Privacy Policy

1. What this policy covers

This policy describes how Today Capital Group LLC (“TCG”, “we”, “us”) handles information about you when you visit todaycapitalgroup.com and its subdomains (the “Site”), check your eligibility or apply for financing through us, use the client portal, or communicate with us by phone, text, email or in the portal (together, the “Services”). It applies to both the individuals who use the Site and the businesses they represent.

It does not cover the funders we present your request to. Each funder has its own privacy policy, which governs what it does with your information once it has it. Our Terms of Use explain the Services themselves.

2. Information we collect

Information you give us

• Contact and identity details: your name, email address, phone number, home address, date of birth and, at the full-application stage, your Social Security number.
• Business details: legal name, trade name, tax identification number, address, industry, start date, ownership, monthly revenue, time in business, whether the business takes card payments, and any existing financing.
• Financial information: the amount you are requesting, the credit score range you tell us, bank statements or other documents you upload, and transaction data from a bank account you choose to connect through a data provider.
• Your communications with us: messages you send in the portal, emails, texts and what you tell us on calls, which may be recorded where the law allows.
• Your consents and agreements: the consent to be contacted and the application agreement you accept, with the time and the version you accepted.

Information collected automatically

When you use the Site we collect the kind of information websites normally collect: your IP address, device and browser type, the pages you view and how long you stay, the page or advertisement that brought you here and any campaign parameters in the link, and identifiers stored in cookies and similar technologies. On the marketing pages we also use a session-analytics tool that records how visitors interact with a page, such as clicks and scrolling, with what you type masked. These tools do not run on the application pages. See section 5.

Information from other sources

• Credit bureaus, business credit and identity-verification providers, when you have authorised us to obtain reports.
• Bank data providers, when you choose to connect an account.
• Funders, who tell us where your request stands, what they offer and whether it funded.
• Referral partners, if someone referred you to us, and our advertising and analytics partners, who tell us which campaign a visit came from.
• Public records and publicly available business information.

3. How we use information

• To provide the Services: check eligibility, prepare your request, present it to funders, keep you informed and help you understand the offers.
• To communicate with you about your request, by phone, text, email and the portal, in line with the consent you gave.
• To verify your identity and the information you provided, and to detect and prevent fraud.
• To operate, secure and improve the Site and the Services, including understanding how visitors use the Site.
• To market our Services to you, where you have not opted out, and to measure our advertising.
• To comply with the law, respond to lawful requests, enforce our Terms and protect our rights and the rights of others.

4. How we share information

• Funders and their service providers. This is the point of the Services: we share your application, documents and reports with the funders we present your request to, often more than one, so they can evaluate it. Each funder then handles your information under its own policy.
• Service providers who work for us under contract, such as the companies that host the Site and our database, our customer-relationship system, email and text delivery, analytics and advertising measurement, and bank-data connections. They may use your information only to provide their service to us.
• Credit bureaus and verification providers, when we request a report or verification you have authorised.
• Professional advisers, such as our attorneys and accountants, where needed.
• Authorities and others when the law requires it, to respond to a subpoena or lawful request, to prevent fraud or harm, or to protect the rights, property or safety of TCG, our clients or others.
• A successor, if TCG is involved in a merger, acquisition, financing or sale of assets, in which case your information may be transferred as part of that transaction.
• Anyone else you ask or permit us to share it with.

We do not sell personal information for money. We do not share the details of your application with anyone for their own marketing. Advertising cookies on the marketing pages may be treated as “sharing” under California law; section 11 explains how to opt out.

5. Cookies and similar technologies

The Site uses cookies and similar technologies for four things:

• Essential operation: keeping you signed in, remembering where you are in an application, and protecting the Site from abuse. These cannot be switched off without breaking the Site.
• Analytics: understanding which pages are visited and how, through tools such as Google Analytics.
• Session analytics on the marketing pages: recording interactions such as clicks and scrolling, with typed input masked, through tools such as Microsoft Clarity.
• Advertising: where we run advertising, measuring whether an advertisement on a platform such as Google, Meta or TikTok led to a visit or an application, and reaching people who have visited the Site with our advertising elsewhere.

Analytics and advertising technologies run only on the marketing pages of the Site, never on the pages where you enter your application or on the pages behind a sign-in. You can control cookies through your browser settings, which usually let you block or delete them, and through the choices in section 7. A notice on your first visit lets you untick analytics and advertising cookies, and “Cookie settings” in the footer of every page lets you change that at any time; when they are off, analytics runs only in the cookieless mode described below and no session-recording or advertising tag is loaded. Blocking essential cookies may stop parts of the Site from working.

Global Privacy Control

Global Privacy Control (GPC) is a setting in some browsers and browser extensions that tells every website you visit not to sell or share your personal information. We treat it as a valid request to opt out of sharing under California law and process it without any action on your part: when your browser sends the signal, no advertising or session-recording tag is loaded on any page of the Site, Google Analytics runs only in a cookieless mode that sets no cookies and sends no identifiers (so we can count that a page was visited, without profiling you or reporting your visit for advertising), and the footer of every page shows “Opt-Out Preference Signal Honored” so you can see that it has been applied. The signal applies to the browser or device that sends it, not to other devices or to an account, and it does not affect the information you give us directly or the handling of your application. We process opt-out preference signals in a frictionless manner: nothing about the Site changes for you and we do not show a notice in response, other than the line in the footer.

To turn it on, use the privacy settings in a browser that supports it, such as Firefox, Brave or DuckDuckGo, or install an extension such as Privacy Badger; globalprivacycontrol.org explains the options. We do not respond to the older “Do Not Track” setting, which has no agreed meaning.

6. Calls, texts and email

When you give us your number and email and tick the consent box, you agree that we may contact you about your funding request by phone, text and email, including with automated technology, as described in section 5 of the Terms of Use. Consent is not a condition of any service. To stop texts, reply STOP; for help, reply HELP. To stop marketing email, use the unsubscribe link in any message. To stop calls, tell the caller or contact us. We will still send messages needed to handle an open request, such as a sign-in code, unless you close the request.

7. Your choices

• Marketing: opt out of texts, calls and marketing email as described in section 6.
• Cookies: use your browser controls, and where a cookie choice is offered on the Site, the choice you make there.
• Access and correction: you can see and update much of your information in the client portal, or ask us to correct it.
• Deletion: you can ask us to delete your information. We will do so unless we need to keep it to complete a request you made, to comply with the law, or for another legitimate reason we will explain.
• Not providing information: you can always choose not to give us information, but we may then be unable to provide the Services.

To make a request, contact us using the details in section 14. We may need to verify that a request comes from you, or from someone you authorised, before we act on it.

8. How we protect information

We use administrative, technical and physical safeguards appropriate to the sensitivity of the information. Connections to the Site are encrypted in transit. Social Security numbers entered on the application are passed to our client-management system for the funders’ review and are not stored by the website’s own systems. Access to client information is limited to staff who need it for their work, and the portal signs you in with a one-time code rather than a password that could be reused elsewhere. Our Security Policy has more detail, including how to report a concern. No method of transmission or storage is completely secure, so we cannot promise absolute security.

9. How long we keep information

We keep information for as long as your request is open and afterwards for as long as we need it to serve you, to meet legal, regulatory, accounting and audit obligations, to resolve disputes and to enforce our agreements. When we no longer need information we delete it or de-identify it. An eligibility check that is started but never gives us a way to contact you is kept only for a short time before it is deleted.

10. Children

The Site and the Services are for businesses and the adults who run them. We do not knowingly collect information from anyone under 18. If you believe a minor has given us information, contact us and we will delete it.

11. Notice to California residents

This section applies to California residents and supplements the rest of this policy, as required by the California Consumer Privacy Act (“CCPA”). Our separate Notice at Collection summarises it at the points where we collect information.

Categories of personal information we collect

In the twelve months before the date of this policy we have collected the following categories of personal information, from the sources and for the purposes described in sections 2 and 3:

• Identifiers: name, postal address, email address, phone number, IP address, online identifiers, and Social Security number and tax identification number at the application stage.
• Information described in California Civil Code section 1798.80(e): contact details, financial information and signature.
• Commercial information: the financing you request and existing financing you tell us about.
• Financial information: bank statements, bank transaction data you authorise, revenue and credit history.
• Internet or other electronic network activity: how you use the Site and interact with our advertising.
• Professional or employment-related information: your role and ownership in the business.
• Our underwriter’s assessment of which financing types may fit your request, based on the information described above.
• Sensitive personal information: Social Security number, financial account information, and log-in credentials for the portal.

How we disclose it

We disclose these categories for business purposes to the recipients described in section 4: funders and their service providers, our own service providers, credit and verification providers, professional advisers, and authorities where required. We do not sell personal information for money. Advertising cookies on the marketing pages may be “sharing” for cross-context behavioural advertising under the CCPA; the categories involved are identifiers and internet activity. A browser sending Global Privacy Control is treated as having opted out of that sharing, as section 5 describes. We do not knowingly sell or share the personal information of anyone under 16. We use and disclose sensitive personal information only for the purposes the CCPA permits, such as providing the Services you requested, verifying your identity, preventing fraud and complying with the law, so no right to limit its use arises.

Your rights

• To know what personal information we have collected about you, including the categories, the sources, the purposes, the categories of recipients and the specific pieces.
• To delete personal information we collected from you, subject to the exceptions in the CCPA.
• To correct inaccurate personal information we hold about you.
• To opt out of the sharing of your personal information for cross-context behavioural advertising. Turning on Global Privacy Control in your browser does this automatically; section 5 explains how.
• Not to be treated differently for exercising these rights. We do not offer financial incentives in exchange for personal information.

How to exercise them

Email info@todaycapitalgroup.com or call (818) 351-0225. Tell us which right you are exercising and give us enough information to verify that you are the person the information is about, or that you are authorised to act for them; we will ask for details that match our records and may ask for more if the request concerns sensitive information. An authorised agent may submit a request on your behalf with your written permission. To opt out of sharing, turn on Global Privacy Control in your browser, which we process in a frictionless manner, or contact us; you do not need to verify your identity to opt out. We will respond within the time the CCPA allows, normally 45 days.

California’s “Shine the Light” law (Civil Code section 1798.83) lets residents ask about disclosures of personal information to third parties for those third parties’ own direct marketing. We do not make such disclosures.

12. Residents of other states

If you live in another state with a consumer privacy law, you may have similar rights to access, correct, delete and opt out. Contact us using the details in section 14 and we will handle your request in line with the law that applies to you. If we decline a request, you may appeal by replying to our response.

13. Changes to this policy

We may update this policy from time to time. The date at the top is the date the current version took effect. If a change materially affects how we use information you have already given us, we will tell you in a reasonable way, such as a notice on the Site or an email.

14. Contact us

Email info@todaycapitalgroup.com, call (818) 351-0225, or write to Today Capital Group LLC, 22837 Ventura Blvd, Woodland Hills, CA 91364.