Privacy Policy and Financial Privacy Notice

Qualified Commercial LLC does not sell lead information or borrower information. We use information to operate the platform, communicate about accounts and funding files, conduct internal file review, prepare lender packages, support AI-assisted workflows, and submit validated packages to selected lending companies or authorized service providers. Certain advertising and analytics tools may be considered targeted advertising or sharing under some privacy laws; opt-out options are described below.

This Privacy Policy and Financial Privacy Notice explains how Qualified Commercial LLC collects, uses, protects, retains, and discloses information through the QualifiedCommercial website, web portal, mobile applications, messaging tools, e-signature flows, AI-assisted funding tools, agent/realtor workflows, and related services. It applies to borrowers, business owners, guarantors, real estate professionals, brokers, agents, internal users, and other users of the platform.

This policy is intended to cover personal information, financial information, nonpublic personal information, documents uploaded to a funding file, communications, consent records, device data, and related operational records. It should be read together with the Terms and Conditions, Funding/AI/Communications Disclosure, and Signature Authorization Packet.

Account information, including name, business name, email address, phone number, role, login information, contact preferences, and account status.

Funding file information, including property address, loan purpose, requested amount, estimated values, bank statements, entity documents, tax documents, financial documents, credit-related information, identity information, real estate documents, and other information supplied by a user, agent, realtor, broker, or authorized representative.

Connected business bank information, when a user chooses to link an account through Plaid, Inc., including the financial institution name, account name and last four digits, and the product-specific information selected for that funding file. Plaid Assets may provide account identity, balances, and up to 210 days of transaction history for an underwriting Asset Report. Plaid Statements may provide available bank-produced statement PDF files for a requested range of up to twenty-four months. A file may use either product or both.

Bank connection authorization records, including the disclosure text shown, its version, the date and time of authorization, IP address, device information, and the identity of the person who authorized the connection.

Credit authorization and underwriting information, including consent records, credit pull authorization status, internal file review results, AI-generated observations, underwriting notes, lender package status, and lender responses.

Payment and credit card authorization information, including authorized amount, payment purpose, card brand, last four digits, expiration month/year, payment token or processor reference, billing information, and authorization/audit records. We do not intentionally store CVV/CVC codes and should not store full raw card numbers in the QualifiedCommercial database.

Communications information, including emails, SMS/text messages, mobile push notifications, in-app messages, chat transcripts, call notes, support tickets, delivery statuses, opt-in and opt-out records, and campaign/notification logs.

Device and usage information, including IP address, browser, operating system, mobile device type, app version, time zone, pages/screens viewed, session data, clicks, consent events, and system logs.

Advertising and analytics information, including cookie identifiers, pixel events, ad interactions, source/medium/campaign data, retargeting audiences, conversion events, and aggregated analytics from tools such as Meta/Facebook, Google Ads, and similar platforms.

Real estate professional lead/client information uploaded by a realtor, broker, or agent, including lead/contact details, client notes, task status, file stage, communications, and delegated AI pipeline instructions.

E-signature records, including document version, signer identity, signature method, checkbox confirmations, IP address, device data, timestamp, audit trail, final PDF, certificate of completion, and document hash or integrity record.

To create, maintain, and secure user accounts and funding files.

To verify identity, authority, consent, and eligibility to use the platform.

To conduct internal file review, AI-assisted analysis, document validation, scenario review, and preliminary funding assessment.

To prepare, organize, and submit validated lender packages to selected third-party lending companies, funding partners, processors, underwriters, and service providers for real underwriting and funding review.

To obtain, document, and retain authorizations for credit card payments, hard credit pulls, file sharing, electronic signatures, electronic records, SMS/email/push communications, and related account notices.

To communicate by email, SMS/text message, phone, push notification, in-app message, and other channels about accounts, pending files, document requests, signatures, funding updates, platform activity, and service announcements.

To support realtor, broker, and agent workflows, including AI pipeline delegation, task tracking, client engagement, and file preparation.

To provide customer support, troubleshooting, security monitoring, fraud prevention, compliance review, and audit records.

To improve the platform, train internal workflows, measure performance, analyze conversion activity, debug errors, and develop new features.

To run advertising, retargeting, measurement, attribution, and audience management through tools such as Meta/Facebook and Google Ads, subject to opt-out rights and applicable law.

To comply with law, enforce agreements, respond to lawful requests, protect rights, investigate misuse, and defend claims.

QualifiedCommercial uses AI-assisted tools to review files, identify missing information, produce observations, support underwriting preparation, help agents manage pipelines, and generate internal or borrower-facing communications. AI output may be incomplete, inaccurate, delayed, inconsistent, or based on limited information. AI output is not a final loan approval, final underwriting decision, legal advice, tax advice, appraisal, valuation, commitment to lend, or servicing instruction.

Final lending decisions, loan terms, approvals, denials, credit conditions, rate locks, document conditions, and post-closing servicing are controlled by the applicable lender, funding company, servicer, or other third party. Qualified Commercial LLC does not represent that every projection, scenario, internal term, prequalification, or AI-generated recommendation will close as projected.

We do not sell borrower, lead, or realtor-uploaded client information for money. We do not use realtor-uploaded leads to independently solicit or compete for that client outside the relationship and file purpose provided to us by the realtor, broker, or agent, except where the client independently contacts us, law requires action, or the realtor/client relationship has been separately authorized.

We may disclose information as follows:

To selected lending companies, funding partners, processors, underwriters, credit/reporting vendors, and service providers when a funding package is validated, authorized, or ready for underwriting review.

To service providers that help operate the platform, including cloud hosting, AWS infrastructure, Twilio, AWS End User Messaging, or another messaging provider for text message delivery, email delivery, payment processing, analytics, identity verification, document generation, e-signature, customer support, and security vendors.

To Plaid, Inc. ("Plaid") when a user chooses to connect a business bank account. Plaid acts on the user's behalf to retrieve the Assets data, Statement PDFs, or both that are selected for the funding file and authorized by the user. Plaid collects the login information entered into Plaid's own connection window, together with account identifiers, authorized account and product information, and device information. Those login credentials are not received or stored by Qualified Commercial. Plaid is an independent controller of the information it collects, and Plaid's use of that information is governed by Plaid's End User Privacy Policy at https://plaid.com/legal/#end-user-privacy-policy rather than by this policy.

To Meta/Facebook, Google Ads, and similar advertising/analytics platforms for retargeting, conversion tracking, analytics, and campaign measurement. These activities may be considered targeted advertising or sharing under some privacy laws even though we do not sell information for money.

To realtors, brokers, agents, or authorized representatives associated with a client file, when needed to manage the file, complete tasks, communicate with the client, or process a funding request.

To comply with law, legal process, regulatory inquiry, lender or investor review, fraud/security investigation, dispute resolution, or rights enforcement.

In connection with a merger, financing, reorganization, sale, assignment, or transfer of business assets, subject to reasonable confidentiality and legal requirements.

Because the platform supports commercial and real estate financing workflows, we treat financial and nonpublic personal information with heightened care.

Everyday business purposes (operating accounts, processing funding files, preparing lender packages, responding to authorized requests, maintaining records): Yes, we share. You cannot limit this sharing where it is needed to provide the service, complete the funding workflow, comply with law, or protect the platform.

With selected lenders, funding partners, credit/reporting vendors, processors, underwriters, and service providers for underwriting and funding review: Yes, when authorized or needed for a file. You may stop using the service or withdraw consent before submission when possible, but withdrawal may prevent funding review.

For our own marketing, retargeting, conversion measurement, and platform improvement: Yes, limited to permitted uses. You may opt out of marketing emails, SMS marketing, push notifications, cookies, and targeted advertising as described below.

Connecting a bank account is optional. A user may upload bank-produced statement PDFs instead, including when an institution does not support Plaid Statements, and we can process a funding file using the evidence available for review.

For each funding file, authorized staff select Plaid Assets, Plaid Statements, or both, and the user sees and authorizes the selected scope before connecting. The connection is read-only and cannot move funds, initiate payments, or create charges. Plaid Assets may provide balances and up to 210 days of transaction history for an underwriting Asset Report. Plaid Statements may provide available bank-produced Statement PDFs for a requested range of up to twenty-four months.

Selected information may refresh approximately every thirty days while the applicable product remains enabled and the bank remains connected. Information retrieved through Plaid is stored with the funding file and may be reviewed by the same AI-assisted and human underwriting tools used for uploaded evidence. Plaid's own collection is governed by its End User Privacy Policy at https://plaid.com/legal/#end-user-privacy-policy, and Plaid maintains end-user controls at https://my.plaid.com.

A user may ask us to disconnect a linked bank account at any time by emailing support@qualifiedcommercial.com. Disconnection or disabling a product stops future retrieval for that connection or product. Evidence already retrieved remains part of the funding file as described under Data Retention.

With nonaffiliated companies for their independent marketing unrelated to your funding request: No.

Realtor-uploaded leads or client contacts sold to unrelated third parties: No, we do not sell those leads or contacts.

We send two distinct kinds of text message and we treat them as two distinct permissions. Account and application messages relate to a funding file you or your representative opened: secure links to connect a bank account, document requests, signature requests, status updates, and security or login messages. Promotional and marketing messages are announcements of new loan programs, rate updates, and offers. Agreeing to one does not agree you to the other, and each is asked for on its own checkbox.

Providing a mobile number, creating an account, accepting an invitation, starting a funding file, or using the platform does not by itself enroll anyone in text messages. We send account and application text messages only after the owner of the mobile number gives separate, affirmative consent through an unchecked transactional SMS control. SMS consent is optional and is not a condition of purchase, applying for funding, receiving funding, or using the platform; email remains available for required file communications.

We send marketing text messages only where the recipient has given prior express written consent by ticking a separate unchecked control specific to marketing messages. Consent to receive marketing text messages is not a condition of purchase, of applying for funding, or of receiving any service from us. You can decline it and still use everything we offer.

Message frequency varies. Message and data rates may apply. Reply STOP to any message to unsubscribe, and you will receive one confirmation that no further messages will be sent. Reply HELP to any message, or email support@qualifiedcommercial.com, for help. Carriers are not liable for delayed or undelivered messages.

No mobile information, phone number, or SMS consent is sold, rented, or shared with third parties or affiliates for their own marketing or promotional purposes. Phone numbers and consent records are shared only with the messaging providers who deliver the messages on our behalf, and those providers are contractually restricted to that purpose alone. Consent to receive text messages from us is never transferred to any other party.

Where a Qualified Commercial representative collects your consent in person, we record who obtained it, the exact wording you agreed to, the date and time, and the network address of the device it was entered on. You may ask us for a copy of that record, or ask us to delete your number, at any time by contacting support@qualifiedcommercial.com.

Opting out of text messages does not opt you out of email. Transactional and account emails continue as long as you have an active file with us, because they carry things like document and signature requests that the file cannot proceed without. You may unsubscribe from marketing emails using the unsubscribe link in any of them. Mobile push notifications are controlled through your device or app settings.

We may use cookies, pixels, SDKs, tags, and similar technologies from Meta/Facebook, Google Ads, analytics providers, and other partners to measure traffic, understand use of the platform, improve campaigns, attribute conversions, and show retargeting ads. Retargeting ads may appear in a user's social media feed, search results, display placements, or other digital channels after interacting with QualifiedCommercial.

These technologies may process device identifiers, IP address, browser information, event data, pages/screens visited, and campaign identifiers. We do not use these tools to sell lead information or realtor-uploaded client lists. Users can control cookies through browser settings, device settings, platform opt-outs, ad preference tools, or by contacting us at the email listed in this policy.

We use administrative, technical, and physical safeguards designed to protect information, including encryption in transit and at rest where appropriate, access controls, role-based permissions, authentication controls, logging, monitoring, backups, and vendor review. No system can be guaranteed completely secure. Users are responsible for protecting their login credentials, devices, email accounts, and phone numbers.

We may use AWS and other infrastructure providers. The platform may experience downtime, latency, interrupted access, data delays, message delays, or degraded performance due to AWS outages, third-party vendor issues, maintenance, cybersecurity events, internet outages, mobile carrier issues, or other conditions beyond our control.

We seek to minimize sensitive information where possible. However, funding files, credit authorizations, bank statements, tax records, identity documents, entity documents, property documents, and other uploaded records may contain sensitive information needed to evaluate, prepare, or submit a funding package. We use encryption and access controls for such records and limit access to authorized personnel, representatives, service providers, and selected lending parties who need the information for the funding workflow.

Payment card data should be handled through tokenized or hosted payment providers when possible. We do not intentionally store CVV/CVC codes after authorization and should not store full raw card numbers in platform databases or signed PDFs.

We retain information for as long as reasonably necessary to operate the platform, maintain account and funding records, comply with legal and regulatory obligations, support lender or investor review, document authorizations, resolve disputes, enforce agreements, prevent fraud, and maintain audit trails. Retention periods may vary by record type, lender requirement, law, and business need.

Access or correction requests may be sent to support@qualifiedcommercial.com.

Users may request deletion of certain account information, subject to legal, security, transactional, funding, audit, lender, regulatory, and record-retention requirements.

Users may opt out of marketing emails through unsubscribe links where provided.

Users may opt out of any SMS program at any time by replying STOP. Opting out of SMS does not close a funding file; required communications can continue by email.

Users may control mobile push notifications through device or app settings.

Users may manage cookies and retargeting through browser/device settings and ad platform preference tools.

Withdrawal of a required non-SMS authorization may prevent us from continuing a funding file, submitting a package to lenders, or providing the feature covered by that authorization.

The platform is intended for business, real estate, funding, and professional use by adults. It is not directed to children under 13, and we do not knowingly collect personal information from children under 13.

We may update this policy from time to time. The version and effective date above identify the current policy. Continued use of the platform after an update means the user accepts the updated policy, except where additional notice or consent is required by law.

Questions, requests, opt-out instructions, or privacy concerns may be sent to Qualified Commercial LLC, 14 53rd St #408N, Brooklyn, NY 11232, email: support@qualifiedcommercial.com.