Privacy Policy

TRINITY FINANCE, LLC – PRIVACY POLICY

Last Updated: November 13th, 2025 (11/13/2025)

1. INTRODUCTION & SCOPE

This Privacy Policy (“Policy”) describes how Trinity Finance, LLC (“Trinity,” “we,”

“us,” or “our”) collects, uses, shares, and protects Personal Information in

connection with our operations as a U.S.-based commercial finance and business

services firm. Our offerings include, but are not limited to, commercial lending

brokerage, funding matchmaking, financial consulting, referral services, business

financing facilitation, analytics services, technology-enabled services, AI-driven

tools, business solutions, and all related or future services provided by Trinity

(collectively, the “Services”).

This Policy applies whenever you interact with any Trinity Services, including, but not limited to:

● Visiting or using any Trinity-operated websites, applications, platforms, or digital tools (“Site”);

● Interacting with Trinity via email, SMS/text, phone, AI systems, live chat, or similar communication channels;

● Providing data as a business customer, applicant, partner, or referral source;

● Interacting with Trinity’s Partners, which include lending partners and

non-lending partners, such as technology partners, service providers,

affiliates, financial institutions, data vendors, marketing platforms, referral

partners, and any third-party organizations Trinity collaborates with (“Partners”).

Trinity may act as both a data controller and data processor/service provider, depending on the context and governing laws.

All Personal Information is processed exclusively within the United States, regardless of where the information originates.

By using the Services, you acknowledge and agree to the terms of this Privacy Policy.

Privacy Policy Continued By Section

  • For purposes of this Policy:

    “Personal Information” means information that identifies, relates to, describes, or could reasonably be associated with a specific consumer, business, or device.

    “Processing” means any operation performed on Personal Information, including collection, storage, transmission, use, disclosure, or deletion.

    “Commercial Lending Brokerage Activities” include Trinity’s lender and funding matchmaking services, underwriting support, referral activities, and related service operations.

    “Partners” means both lending and non-lending third parties, including financial institutions, referral partners, affiliates, technology providers, analytics firms, AI vendors, contractors, service providers, marketing partners, or any other third parties Trinity collaborates with to deliver or improve Services.

    “AI Systems” include automated tools used for communication, analytics, workflow optimization, fraud mitigation, eligibility assessment, or service enhancement.

    “Sensitive Information” includes government IDs, bank account numbers, tax returns, financial statements, and other non-public financial or identification data.

  • Trinity collects Personal Information as necessary to deliver, operate, and improve Services, including, but not limited to all commercial lending, financial, technology, consulting, operational, AI, and analytics offerings.

    A. Information You Provide

    ● Registration credentials

    ● Business and ownership details

    ● Application and underwriting information

    ● Identity verification information

    ● Financial documents (bank statements, tax returns, financials, projections)

    ● Communications, preferences, and consents

    B. Verified & Third-Party Information

    ● Banking, financial, or transactional data

    ● Credit bureau or identity data (where authorized)

    ● Information from referral partners

    ● Data from analytics platforms, AI tools, and marketing technologies

    C. Automatically Collected Data

    ● IP address, device IDs, browser information

    ● Usage analytics, session data, click interaction

    ● Cookie, pixel, and tracking information

    D. AI Interaction Data

    ● Chat logs and conversation metadata

    ● Behavioral insights used for optimization

    ● Fraud detection and eligibility assessment context

    Minors: We do not knowingly collect information from users under 16.

  • Trinity uses Personal Information only for legitimate business purposes in connection with our Services and our Partners’ services, including but not limited to:

    A. Providing, Enhancing & Expanding Services

    ● Delivering Trinity Services, including current and future offerings

    ● Matching you with Trinity Partners, both lending and non-lending

    ● Facilitating assessments, applications, consulting, and analysis

    ● Automating workflows, communications, and document processing

    B. Communications

    ● Sending operational, transactional, compliance, and service-related messages

    ● Sending promotional messages on behalf of Trinity or Trinity Partners (with

    consent)

    ● Providing AI-assisted or human-assisted support

    C. Analytics, AI & Platform Optimization

    ● Improving accuracy, efficiency, and user experience

    ● Detecting anomalies, preventing fraud, and mitigating risk

    ● Supporting decision-making with human oversight

    D. Legal, Regulatory & Compliance Purposes

    ● Meeting obligations under applicable financial, commercial, or privacy laws

    ● Responding to lawful regulatory, government, or law enforcement requests

  • By providing your contact information, you consent to receive communications from Trinity AND Trinity Partners, including both lending and non-lending partners.

    These communications may include:

    ● Emails

    ● SMS or text messages

    ● Phone calls, including autodialed or prerecorded messages

    ● Digital marketing messages

    ● AI-generated or AI-assisted messages

    Opt-Out Mechanisms

    ● Email: Click “unsubscribe”

    ● SMS: Reply STOP

    ● Phone: Request placement on do-not-call list

    ● Cookies: Change browser or tool settings

    ● AI interactions: Discontinue use or notify us

    Service-related communications (e.g., updates to applications, compliance,

    verification) may still be required.

  • Trinity shares Personal Information only as needed to operate Services and enable Partner interactions, including both lending and non-lending Partners.

    A. Trinity Partners

    Includes, but is not limited to:

    ● Lending partners

    ● Non-lending commercial Partners

    ● Referral partners

    ● Technology and platform partners

    ● Data providers

    ● AI and analytics vendors

    ● Marketing and operations platforms

    ● Affiliates and strategic partners

    Partners may use information for:

    ● Service fulfillment

    ● Evaluating eligibility

    ● Customer support

    ● Analytics and operational efficiency

    ● Delivering Partner offerings or communications

    B. Service Providers

    E.g., hosting, analytics, data verification, compliance, communications, security.

    C. Legal & Compliance

    We may disclose information to:

    ● Comply with laws or subpoenas

    ● Respond to regulators

    ● Investigate fraud or threats

    D. Corporate Transitions

    In mergers, acquisitions, reorganizations, or bankruptcy, Personal Information may be transferred.

    E. Aggregated or De-Identified Data

    Shared for analytics, reporting, or research.

    F. No Selling of Personal Information

    Trinity does not “sell” Personal Information as defined by CCPA/CPRA.

  • We use cookies, pixels, analytics technologies, and advertising tools to support:

    ● Functionality

    ● Performance

    ● Marketing and retargeting

    ● Preference settings

    ● AI model improvement

    You may manage cookies via browser tools or site-specific settings.

  • Trinity uses AI Systems to improve communications, workflows, fraud prevention, analytics, and overall service quality.

    ● AI is used with human oversight.

    ● Trinity does not use automated systems that make binding legal or financial decisions without human review.

    ● Users may request manual review or object to automated processing, where legally applicable.

  • We retain Personal Information only as long as reasonably necessary to:

    ● Provide Services

    ● Fulfill legal or regulatory requirements

    ● Meet contractual obligations with Partners

    ● Maintain business records

    ● Resolve disputes

    Data is securely deleted or anonymized when no longer required.

  • We maintain commercially reasonable safeguards including:

    ● Encryption

    ● Access controls

    ● Firewalls and monitoring

    ● Vendor security reviews

    ● Role-based access

    ● Incident response procedures

    No system is perfectly secure. Use of the Site is at your own risk.

  • Depending on jurisdiction, rights may include:

    • A. California (CCPA/CPRA)

      Right to know, access, delete, correct, opt-out, limit use of sensitive data, and non-

      discrimination.

      B. GDPR / UK Residents

      Right to access, rectify, erase, restrict, portability, object, and request human review.

      C. Other U.S. States

      (Virginia, Colorado, Connecticut, Utah, etc.)

      Rights vary but generally include access, correction, deletion, and opt-out rights.

      Verification

      We may require identity verification.

      Authorized Agents

      Permitted with written authorization.

  • All data is stored and processed in the U.S. Trinity uses contractual, administrative, and industry-standard safeguards for data originating outside the U.S.

  • We do not knowingly collect data from children under 16. If received, it will be deleted promptly.

  • Personal Information may be transferred to another entity in the event of:

    ● Merger

    ● Acquisition

    ● Reorganization

    ● Sale of assets

    ● Bankruptcy

  • We may update this Policy at any time.

    Updates are effective upon posting to the Site.

    Continued use of Services constitutes acceptance of changes.

  • Trinity Finance, LLC

    Email: info@financetrinity.com

    Website: www.financetrinity.com

    Address: 613 Chillicothe Street, Portsmouth, Ohio 45662

  • Additional disclosures for California, Virginia, Colorado, Connecticut, Utah, EU/UK, Canada, and other jurisdictions may be provided separately or upon request.

END OF POLICY