Online Privacy Policy

1. Introduction

Your privacy is important to Monera Capital Group LLC ("Monera Capital," "we," "us," and "our"). This Online Privacy Policy ("Policy") explains how we collect, share, use, and protect information when you visit or use this online service and any other product or service offered by or through Monera Capital. This Policy covers Monera Capital's online services, any product or service offered by or through us, as well as any interactions you may have while viewing content provided through one of Monera Capital's digital advertising campaigns.

General Principles

Our online services are directed and intended for businesses located in the United States. Monera Capital Group LLC is a business-to-business ("B2B") company; our products and services are designed for and offered exclusively to business entities and their authorized representatives.

Our online services are not intended for children under 18. We do not knowingly collect personal information from children under 18. If we learn we have collected or received personal information from a child under 18, we will delete that information.

If you have a financial product or service with us, we will use and share any information that we collect from or about you in accordance with this Policy.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website or products or services offered by us or through us. By accessing or using this Website or products or services offered by us or through us, you agree to this Privacy Policy. This Policy may change from time to time. Your continued use of this Website or products or services offered by us or through us after we make changes is deemed to be acceptance of those changes, so please check this Policy periodically for updates.

2. Information We Collect

2.1 Personal Information

When you visit or use our online services or obtain a product or service from us or through us, we may collect personal information from or about you such as your name, business name, email address, mailing address, telephone number(s), account numbers, user name, and password. We may also collect social security number, driver's license number, financial information (such as bank statements, credit card statements, average bank balance, personal and business credit history, payment behavior, bank account information, tax identification number, and beneficial ownership information) when you provide such information and where we believe it is reasonably required for ordinary business purposes.

2.2 Usage and Other Information

In addition to the personal information described above, we may collect certain information about your use of our online services. For example, we may capture the IP address of the device you use to connect to the online service, the type of operating system and browser you use, and information about the site you came from, the parts of our online service you access, and the site you visit next. We or our third-party partners may also use cookies, web beacons, or other technologies to collect and store other information about your visit to, or use of, our online services. In addition, we may later associate the usage and other information we collect online with personal information about you.

2.3 Additional Sources of Information

We may also collect information about you from additional online and offline sources including from co-branded partner sites or commercially available third-party sources, such as credit reporting agencies. We may combine this information with the personal and other information we have collected about you under this Online Privacy Policy.

2.4 Categories of Personal Information Collected

In accordance with applicable state privacy laws, the following table summarizes the categories of personal information we may collect, the sources from which we collect it, and the purposes for which it is used:

2.5 Sensitive Personal Information

In the course of providing our financial products and services, Monera Capital may collect certain categories of information classified as "sensitive personal information" under applicable state privacy laws, including:

• Social security numbers
• Driver's license or state identification numbers
• Financial account information, including bank account numbers and login credentials
• Tax identification numbers

We collect and use sensitive personal information only as necessary to provide our financial products and services, verify your identity, conduct due diligence, process your applications and transactions, prevent fraud, and comply with applicable legal and regulatory requirements.

3. Use of Information

We use the information that we collect about you or that you provide to us (including any personal information) for the following purposes:

• To present our website and its content to you
• To process your applications and transactions
• To verify your identity and conduct appropriate due diligence
• To register you as a user and identify you when you sign into your account
• To prevent fraud and enhance the security of your account or our online services
• To respond to your requests and communicate with you
• To perform analytics concerning your use of our online services, including your responses to our emails and the pages and advertisements you view
• To provide you with tailored content and marketing messages
• To operate, evaluate, and improve our business (including developing new products and services; improving existing products and services; performing data analytics; and performing accounting, auditing, and other internal functions)
• To comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations, and our policies
• For any other purposes that we may specifically disclose at the time you provide, or we collect, your information
• For any other purpose with your consent

We may also use data that we collect on an aggregate or anonymous basis (such that it does not identify any individual) for various business purposes, where permissible under applicable laws and regulations.

4. Use of Automated Processing Tools

Monera Capital may use automated systems, including artificial intelligence and machine learning technologies, to assist in processing applications, accurately capturing and extracting information, classifying business data, and streamlining internal workflows. These tools are used solely to expedite processing and improve the accuracy of data handling.

All funding decisions and material account determinations are made by qualified human reviewers. Automated tools do not make decisions regarding your application, funding, or account status. A human being always reviews and approves any such determination.

If you have questions about how your information is processed or about a decision related to your account or application, you may contact us using the information provided in Section 17 of this Policy.

5. Privacy and Sharing of Information

Monera Capital may share your personal information with third parties only in the ways described in this Policy and as permitted or required by law. We do not sell, trade, or otherwise provide your personal information — including sensitive personal information — as leads or for any commercial purpose to third parties. We do not share your personal information for cross-context behavioral advertising.

We may share anonymous or aggregated information with third parties to help deliver products, services, and content that are tailored to the users of our online services and for other purposes without restrictions.

We may disclose personal information that we collect about you or that you provide to us in the following ways:

• With Monera Capital's subsidiaries and affiliates
• With Monera Capital's bank partner(s)
• With Monera Capital's contractors, service providers, and other third parties that we use to support our business (and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which it was disclosed to them)
• With syndication partners in connection with funding transactions, subject to appropriate confidentiality agreements

We may also disclose your personal information:

• To comply with any court order, law, or legal process including a bankruptcy proceeding or to respond to any government or regulatory request
• To third parties or affiliates in connection with a corporate transaction, such as a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Monera Capital's assets
• To enforce or apply our terms of use, applicable policies, other agreements, including for collection purposes
• When we believe in good faith that disclosure is necessary to investigate fraud, security, or technical issues; to respond to an emergency; or otherwise to protect the rights, property, or security of our customers or third parties
• For any other purpose disclosed by us when you provide the information
• To any other third party with your prior consent to do so

6. Data Retention

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, including to satisfy any legal, regulatory, accounting, or reporting requirements. The specific retention period depends on the nature of the data and the context in which it was collected. In determining the appropriate retention period, we consider:

• The nature, amount, and sensitivity of the personal information
• The potential risk of harm from unauthorized use or disclosure
• The purposes for which we process the information and whether we can achieve those purposes through other means
• Applicable legal, regulatory, and contractual requirements

Financial records and transaction data are generally retained for a minimum of five (5) years following the conclusion of the business relationship, or longer if required by applicable law. When personal information is no longer needed, we will securely delete or anonymize it in accordance with our data retention policies.

7. Cookies, Web Beacons, and Tracking Technologies

We, or our service providers, and other companies we work with may deploy and use cookies, web beacons, local shared objects, and other tracking technologies for various purposes, such as fraud prevention, monitoring our advertising and marketing campaign performance, and improving your experience on our online services.

7.1 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for core website functionality and cannot be disabled.
• Analytics/Performance Cookies: Collect anonymous data about how visitors use our website to help us improve it.
• Functionality Cookies: Remember your preferences and settings for an enhanced experience.
• Marketing/Targeting Cookies: Used to deliver relevant content and measure advertising effectiveness.

7.2 Managing Cookie Preferences

Most web browsers allow you to control cookies through their settings. You can set your browser to refuse all or some cookies, or to alert you when cookies are being sent. Please note that if you disable or refuse cookies, some parts of our website may become inaccessible or not function properly.

7.3 Do Not Track Signals

Our website does not currently respond to "Do Not Track" (DNT) signals sent by web browsers. We will continue to monitor developments around DNT browser technology and the implementation of industry standards. In the meantime, you may manage your cookie preferences as described above.

8. State Privacy Rights

Depending on where you reside, you may have specific rights under applicable state privacy laws. While Monera Capital is a B2B company and much of the information we collect relates to business activities and business representatives, we recognize that certain state privacy laws may extend protections to individuals acting in a business capacity. The following summarizes rights that may be available to you under applicable state laws:

8.1 Your Rights

Subject to applicable law, you may have the right to:

• Right to Know/Access: Request information about the categories and specific pieces of personal information we have collected about you, the categories of sources from which we collected it, our purposes for collecting it, and the categories of third parties with whom we have shared it.
• Right to Delete: Request deletion of your personal information, subject to certain legal exceptions.
• Right to Correct: Request correction of inaccurate personal information that we maintain about you.
• Right to Opt-Out: Opt out of the sale or sharing of your personal information for cross-context behavioral advertising. Note: Monera Capital does not sell personal information or share it for cross-context behavioral advertising.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights.
• Right to Data Portability: Where applicable, request a copy of your personal information in a portable, readily usable format.

8.2 How to Submit a Request

To exercise any of the rights described above, please submit a verifiable request to us by:

• Emailing us at: privacy [at] moneracapitalgroup [dot] com
• Calling us at: 1-833-624-3863
• Writing to us at: Monera Capital Group LLC, Attn: Privacy Department, 1560 Sawgrass Corporate Pkwy 4th Floor, Fort Lauderdale, FL 33323

We will verify your identity before processing your request. Only you, or a person authorized to act on your behalf, may make a verifiable request related to your personal information. We will respond to your request within the timeframe required by applicable law (generally within 45 days, with the possibility of extension where permitted).

8.3 California Residents

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA). In the preceding twelve (12) months, we have collected the categories of personal information described in Section 2.4 above. As stated in Section 5, we do not sell personal information or share it for cross-context behavioral advertising. California residents may also designate an authorized agent to submit requests on their behalf by providing written authorization and valid identification.

9. Financial Privacy Notice

As a provider of financial products and services, Monera Capital may be subject to certain provisions of the Gramm-Leach-Bliley Act ("GLBA") and related regulations. To the extent GLBA applies to our activities:

• We collect nonpublic personal information ("NPI") about you from the applications and forms you submit, your transaction history with us, and from third-party sources such as credit reporting agencies.
• We do not disclose NPI to nonaffiliated third parties except as permitted or required by law, including to process your transactions, maintain your account, respond to regulatory inquiries, and as otherwise described in this Policy.
• We restrict access to NPI to those employees and service providers who need to know that information to provide products or services to you.
• We maintain physical, electronic, and procedural safeguards to protect your NPI.

10. Mobile Services and SMS/TCPA Compliance

Any information we obtain from you in connection with any mobile service, including SMS services, may include your name, address, mobile phone number, mobile service provider's name, and your messages' date, time, and content.

By providing your mobile phone number and opting in to receive SMS communications from Monera Capital, you expressly consent to receive text messages from us, including marketing messages, at the phone number you provide. This consent constitutes your prior express written consent under the Telephone Consumer Protection Act ("TCPA") for us to contact you via text message.

In addition to any fee we may charge, your mobile service provider's standard messaging rates apply. All charges are billed by and payable to your mobile service provider. We will not be liable for any delays in the receipt of any SMS messages. SMS message services are provided on an AS-IS basis.

You may opt out of mobile services at any time by emailing privacy [at] moneracapitalgroup [dot] com or by replying "STOP," "END," or "QUIT" to any SMS text message received from us. Please note that opting out will not apply to any communications from third parties to whom we may have already provided your information in accordance with this Policy.

11. Linking to Third-Party Websites

Monera Capital may provide links to websites owned or operated by other companies. When you visit a third-party website, you are subject to that website's privacy and security practices, which may differ from ours. We encourage you to review the privacy policy of any website you visit before providing information.

12. Data Security

Monera Capital takes the security of your information very seriously. We have implemented administrative, technical, and physical safeguards designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. These measures include encryption of data in transit and at rest, access controls, regular security assessments, and employee training on data protection practices.

13. Data Breach Notification

In the event of a data breach involving your personal information that triggers notification obligations under applicable federal or state law (including Florida's Information Protection Act of 2014), Monera Capital will:

• Notify affected individuals as expeditiously as practicable and without unreasonable delay, but no later than 30 days after determination that a breach has occurred (or as otherwise required by applicable law)
• Provide notice to the applicable state attorney general or regulatory agency as required by law
• Include in the notification a description of the incident, the types of information involved, and the steps individuals can take to protect themselves
• Offer appropriate remedial measures, which may include credit monitoring services where warranted

14. Accessing, Updating, and Correcting Your Information

Keeping your account information up to date is very important. You may be able to review or update certain account information by logging in and accessing our Online Portal. If you cannot change the incorrect information online, or if you prefer to request changes offline, please call us at 1-833-624-3863 or email us at privacy [at] moneracapitalgroup [dot] com .

15. Changes to This Online Privacy Policy

Monera Capital reserves the right to amend this Policy at our discretion and at any time. When we make material changes to this Policy, we will post the updated Policy on the Website and update the Policy effective date. Where required by law, we will provide you with prior notice of material changes. Any changes to this Online Privacy Policy will become effective when posted unless indicated otherwise. Your continued use of our Website or products or services offered by us or through us following the posting of changes constitutes your acceptance of such changes. We encourage you to periodically review this page for the latest information on our privacy practices.

16. Opting Out of Marketing Communications

If you would like to opt out of marketing communications, please notify us by:

• Emailing us at privacy [at] moneracapitalgroup [dot] com
• Sending a letter to: 1560 Sawgrass Corporate Pkwy 4th Floor, Fort Lauderdale, FL 33323, Attn: Privacy Department
• Following the "unsubscribe" instructions in any promotional email received from us

Please note that unsubscribing from one email list does not automatically unsubscribe you from any other email list that you may be on. You may also opt out of receiving telephone calls from Monera Capital by requesting to be placed on our company-specific do-not-call list.

17. Contact Information

If you have any questions or comments about this Policy, the ways in which Monera Capital collects and uses your information, your choices and rights regarding such use, or wish to exercise your rights under applicable state or federal privacy law, please do not hesitate to contact us at:

© 2021–2026 Monera Capital Group LLC