial details or government-issued identification. Intrepid will collect and process this data only with your explicit consent and in accordance with applicable laws.

2.3 Information Collected Automatically

We collect certain information about your interaction with our website to improve service quality, including:

• Usage Data: IP address, browser type, pages viewed, device information, and time spent on the site.
• Cookies and Tracking Technologies: Used to enhance site functionality, gather analytics, and enable targeted advertising. You may control cookie use via your browser settings.

2.4 Cookies and Tracking Technology

Intrepid uses cookies to recognize users, optimize site performance, facilitate a secure user experience, and provide aggregated analytics on site usage. These cookies are small text files stored on your device. If you prefer, you can adjust your browser settings to block cookies, though certain features of our site may be limited without them.

Intrepid may also use:

• Web Beacons: Pixel tags to track website visits and engagement.
• Google Analytics: Aggregated data collection for analysis and service enhancement.

Where a cookie preference tool or consent banner is available on the Site, you may use it to manage optional (analytics, preference, and marketing) cookies, which are deployed only in accordance with your selections; strictly necessary cookies remain active because the Site cannot function without them. We also honor legally recognized opt-out preference signals, such as the Global Privacy Control, as described in Section 11.

3. Use of Personal Information

Intrepid uses collected information for:

• Operational Purposes: To deliver, maintain, and enhance services.
• Customer Support and Communications: To respond to inquiries and provide updates.
• Marketing Communications: With your consent, we may use your information for promotional communications (you may unsubscribe anytime).
• Fraud Prevention and Security: To verify identities and safeguard users.

Additional Uses

• Analytics and Machine Learning: Aggregated, de-identified data may be used to improve products and services through AI and machine learning. Data is anonymized where possible, and users retain rights to opt out of data processing for non-essential services.
• Enhanced User Experience: Data insights may be used to optimize website performance and personalize user interactions.

3.1 Telephone and SMS Communications

Mobile phone numbers collected in connection with the Intrepid Portal are used for portal security and operational communications, including Two-Factor Authentication (2FA) verification codes and account-related notifications, as described in Section 26 of the Terms. Marketing or promotional text messages are sent only with your prior express written consent, as described in Section 5.2 of the Terms, and you may opt out of such messages at any time by replying STOP.

SMS consent is not shared with third parties or affiliates for marketing purposes.

4. Sharing Information with Third Parties

Intrepid may share personal information under limited circumstances, including but not limited to:

• Service Providers: Trusted third-party vendors may assist in website operations, identity verification, analytics, and marketing. Providers are contractually obligated to use data solely as directed by Intrepid.
• Business Transactions: In mergers, acquisitions, or asset sales, user data may be transferred per applicable laws and confidentiality agreements.
• Legal Compliance: We may disclose data to comply with legal requests, such as court orders, or to address fraud or security issues.
• Protection of Intrepid and Others: Information may be shared as needed to protect the rights, safety, and property of Intrepid, its users, or others, including enforcing our Terms of Service.
• Third-Party Websites: Our website may contain links to third-party sites. Intrepid is not responsible for the privacy practices, security, or content of these external sites. Users are encouraged to review the privacy policies of any third-party sites they visit.
• Payment Processors: To process transactions and facilitate payments.
• Cloud Storage Providers: To store and protect your data securely.
• Marketing Partners: To assist in promotional activities, but only with your explicit consent.
• Fraud Detection Providers: To enhance security and prevent fraud.

If you are located outside the United States, please be aware that any personal data you provide to us may be transferred to and processed in the United States. By using our services, you consent to this transfer and processing of your data, in accordance with applicable privacy laws.

Intrepid Finance takes appropriate measures to ensure that your personal data is handled securely, regardless of where it is processed, in compliance with applicable privacy laws and regulations.

5. Data Security

Intrepid is committed to protecting data using industry-standard security measures, which include:

• Encryption: Data is encrypted during transmission using SSL/TLS technology.
• Access Controls: Only authorized personnel have access to sensitive data.
• Regular Audits: We conduct periodic audits to ensure the integrity of our systems.

While we implement reasonable safeguards, we cannot guarantee absolute security for data transmitted online. Intrepid assumes no liability for unauthorized access beyond our reasonable control.

Data Security on User's End: Intrepid is not responsible for data breaches or losses that occur due to user negligence, such as accessing accounts via unsecured networks or failing to use updated security practices.

6. Data Breach Notification

In the unlikely event of a data breach, Intrepid will notify affected users as required by applicable law and take appropriate steps to minimize damage and secure user data.

7. Retention of Personal Information

Intrepid retains personal data only for as long as necessary to fulfill the purposes outlined in this Policy, including for the purposes of providing services, legal obligations, and business requirements. Once your data is no longer required, it will be securely deleted or anonymized to prevent any misuse.

If you wish to request the deletion of your personal data, please contact us at getcapital@intrepidfinance.io. However, please note that certain data may be retained for legal or regulatory compliance, as well as for legitimate business interests, even after the termination of your account or service.

8. User Rights and Choices

As a user, you have the following rights regarding your personal data:

• Right to Access: You can request a copy of the personal data we hold about you.
• Right to Rectification: If your personal data is inaccurate or incomplete, you can request that we correct or update it.
• Right to Erasure: You can request that we delete your personal data, subject to legal exceptions.
• Right to Restrict Processing: You may request that we limit how we process your data in certain situations.
• Right to Data Portability: You can request a copy of your data in a structured, commonly used format to transfer it to another provider.

To exercise any of these rights, please contact us at getcapital@intrepidfinance.io.

8.1 California Privacy Rights (CCPA/CPRA Notice)

This section supplements this Policy and applies solely to California residents. It is provided pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the "CCPA"). Terms used in this section — including "sell," "share," "business purpose," and "sensitive personal information" — have the meanings given to them in the CCPA.

Categories of Personal Information We Collect

In the preceding twelve (12) months, Intrepid has collected the following categories of personal information, from the sources and for the purposes described in Sections 2 and 3 of this Policy:

• Identifiers: Name, postal address, email address, telephone number, IP address, and similar identifiers.
• Customer Records (Cal. Civ. Code § 1798.80(e)): Contact details and financial information, including bank statements, credit information, and revenue data provided in connection with an application.
• Commercial Information: Records of services considered or obtained, and application and transaction history.
• Internet or Other Electronic Network Activity: Usage data, browser type, device information, pages viewed, and interactions with the Site.
• Geolocation Data: Approximate location inferred from IP address.
• Professional or Employment-Related Information: Business ownership, role, and related credentials.
• Inferences: Limited analytics-based insights used to improve services and the user experience.
• Sensitive Personal Information: Government-issued identification numbers and financial account information, collected with your explicit consent where required.

How We Disclose Personal Information

We disclose personal information for business purposes to the categories of recipients described in Section 4 of this Policy, such as service providers, payment processors, cloud storage providers, and fraud detection providers. In addition, when you apply for financing, we disclose applicant information to lenders, funders, and financing partners at your direction and with your consent, for the purpose of identifying and obtaining financing options for you.

No Sale or Sharing of Personal Information

Intrepid does not "sell" personal information and does not "share" personal information for cross-context behavioral advertising, as those terms are defined in the CCPA, and has not done so in the preceding twelve (12) months. Our disclosure of applicant information to lenders, funders, and financing partners is made at your direction to provide the services you request; Intrepid does not receive marketing commissions or other monetary consideration in exchange for personal data. Intrepid has no actual knowledge that it sells or shares the personal information of consumers under sixteen (16) years of age. To the extent any use of advertising or analytics cookies on the Site could be deemed "sharing" under the CCPA, you may opt out through the methods below, and we honor legally recognized opt-out preference signals such as the Global Privacy Control.

Sensitive Personal Information

We use and disclose sensitive personal information only for purposes permitted by the CCPA, such as providing the services you request, verifying identity, preventing fraud, and maintaining security. We do not use sensitive personal information to infer characteristics about you.

Your California Rights

• Right to Know / Access: Request disclosure of the categories and specific pieces of personal information we have collected about you, the sources, purposes, and categories of recipients.
• Right to Delete: Request deletion of your personal information, subject to statutory exceptions.
• Right to Correct: Request correction of inaccurate personal information.
• Right to Data Portability: Request a copy of your personal information in a portable and readily usable format.
• Right to Opt Out of Sale or Sharing: Intrepid does not sell or share personal information; should that change, you have the right to opt out, and you may submit an opt-out request at any time, which we will honor.
• Right to Limit Use of Sensitive Personal Information: We do not use sensitive personal information beyond the purposes the CCPA permits, so no separate limitation right is required to be offered; if our practices change, we will provide the required "Limit the Use of My Sensitive Personal Information" mechanism.
• Right to Non-Discrimination: We will not discriminate against you for exercising any CCPA right.

How to Submit a Request

California residents may submit requests through either of the following designated methods:

• By email: getcapital@intrepidfinance.io (please include "California Privacy Request" in the subject line).
• By toll-free telephone: 833.366.6396.

We will verify your request using information associated with your account or application and may request additional information where reasonably necessary. You may designate an authorized agent to submit a request on your behalf; we may require proof of the agent's authority and verification of your identity. We will respond to verifiable requests within forty-five (45) days, subject to a permitted extension of an additional forty-five (45) days with notice to you.

Financial Services Exemptions

Certain personal information Intrepid collects in connection with financial products and services is subject to the federal Gramm-Leach-Bliley Act (GLBA) or the Fair Credit Reporting Act (FCRA) and is exempt from the CCPA. The rights described in this section apply to personal information not covered by those exemptions.

8.2 Other U.S. State Privacy Rights

Residents of other states with comprehensive consumer privacy laws — including Colorado, Connecticut, Delaware, Indiana, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, and Virginia — may have similar rights to the extent their state's law applies to Intrepid and to the information at issue, including the rights to confirm processing and access personal data, correct inaccuracies, delete personal data, obtain a portable copy, and opt out of targeted advertising, the sale of personal data, and certain profiling in furtherance of decisions that produce legal or similarly significant effects. Intrepid does not sell personal data and does not process personal data for such targeted advertising or profiling. Requests may be submitted using the designated methods described in Section 8.1.

If Intrepid declines to act on a request, residents of states that provide an appeal right may appeal that decision by replying to our response or emailing getcapital@intrepidfinance.io with the subject line "Privacy Appeal." If your appeal is denied, you may contact your state Attorney General. Please note that certain information Intrepid processes is exempt from these state laws under entity-level or data-level exemptions (including GLBA and FCRA) or because it is business-to-business information; the rights described above apply to the extent no exemption applies.

Opt-Out of Data Sharing and Marketing

Users in all regions may opt out of data sharing for marketing purposes. Instructions for opting out are provided in our communications or by contacting us directly at getcapital@intrepidfinance.io.

9. Hold Harmless

Intrepid provides services as a facilitator of financial solutions and financing options. By engaging with Intrepid's services, you agree to hold Intrepid and its agents, affiliates, and assignees harmless against any claims, liabilities, losses, or expenses arising from the use of our website or services, except to the extent directly resulting from Intrepid's gross negligence or willful misconduct.

10. Parents, Guardians, and Children's Privacy

The Site is intended for users aged 18 and older. Intrepid does not knowingly solicit or collect personal information from minors. If you are under 18, please refrain from using this site. If we become aware of data collected from a minor, we will delete it promptly. Parents or guardians who believe their child's data has been inadvertently collected should contact us at getcapital@intrepidfinance.io.

11. Advertising and Do Not Track Disclosure

Intrepid may work with advertising and analytics providers to deliver relevant ads on third-party websites. These providers may use cookies to track your activity across sites.

Do Not Track Requests: We do not respond to "Do Not Track" signals from browsers due to the lack of an industry-standard interpretation of these signals. However, where required by applicable law, we will honor legally recognized opt-out preference signals (such as the Global Privacy Control) as a request to opt out of targeted advertising or the "sharing" of personal information.

12. Policy Updates

Intrepid reserves the right to modify this Privacy Policy at any time. If substantial changes are made, we will provide prominent notice through our website or by other appropriate means. Updated policies apply prospectively from their effective date. Where required by applicable law, Intrepid will provide notice of material changes and obtain any legally required consent before applying changed practices to previously collected personal information. Users are encouraged to review this Policy periodically to stay informed of any updates.

13. Limitation of Liability

To the maximum extent permitted by law, Intrepid Finance will not be liable for any indirect, incidental, consequential, or punitive damages arising from or related to the collection, use, disclosure, or security of your information. Intrepid's total aggregate liability for any and all claims arising under or relating to this Policy, including any implied warranties, shall not exceed the greater of (a) the total of all amounts paid to Intrepid by you during the six (6) month period preceding the claim, or (b) one hundred dollars ($100), consistent with the limitations set forth in the Terms of Service.

This limitation of liability applies regardless of whether damages are foreseeable, or whether Intrepid has been advised of the possibility of such damages.

14. Contact Information

If you have any concerns about how your personal data is handled or wish to submit feedback regarding our privacy practices, please contact us at getcapital@intrepidfinance.io. We take user concerns seriously and aim to resolve any issues promptly. You also have the right to lodge a complaint with the relevant authority in your jurisdiction.

For questions about this Policy or to exercise your rights, please contact Intrepid at:

Email: getcapital@intrepidfinance.io

Phone: 833.366.6396

Web: www.intrepidfinance.io

Mail: Intrepid Finance, LLC, 9783 E. 116th Street, Suite 122, Fishers, Indiana 46037