Privacy Policy

Draft dated November 6, 2026. Effective date: [date approved by counsel]

Attorney review required before launch. This is a draft prepared for review by counsel and is not yet in effect. Items in square brackets must be filled in, and every section should be checked against the licenses Trulli Holdings LLC holds and the states where Loanistry operates.

This Privacy Policy explains how Loanistry, a Trulli company, collects, uses, shares and protects information when you use loanistry.com, its tools, newsletters and application (the "Service"). The Service is owned and operated by Trulli Holdings LLC, [address] ("Loanistry", "Trulli", "we", "us" or "our"). By using the Service you acknowledge this policy. It is part of our Terms of Service.

1. In short

  • We collect what you give us to match your business with funding providers, plus standard technical data about how the site is used.
  • When you apply, your application goes to Trulli, Loanistry's parent company, and to the funding providers and partners matched to your business, who use it to evaluate your request and contact you.
  • We do not sell your personal information for money. You can opt out of any cookie-based "sharing" for advertising.
  • The qualify questions run in your browser and are not sent to us.
  • Depending on where you live, you have rights to access, correct and delete your information. See section 11.

2. Information we collect

Information you give us. When you apply or contact us, we collect:

  • Identifiers and contact details: name, email, phone number, home address and business address.
  • Personal details used for verification: date of birth and Social Security number.
  • Business information: legal business name, entity type, industry, Employer Identification Number, start date, ownership percentage, and whether the business accepts card payments.
  • Financial information: monthly and annual revenue, funding amount and purpose, credit score range, existing debts and payments, tax liens and bankruptcy history, and bank statements or other documents you upload in the funding portal.
  • Records of consent: the consents you give, the wording shown to you, the time and the page.
  • Communications: emails, messages, call recordings and notes of calls with us or our partners, and newsletter sign-ups.

Information collected automatically. When you browse, we and our service providers collect device and browser type, operating system, IP address and approximate location derived from it, pages viewed, links clicked, the page that referred you, campaign tags in links, dates and times of visits, and similar usage data, using cookies, pixels, local storage, server logs and similar technologies.

Information from others. We and our partners may receive information about you and your business from consumer and business credit reporting agencies, identity verification and fraud prevention services, bank data providers you authorize, public records, funding providers (for example, the status of your application or whether you were funded), marketing and lead partners, and business data providers.

3. What stays in your browser

Answers to the qualify questions are processed in your browser to produce an estimate and a list of matching lenders, and are not sent to us. To remember which page brought you to the application and to fill in answers you already gave, the site stores non-sensitive details, such as the landing page, link source and your qualify answers, in your browser's session storage, which clears when you close the tab. After you apply, the site keeps the link to your funding portal and the time you applied in your browser's local storage so you can find the portal again; you can clear it in your browser settings. Your Social Security number and the rest of the application are not stored in your browser, and the form is cleared after you submit.

4. How we use information

  • To process your application, match your business with funding providers and pass your application to them.
  • To verify your identity, authority and information, obtain credit reports with your authorization, and detect and prevent fraud, abuse and security incidents.
  • To operate the funding portal and let you track your application and offers.
  • To contact you by phone, text and email about your application and, with your consent where required, about other financing options, products and services.
  • To send newsletters you request, and to personalize content.
  • To measure, analyze and improve the Service, our content and our advertising.
  • To comply with law, regulation, legal process and the requirements of funding partners, and to enforce our Terms and protect our rights and the rights and safety of others.
  • For any other purpose we describe when we collect the information, or with your consent.

We may create de-identified or aggregated information that no longer identifies you, and use it for any lawful purpose. We will not attempt to re-identify it.

5. How we share information

  • With Trulli and our affiliates. Loanistry is owned by Trulli Holdings LLC. Your application and related information go to Trulli's business funding marketplace and funding portal, and may be shared among Trulli's affiliated companies for the purposes in this policy.
  • With funding providers and partners. We share your application and supporting documents with lenders, funders, brokers and other financing partners that may be able to serve your business, so they can evaluate your request, make offers and contact you. Once they receive it, their own privacy policies govern how they use and keep it, and they may keep it even if you do not accept an offer.
  • With service providers. We use companies that provide hosting, data storage, form processing, identity verification, credit reporting, fraud prevention, communications, analytics, customer support and security. They may use information only to provide services to us.
  • With advertising and analytics partners. Partners may collect device and usage data through cookies and pixels on the Service to measure performance and show relevant ads. See sections 7 and 11.
  • For legal reasons. We may disclose information to comply with law, regulation, subpoena, court order or government request; to report suspected fraud; or to protect the rights, property and safety of Loanistry, Trulli, our users, partners or the public.
  • In a business transfer. If we are involved in a merger, acquisition, financing, reorganization, bankruptcy or sale of assets, information may be transferred as part of that transaction.
  • With your consent or at your direction.

6. Financial privacy (GLBA)

Applications on the Service are for business and commercial purposes. To the extent we receive nonpublic personal information about an individual that is covered by the Gramm-Leach-Bliley Act, we protect it under the administrative, technical and physical safeguards that law requires, limit its use and disclosure to the purposes permitted by that law, and provide any separate privacy notice the law requires. Information covered by the Gramm-Leach-Bliley Act or the Fair Credit Reporting Act may be exempt from some state privacy laws described below.

7. Cookies and tracking technologies

We use cookies, pixels, local and session storage, and similar technologies that are strictly necessary to run the Service, that remember your preferences, that help us understand how the Service is used, and, if enabled, that help us and our partners measure and target advertising. You can block or delete cookies in your browser settings, though parts of the Service may not work as intended. We honor Global Privacy Control signals as a request to opt out of the sale or sharing of personal information for targeted advertising, for the browser that sends the signal. Because there is no common standard for "Do Not Track" signals, we do not respond to them.

8. How we protect information

Applications are sent over encrypted connections. Your Social Security number is masked on screen, sent directly to the processing system, and is not logged or stored by this website. We and Trulli use administrative, technical and physical safeguards designed to protect information, and limit access to people who need it. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If you believe your information has been misused, contact us at [contact email]. Where the law requires, we will notify you of a security breach affecting your information.

9. How long we keep information

We keep personal information for as long as needed for the purposes in this policy, including to process applications, maintain business records, meet legal, regulatory, tax, anti-fraud and audit requirements, resolve disputes and enforce agreements. Our standard retention period is [retention period], after which we delete or de-identify the information unless the law requires us to keep it longer. Funding providers that receive your information keep it under their own retention policies.

10. Your choices

  • Email: use the unsubscribe link in any marketing email.
  • Texts: reply STOP to any text to opt out, or HELP for help.
  • Calls: tell the caller, or write to [contact email], to be placed on our internal do-not-call list.
  • Cookies: use your browser settings or a Global Privacy Control signal.
  • Funding providers: to stop contact from a provider you were matched with, contact that provider directly as well.

We may still send messages needed to process an application you submitted or to meet legal obligations.

11. State privacy rights

Residents of California and of other states with comprehensive privacy laws, including Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah and Virginia, may have some or all of these rights, subject to exceptions in those laws, including for information covered by the Gramm-Leach-Bliley Act or the Fair Credit Reporting Act and for information collected in a business-to-business context:

  • Know and access the categories and specific pieces of personal information we collect, use and disclose.
  • Correct inaccurate personal information.
  • Delete personal information we collected from you.
  • Portability: receive a copy in a usable format.
  • Opt out of the sale of personal information, sharing for cross-context behavioral or targeted advertising, and profiling that produces legal or similarly significant effects.
  • Limit the use of sensitive personal information. We use sensitive personal information, such as your Social Security number, only to process your application, verify your identity and prevent fraud, and not to infer characteristics about you.
  • Non-discrimination: we will not discriminate against you for exercising these rights.
  • Appeal: if we decline your request, you may appeal by replying to our decision, and, where the law provides, contact your state attorney general.

How to make a request. Email [contact email] with "Privacy request" in the subject line, or write to us at [address]. We will verify your request by matching information you give us with information we hold, and may ask for more. You may use an authorized agent, who must provide proof of your signed permission; we may still verify your identity directly. We will respond within the time the law requires.

California notice at collection. In the past 12 months we have collected these categories of personal information: identifiers; personal information described in California Civil Code section 1798.80 (including Social Security number, financial information and bank statements); characteristics of protected classifications (age, from date of birth); commercial information (funding needs, business revenue and debts); internet or other electronic network activity; approximate geolocation; audio and electronic information (call recordings); professional or employment-related information (business ownership and role); inferences drawn to match you with financing; and sensitive personal information (Social Security number and financial account information in documents you upload). We collect them from the sources and for the purposes in sections 2 and 4, and disclose them to the categories of recipients in section 5. We do not sell personal information for money. We may "share" identifiers and internet activity with advertising partners for cross-context behavioral advertising, which you may opt out of as described above. We do not knowingly sell or share the personal information of anyone under 16. We keep each category for the period in section 9.

Nevada residents may ask us not to sell covered information by writing to [contact email]. California residents may also ask, once a year, about disclosures to third parties for their own direct marketing under California Civil Code section 1798.83.

12. Children

The Service is for adults seeking business financing and is not directed to anyone under 18. We do not knowingly collect personal information from children. If you believe a child has given us information, contact [contact email] and we will delete it.

13. United States only

The Service is intended for businesses in the United States, and information is processed and stored in the United States. If you access the Service from elsewhere, you do so at your own initiative and consent to processing in the United States.

The Service links to websites and services we do not control, including funding providers' sites. This policy does not apply to them. Review their privacy policies before giving them information.

15. Changes to this policy

We may update this policy from time to time. The effective date at the top shows the current version. If we make material changes, we will give notice on the Service or by email where appropriate before they take effect.

16. Contact us

Trulli Holdings LLC, doing business as Loanistry, [address]. Email: [contact email], with "Privacy request" in the subject line for rights requests.