Privacy Policy

PRIVACY POLICY & SMS TERMS OF SERVICE

Effective Date: February 24, 2026


This Privacy Policy and SMS Terms of Service (“Policy”) governs the collection, use, disclosure, and protection of information by All Fresh Holdings LLC, doing business as All Fresh Capital (“All Fresh Capital,” “Company,” “we,” “our,” or “us”) through www.allfreshcapital.com (the “Site”) and related services.

This Policy is incorporated into and subject to our Terms of Use. In the event of a conflict, the Terms of Use control.

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SECTION 1 – COMPANY STATUS
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All Fresh Capital provides business funding solutions and consulting services. We are not a bank and, unless explicitly stated in writing, we are not a direct lender. We work with third-party lenders, funding partners, financial institutions, and service providers.

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SECTION 2 – INFORMATION WE COLLECT
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We may collect:

A. Personal & Business Information
– Name
– Business name
– Address
– Email address
– Phone number
– EIN or SSN (where legally required)
– Revenue information
– Bank statements
– Government-issued identification
– Ownership information
– Any information voluntarily submitted

B. Automatically Collected Information
– IP address
– Browser/device type
– Cookies and tracking technologies
– Website usage data

C. Financial & Credit Information
By submitting an application, you authorize us and our funding partners to obtain consumer and/or business credit reports and background information for underwriting and funding purposes in compliance with the Fair Credit Reporting Act (FCRA) where applicable.

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SECTION 3 – HOW WE USE INFORMATION
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We use collected information to:
– Evaluate funding eligibility
– Match applicants with funding providers
– Communicate via phone, email, and SMS
– Prevent fraud and identity theft
– Comply with regulatory obligations
– Improve website performance and services
– Enforce agreements and protect legal rights

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SECTION 4 – INFORMATION SHARING
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We may share information with:
– Lenders and funding partners
– Financial institutions
– Underwriting providers
– Payment processors
– CRM and marketing platforms
– Legal, regulatory, or governmental authorities when required

We do not sell personal information for monetary compensation.

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SECTION 5 – GLBA-STYLE FINANCIAL PRIVACY NOTICE
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To the extent applicable, we follow principles consistent with the Gramm-Leach-Bliley Act (GLBA) regarding safeguarding nonpublic personal information. We implement administrative, technical, and physical safeguards designed to protect financial information.

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SECTION 6 – UDAAP COMPLIANCE
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We are committed to avoiding unfair, deceptive, or abusive acts or practices (UDAAP). We strive to present funding terms accurately and transparently. Funding approvals, rates, and terms are determined solely by third-party providers unless otherwise stated.

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SECTION 7 – DATA RETENTION & SECURITY
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We retain information as long as necessary to:
– Fulfill business purposes
– Comply with legal obligations
– Resolve disputes
– Enforce agreements

We implement commercially reasonable safeguards; however, no transmission over the Internet is 100% secure.

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SECTION 8 – YOUR PRIVACY RIGHTS
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Depending on jurisdiction, you may have rights to:
– Access personal data
– Request correction
– Request deletion (subject to legal exceptions)
– Opt out of marketing communications

California (CCPA/CPRA): California residents may request disclosure of categories of data collected and request deletion subject to statutory exceptions.

Nevada Residents: Nevada residents may request to opt out of certain future sales of covered information.

Canada (PIPEDA): For Canadian users, we comply with applicable privacy laws, including PIPEDA. Users may request access or correction of personal information subject to identity verification.

To exercise rights, contact: support@allfreshcapital.com

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SECTION 9 – CHILDREN’S PRIVACY
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Our services are intended for individuals 18 years or older. We do not knowingly collect information from minors.

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SECTION 10 – ARBITRATION & DISPUTES
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Any disputes relating to privacy or data use shall be governed by the arbitration and dispute resolution provisions contained in our Terms of Use.

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SECTION 11 – SMS TERMS & CONSENT
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By providing your phone number, you expressly consent to receive transactional and marketing communications from All Fresh Capital, including via automated dialing systems, prerecorded voice messages, and SMS text messages, where permitted by law.

Message frequency may vary. Message and data rates may apply.

You may opt out at any time by replying STOP to any SMS message. For assistance, reply HELP or contact support@allfreshcapital.com.

Consent to receive marketing messages is not a condition of obtaining funding.

We comply with the Telephone Consumer Protection Act (TCPA), CAN-SPAM Act, and applicable state communication laws.

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SECTION 12 – CHANGES TO THIS POLICY
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We may update this Policy at any time. Changes will be posted with a revised Effective Date.

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SECTION 13 – CONTACT INFORMATION
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All Fresh Holdings LLC
DBA All Fresh Capital
Website: www.allfreshcapital.com
Email: support@allfreshcapital.com