California Consumer Privacy Act (CCPA) Notice

Capital Gurus LLC
A Delaware Limited Liability Company

Effective Date: August 29, 2024
Last Updated: June 25, 2026

1. Introduction

This California Consumer Privacy Act Notice (“CCPA Notice”) is provided by Capital Gurus LLC (“Capital Gurus,” “Company,” “we,” “our,” or “us”) in compliance with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, “CCPA”), Cal. Civ. Code §§ 1798.100–1798.199.100.

Capital Gurus is a financial services company operating in the merchant cash advance (“MCA”) industry. We provide funding solutions to small and medium-sized businesses across the United States. This CCPA Notice applies to California residents (“consumers” or “you”) and describes the categories of personal information we collect, how we use and share that information, and the rights you have under the CCPA.

This Notice supplements, but does not replace, our general Privacy Policy. In the event of a conflict between this Notice and our Privacy Policy, the terms of this Notice shall control with respect to California residents.

This CCPA Notice covers the following topics:

• Scope and Applicability
• Categories of Personal Information Collected
• Sources of Personal Information
• Purposes for Collection and Use
• Sharing and Disclosure of Personal Information
• Retention of Personal Information
• Your CCPA Rights
• How to Exercise Your Rights
• Notice of Financial Incentive
• Minors
• CCPA Metrics
• Changes to This Notice
• Contact Information

2. Scope and Applicability

Who This Applies To

This CCPA Notice applies to all California residents who interact with Capital Gurus in any capacity, including:

• Business owners and applicants who apply for or receive merchant cash advances or other funding products
• Guarantors and co-signatories on funding agreements
• Visitors to our websites, applications, or digital properties
• Prospective clients whose information we obtain through lead generation or marketing activities
• Business contacts of our clients, vendors, or partners
• Employees, job applicants, and contractors (to the extent required under CCPA)

Exemptions

Certain information may be exempt from the CCPA, including:

• Information covered by the Gramm-Leach-Bliley Act (GLBA) and implementing regulations, to the extent such information is collected, processed, sold, or disclosed pursuant to GLBA
• Information covered by the Fair Credit Reporting Act (FCRA)
• Information collected in a business-to-business (B2B) context, to the extent permitted under applicable law
• Publicly available information lawfully made available from federal, state, or local government records
• De-identified or aggregated consumer information

3. Categories of Personal Information Collected

In the preceding twelve (12) months, Capital Gurus has collected the following categories of personal information from or about California consumers:

A. Identifiers — Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, Social Security Number, driver’s license number, passport number, Employer Identification Number (EIN), or other similar identifiers. Collected: Yes

B. Personal Information (Cal. Civ. Code § 1798.80(e)) — Name, signature, Social Security Number, physical characteristics or description, address, telephone number, driver’s license or state identification card number, bank account number, credit card number, debit card number, or any other financial information. Collected: Yes

C. Characteristics of Protected Classifications — Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression), sexual orientation, veteran or military status. Collected: No (not intentionally collected)

D. Commercial Information — Records of property, products or services purchased, obtained, or considered; other purchasing or consuming histories or tendencies; business revenue data, transaction volumes, merchant processing history. Collected: Yes

E. Biometric Information — Genetic, physiological, behavioral, or biological characteristics; activity patterns used to extract a template or identifier (e.g., fingerprints, faceprints, voiceprints). Collected: No

F. Internet or Other Electronic Network Activity — Browsing history, search history, information regarding a consumer’s interaction with our websites, applications, or advertisements; cookies, pixel tags, analytics data. Collected: Yes

G. Geolocation Data — Physical location or movements, approximate location derived from IP address. Collected: Yes (approximate only)

H. Sensory Data — Audio (recorded customer service calls, with notice), electronic, visual, or similar information. Collected: Yes (limited)

I. Professional or Employment-Related Information — Current or past job history, business ownership details, industry type, years in business, title, role. Collected: Yes

J. Non-Public Education Information — Education records directly related to a student maintained by an educational institution or a party acting on its behalf. Collected: No

K. Inferences — Profile reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, aptitude; creditworthiness assessments, risk scoring. Collected: Yes

L. Sensitive Personal Information — Social Security Number, driver’s license number, state identification card number, passport number; account log-in credentials; financial account number with access code; precise geolocation. Collected: Yes (as necessary for funding services)

4. Sources of Personal Information

We collect personal information from the following categories of sources:

• Directly from you: When you submit a funding application, speak with our sales or support team, visit our website, or otherwise communicate with us
• From your authorized representatives: Including brokers, ISOs (Independent Sales Organizations), and other intermediaries who submit applications on your behalf
• From financial institutions: Including banks, credit bureaus, and payment processors in connection with underwriting and due diligence
• From third-party data providers: Including lead generation companies, business data aggregators, credit reporting agencies, and marketing partners
• Automatically: Through cookies, pixel tags, web beacons, server logs, and similar technologies when you interact with our digital properties
• From public sources: Including Secretary of State filings, UCC records, court records, and other publicly available databases
• From our service providers: Including CRM platforms, analytics tools, communication platforms, and document processing services

5. Purposes for Collection and Use

We collect and use personal information for the following business and commercial purposes:

Operational Purposes

• Funding services: Processing, underwriting, and servicing merchant cash advance applications and agreements
• Identity verification: Confirming the identity of applicants, guarantors, and authorized signatories
• Due diligence: Conducting credit analysis, bank statement review, fraud detection, and risk assessment
• Account management: Managing customer accounts, payment collection, and servicing
• Communication: Responding to inquiries, providing customer support, and sending transactional notifications

Commercial Purposes

• Marketing: Sending promotional offers, newsletters, and information about our products and services (with appropriate consent or opt-out mechanisms)
• Lead generation: Identifying and contacting potential business clients
• Advertising: Delivering targeted advertising through digital channels

Compliance and Legal Purposes

• Regulatory compliance: Meeting obligations under federal and state financial services regulations
• Fraud prevention: Detecting, investigating, and preventing fraudulent activity
• Legal proceedings: Exercising or defending legal claims, responding to subpoenas or other legal process
• Auditing: Conducting internal audits, financial reporting, and compliance reviews

Business Operations

• Analytics: Analyzing business performance, market trends, and customer behavior
• Service improvement: Enhancing our products, services, and user experience
• Security: Protecting our systems, networks, and data from unauthorized access or misuse

6. Sharing and Disclosure of Personal Information

Categories of Third Parties

In the preceding twelve (12) months, we have disclosed personal information for a business purpose to the following categories of third parties:

• Service providers — To perform services on our behalf (e.g., underwriting support, document processing, payment processing, CRM, analytics, IT/hosting). Categories shared: A, B, D, F, G, I, K, L
• Funding partners and syndicators — To facilitate funding of merchant cash advances when we syndicate or participate deals. Categories shared: A, B, D, I, K
• Financial institutions and credit bureaus — For credit checks, bank verification, UCC filings, and related financial diligence. Categories shared: A, B, D, L
• ISOs and broker partners — To manage referral relationships, commission tracking, and deal pipeline management. Categories shared: A, B, D, I
• Legal and compliance advisors — For legal advice, regulatory compliance, dispute resolution, and litigation. Categories shared: A, B, D, L
• Government and regulatory bodies — As required by law, regulation, legal process, or governmental request. Categories shared: A, B, D, I, L
• Acquirers and successors — In connection with a merger, acquisition, reorganization, bankruptcy, or sale of assets. Categories shared: All categories

Sale and Sharing of Personal Information

We do not “sell” personal information as defined under the CCPA, and have not done so in the preceding twelve (12) months. We do not exchange personal information for monetary consideration.

We may use certain online identifiers (such as cookies and pixel data) in connection with advertising partners. To the extent this constitutes “sharing” under CCPA, you have the right to opt out (see Section 8).

Sensitive Personal Information

We do not use or disclose sensitive personal information for purposes beyond those authorized under Cal. Civ. Code § 1798.121(a), which include:

• Performing the services or providing the goods reasonably expected by an average consumer who requests those services or goods
• Detecting security incidents, resisting malicious, deceptive, or illegal actions, and prosecuting those responsible
• Ensuring the physical safety of natural persons
• Short-term transient use (not including profiling)
• Performing services on behalf of the business (including account servicing, processing transactions, and verifying information)
• Activities to verify or maintain the quality or safety of a service and to improve, upgrade, or enhance the service

7. Retention of Personal Information

We retain personal information only for as long as reasonably necessary to fulfill the purposes for which it was collected, as described in this Notice, and as required by applicable law. Our retention periods include:

• Funding application data: Duration of the funding agreement + 7 years
• Bank statements and financial documents: Duration of the funding agreement + 5 years (or as required by regulation)
• Customer account information: Duration of relationship + 7 years
• Marketing and lead data: Until opt-out or 3 years from last interaction, whichever is earlier
• Website analytics and cookies: 13 months (rolling)
• Call recordings: 3 years from date of recording
• Employee/contractor data: Duration of employment/engagement + 7 years

We may retain de-identified or aggregated data indefinitely, as such data is not subject to the CCPA.

8. Your CCPA Rights

If you are a California resident, you have the following rights under the CCPA:

Right to Know (Access)
You have the right to request that we disclose:

• The categories of personal information we have collected about you
• The categories of sources from which the personal information was collected
• The business or commercial purpose for collecting, selling, or sharing personal information
• The categories of third parties to whom we disclose personal information
• The specific pieces of personal information we have collected about you

Right to Delete
You have the right to request that we delete personal information we have collected from you, subject to certain exceptions (e.g., legal obligations, ongoing business relationships, fraud detection, exercising legal rights).

Right to Correct
You have the right to request that we correct inaccurate personal information that we maintain about you.

Right to Opt-Out of Sale/Sharing
You have the right to opt out of the “sale” or “sharing” of your personal information. While we do not sell personal information for monetary consideration, you may opt out of any cross-context behavioral advertising by:

• Clicking the “Do Not Sell or Share My Personal Information” link on our website
• Submitting a request via the methods described in Section 9
• Enabling a browser-based opt-out preference signal (e.g., Global Privacy Control / GPC), which we honor as a valid opt-out request

Right to Limit Use of Sensitive Personal Information
You have the right to direct us to limit the use and disclosure of your sensitive personal information to purposes authorized under CCPA § 1798.121(a).

Right to Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. We will not:

• Deny you goods or services
• Charge you different prices or rates
• Provide you a different level or quality of service
• Suggest that you will receive a different price, rate, level, or quality of service

However, we may offer financial incentives for the collection, sale, or retention of personal information, provided such incentives are reasonably related to the value of the personal information and comply with applicable law.

9. How to Exercise Your Rights

Submitting a Request

You may submit a CCPA request through any of the following methods:

• Email: info@capitalgurus.com
• Phone: (725) 425-4307
• Mail: Capital Gurus LLC, Attn: Privacy Officer, 1700 S Pavilion Drive, Suite #420, Las Vegas, 89135, Nevada, USA.

Verification

To protect your privacy and security, we will verify your identity before fulfilling any request. Verification may include:

• Matching at least two (2) data points you provide with information we already maintain (for requests to know categories of personal information)
• Matching at least three (3) data points and obtaining a signed declaration under penalty of perjury (for requests to know specific pieces of personal information)
• Reasonable verification appropriate to the nature and sensitivity of the request

If we cannot verify your identity, we may deny your request and will explain the basis for the denial.

Authorized Agents

You may designate an authorized agent to submit a CCPA request on your behalf. To do so, you must:

• Provide the authorized agent with written permission signed by you; and
• Verify your own identity directly with us (unless the agent has a valid power of attorney under Probate Code §§ 4000–4465)

We may deny a request from an authorized agent that does not submit sufficient proof of authorization.

Response Timing

We will acknowledge receipt of your request within ten (10) business days and provide a substantive response within forty-five (45) calendar days of receiving your verifiable request. If we require additional time, we will inform you in writing of the reason and the extension period (up to an additional 45 days, for a maximum of 90 days total).

10. Notice of Financial Incentive

Capital Gurus does not currently offer any financial incentive programs (e.g., loyalty programs, discounts, or price differences) that involve the collection, retention, sale, or sharing of personal information. If we establish such a program in the future, we will update this Notice to include the material terms, the value of the consumer’s data, and how to opt in or withdraw.

11. Minors

Capital Gurus does not knowingly collect, sell, or share the personal information of consumers under the age of 16. Our services are designed for business professionals and are not directed at minors. If we learn that we have collected personal information from a minor under 16, we will promptly delete such information.

12. CCPA Metrics (Annual Disclosure)

In compliance with Cal. Code Regs. tit. 11, § 7102, Capital Gurus will publish the following metrics annually, covering the previous calendar year:

• Number of requests to know received, complied with (in whole or in part), and denied
• Number of requests to delete received, complied with (in whole or in part), and denied
• Number of requests to correct received, complied with (in whole or in part), and denied
• Number of requests to opt-out received, complied with (in whole or in part), and denied
• Median number of days to substantively respond to each category of request

These metrics will be published on our website by July 1 of each year for the preceding calendar year.

13. Changes to This Notice

We reserve the right to amend this CCPA Notice at our discretion and at any time. When we make material changes to this Notice, we will:

• Post the updated Notice on our website with a revised “Last Updated” date
• Notify affected consumers through email or prominent notice on our website at least thirty (30) days before the changes take effect (for material changes)

Your continued use of our services after the effective date of any changes constitutes your acknowledgment of the revised Notice.

14. Contact Information

If you have any questions or comments about this CCPA Notice, our privacy practices, or your rights under the CCPA, please contact us at:

Capital Gurus LLC
Attn: Privacy Officer
Capital Gurus LLC, Attn: Privacy Officer, 1700 S Pavilion Drive, Suite #420, Las Vegas, 89135, Nevada, USA.

Email: info@capitalgurus.com
Phone: (725) 425-4307

This CCPA Notice is intended to comply with the California Consumer Privacy Act of 2018 (Cal. Civ. Code §§ 1798.100 et seq.), as amended by the California Privacy Rights Act of 2020, and all implementing regulations. This Notice does not constitute legal advice. Capital Gurus recommends consulting with qualified legal counsel to ensure full compliance with all applicable privacy laws and regulations.

© 2026 Capital Gurus LLC. All rights reserved.