Privacy Policy

1. Introduction

TGM Ventures, Inc. (“Company,” “we,” “us,” or “our”) operates the RefiHub platform, a technology platform for connecting business professionals seeking commercial or business-purpose financing with professional lenders. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Service.

2. Information We Collect

We may collect the following types of information:

• Account Information: Name, email address, phone number, company name, title, and authentication credentials.
• Business Information: Entity details, years of experience, portfolio size, and professional qualifications.
• Borrower Information: Property addresses, estimated values, net operating income, loan balances, and other commercial property and financing details you provide.
• Lender Information: Lending criteria, product offerings, rate ranges, geographic coverage, institution details, and other information you provide to describe your lending capabilities.
• Documents: Loan documents, term sheets, appraisals, and other business files you upload for analysis.
• Usage Data: How you interact with the Service, including pages visited, features used, and device information.

3. How We Use Your Information

We use collected information to:

• Facilitate connections between business professionals and lenders based on your preferences.
• Match financing requirements with relevant lender criteria on the platform.
• Analyze uploaded documents using AI to extract relevant business data.
• Improve and personalize the platform experience.
• Send notifications about connections, platform updates, and relevant market information.
• Comply with legal obligations.

4. AI and Automated Processing

RefiHub uses artificial intelligence and automated processing to analyze documents and data you provide, extract relevant information, and facilitate connections on the platform. AI-generated content is provided as a convenience and may contain errors. You may contact us to request information about the logic involved in automated processing or to opt out of profiling that produces legal or similarly significant effects.

5. Privacy Controls

RefiHub provides users with control over their information on the platform. Borrowers can set their disclosure level to minimal, standard, or detailed. Lenders only see borrower information corresponding to the level the borrower selects. Borrower identity is not revealed to lenders until the borrower chooses to connect directly. Lenders control what lending criteria and institutional information is displayed on their profile.

6. Information Sharing

We do not sell your personal or business information. We may share your information with:

• Platform Users: Property and financing details you choose to share via the platform, according to your privacy settings.
• Service Providers: Third-party vendors who assist in operating the platform (hosting, analytics, email delivery), bound by confidentiality obligations.
• Legal Requirements: When required by law, subpoena, or to protect our rights.

7. Data Security

We implement appropriate technical and organizational measures to protect your information. Uploaded documents are encrypted using AES-256 encryption. Data is stored in secure cloud infrastructure with access controls. However, no method of electronic storage or transmission is 100% secure, and we cannot guarantee absolute security.

8. Data Breach Notification

In the event of a data breach affecting your personal information, we will notify affected individuals and applicable regulatory authorities as required by law, within the timeframes prescribed by applicable state and federal data breach notification statutes.

9. Data Retention

We retain your information for as long as your account is active or as needed to provide the Service. You may request deletion of your account and associated data by contacting us. Certain data may be retained as required by law or for legitimate business purposes.

10. Your Rights

Depending on your jurisdiction, you may have the right to access, correct, delete, or port your personal data. To exercise your rights, contact us at privacy@refihub.com.

11. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have the following rights under the California Consumer Privacy Act and California Privacy Rights Act:

• Right to Know: You may request that we disclose the categories and specific pieces of personal information we have collected about you, the sources of collection, the business purpose for collecting it, and the categories of third parties with whom we share it.
• Right to Delete: You may request deletion of personal information we have collected from you, subject to certain exceptions.
• Right to Opt Out: We do not sell or share personal information for cross-context behavioral advertising. If this changes, we will provide a “Do Not Sell or Share My Personal Information” link.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights.

To submit a verifiable request, email privacy@refihub.com. We will verify your identity and respond within 45 days.

In the preceding 12 months, we have collected the categories of information described in Section 2 above, from the sources described therein, for the business purposes described in Section 3. We share information only as described in Section 6.

12. Children's Privacy

The Service is not directed to individuals under the age of 13 (or 16 in certain jurisdictions). We do not knowingly collect personal information from children. If we learn that we have collected personal information from a child, we will delete it promptly.

13. International Data Transfers

Your information may be transferred to and processed in the United States. By using the Service, you consent to the transfer of your information to the United States, where data protection laws may differ from those in your jurisdiction.

14. Cookies and Tracking

We use cookies and similar technologies to improve your experience, analyze usage, and assist in our marketing efforts. You can manage your cookie preferences through your browser settings.

15. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be posted on this page with a revised date. Your continued use of the Service constitutes acceptance of the updated policy.

16. Contact

If you have questions about this Privacy Policy, please contact us at privacy@refihub.com.