Legal

Privacy Policy

Effective August 29, 2026

Jackson Hill Capital Group LLC, doing business as Jackson Hill Capital ("Jackson Hill Capital," "JHC," "we," "us," or "our"), respects the privacy of borrowers, guarantors, sponsors, beneficial owners, brokers, lenders, service providers, website visitors, and other users of our services. This Privacy Policy explains what information we collect, how we use and disclose it, and the choices available to you.

1. Who we are

JHC is a Connecticut limited liability company that operates as a commercial real estate mortgage intermediary and loan-processing platform. JHC does not extend credit in its own name, is not the lender of record, does not fund or close loans, and does not service loans. JHC helps collect, organize, evaluate, and route business-purpose commercial real estate financing requests to independent third-party lenders that make their own credit decisions.

2. Information we collect

Depending on your relationship with JHC and the services you use, we may collect:

• Contact and account information, such as name, business name, title, email address, phone number, mailing address, login credentials, and account identifiers.
• Identity and verification information, such as date of birth, government-issued identification details, photographs or document images, device information, and verification results provided through identity-verification vendors.
• Commercial financing and property information, including ownership, entity, guarantor, sponsor, property, rent roll, lease, income, expense, debt, valuation, loan request, lender, and transaction information.
• Financial information, including financial statements, tax documents, bank or liquidity information, credit-related information, and other materials you submit or authorize us to obtain.
• Consumer report information for natural-person borrowers, guarantors, principals, or sponsors where permitted by law and after obtaining any required separate authorization.
• Derived and analytical information that JHC or its service providers create from information described above, such as document classifications, extracted data, calculations, summaries, underwriting metrics, completeness indicators, validation results, exception flags, lender-eligibility assessments, and other inferences.
• Communications and support records, including emails, calls, uploaded documents, comments, and other correspondence.
• Technical and usage information, such as IP address, device and browser information, log data, security events, cookies or similar technology data, and interactions with our website and platform.

3. How we use information

We may use information to operate and secure our platform; create and administer accounts; verify identity; process commercial financing requests; evaluate completeness and eligibility; identify potentially qualified lenders; communicate with users and counterparties; perform fraud, compliance, sanctions, security, and risk checks; obtain or use consumer reports where separately authorized and otherwise permitted by law; maintain records; improve our services; enforce agreements; and comply with legal or regulatory obligations.

JHC may use automated systems and artificial-intelligence-assisted tools to extract, classify, organize, calculate, compare, validate, analyze, and summarize information; identify inconsistencies or missing items; derive underwriting metrics; flag exceptions; assess completeness or eligibility; and assist with lender matching and routing. These tools assist JHC's processing and analysis. They do not make an independent lender's decision whether to extend credit or determine the final terms on which a lender may offer credit.

4. Identity verification and Persona

JHC may use Persona and other service providers to verify the identity of natural persons associated with commercial financing requests, including borrowers, guarantors, sponsors, principals, and beneficial owners. Information submitted for verification may be processed by those providers on our behalf and may include identification documents, photographs or other images, device information, identity attributes derived from submitted materials, and verification results. If a verification process involves biometric identifiers, biometric information, or another category of sensitive data for which applicable law requires a specific notice, consent, or release, JHC or its provider will present the applicable materials at or before collection. This Privacy Policy does not replace any such separate notice, consent, or release. A provider's processing may also be subject to its applicable privacy terms.

5. How we disclose information

We may disclose information to:

• Independent third-party lenders and their agents to evaluate or process a financing request, but JHC will distribute financing-request information to prospective lenders only after the applicable borrower or authorized representative has completed any submission, distribution, or information-sharing authorization required by JHC, unless disclosure is otherwise authorized or required by law.
• Service providers that support identity verification, hosting, communications, document extraction or processing, automated or AI-assisted analysis, analytics, security, fraud prevention, credit reporting, compliance, and other business functions.
• Professional advisers, auditors, insurers, financing or transaction counterparties, and other parties as reasonably necessary for legitimate business purposes.
• Government authorities, regulators, courts, law-enforcement agencies, or other persons when required by law or when reasonably necessary to protect rights, safety, property, or the integrity of our services.
• A successor or prospective successor in connection with a merger, financing, reorganization, sale, or transfer of all or part of our business or assets, subject to appropriate safeguards.

JHC does not sell personal information for money. JHC does not use protected-characteristic information to route commercial financing requests to lenders.

JHC requires service providers to process information under applicable contractual and legal restrictions. JHC's vendor-governance standard is that confidential or customer information supplied to an AI or automated-processing provider may not be used to train a generalized model unless JHC has specifically approved that use and the use is otherwise lawful. This statement describes JHC's governance standard; applicable vendor terms control the provider's binding obligations.

6. Consumer reports

Where JHC obtains or uses a consumer report, it will do so only for a permissible purpose, after obtaining any separate authorization, certification, disclosure, or consent required by applicable law. Nothing in this Privacy Policy or the Terms of Service constitutes a separate consumer-report authorization where one is required.

JHC, participating lenders, consumer reporting agencies, and other parties remain responsible for the notices and other duties applicable to each of them under law based on their respective roles, including who obtained or used a report and who made or communicated a decision. Nothing in this Policy transfers or expands another party's legal responsibility.

7. Cookies and similar technologies

We may use cookies and similar technologies for authentication, security, preferences, service functionality, diagnostics, and analytics. Where legally required, we provide appropriate notice and choices regarding non-essential cookies. You can also control cookies through your browser settings, although disabling certain cookies may affect functionality.

8. Data retention

We retain information for as long as reasonably necessary for the purposes described in this Policy, including to process transactions, maintain business and compliance records, resolve disputes, enforce agreements, satisfy legal obligations, and protect our services. Retention periods vary depending on the type of information and applicable legal, contractual, and operational requirements. Any specific retention or destruction commitment presented in a separate legally required notice or consent will control for the information it covers.

9. Security

We use administrative, technical, and organizational safeguards designed to protect information against unauthorized access, use, alteration, disclosure, or destruction. No system is completely secure, and we cannot guarantee absolute security.

10. Your choices and privacy rights

Subject to applicable law and exceptions, you may request access to, correction of, or deletion of certain personal information. Depending on the law applicable to you and to the information, you may also have rights concerning portability, sensitive data, consent withdrawal, profiling, or certain disclosures. These rights are not identical in every jurisdiction, and exemptions may apply to JHC or to particular information or processing activities. You may exercise an applicable right by contacting us. We may need to verify your identity before processing a request, and we may retain information where required or permitted by law. We will not unlawfully discriminate against you for exercising an applicable privacy right.

11. Children

Our services are intended for adults and businesses involved in commercial real estate transactions. They are not directed to children under 18, and we do not knowingly collect personal information from children.

12. Third-party services and links

Our services may link to or integrate with third-party websites, products, or services. Their privacy practices are governed by their own policies, not this Privacy Policy.

13. Changes to this Policy

We may update this Privacy Policy from time to time. We will post the updated version with a revised effective date and provide additional notice when required by law.

14. Contact us

For privacy questions or requests, contact Jackson Hill Capital at info@jacksonhillcapital.com, or by mail at PO Box 18, Middlefield, CT 06455.

This Privacy Policy should be read together with our Terms of Service.