At MEC Capital (“the Company,” “we,” “our,” or “us”), we recognize that our commercial borrowers and accredited investment partners entrust us with highly sensitive financial, corporate, and personal data. Protecting this information and ensuring absolute transactional data security is a foundational pillar of our risk management and corporate governance frameworks.

This Privacy Policy explicitly details how we collect, process, isolate, share, and protect your Non-Public Personal Information (NPI) in strict compliance with the Gramm-Leach-Bliley Act (GLBA), the FTC Safeguards Rule, and other applicable state and federal data privacy standards.

1. Categories of Non-Public Personal Information (NPI) We Collect

To properly evaluate single-family residential assets, issue commercial proof-of-funds letters, execute loan drawings, and verify Regulation D Rule 506(c) investor accreditation thresholds, we must collect comprehensive NPI. This data is collected directly via our secure application forms, onboarding portals, and third-party verifications, including:

• Individual & Entity Identification Data: Full legal name, corporate entity documentation (e.g., Articles of Organization, Operating Agreements), Employer Identification Numbers (EIN), Social Security Numbers (SSN), government-issued Driver’s Licenses, and Passports.
• Deep Financial Analytics & Forensic Data: Federal tax returns (both individual and corporate schedules), detailed bank statements, corporate profit & loss (P&L) statements, K-1 distributions, and brokerage account summaries.
• Credit, Risk, & Background Metrics: Credit bureau reports, corporate background checks, active or historical litigation filings, and bad-boy carveout tracking histories.
• Investment Placement & Banking Data: Third-party accredited investor certification letters, bank wire transfer instructions, routing numbers, and capital account distribution histories.

2. Comprehensive Data Security Framework (FTC Safeguards Rule Compliance)

In alignment with the FTC Safeguards Rule, MEC Capital maintains a rigorous, multi-layered Information Security Program designed to preserve the confidentiality, integrity, and availability of all collected records:

• Bank-Grade Encryption Protocols: All sensitive financial documents, underwriting materials, and tax assets uploaded to our platform are fully encrypted using AES-256 bit encryption at rest and Transport Layer Security (TLS) in transit.
• Mandatory Multi-Factor Authentication (MFA): Access to any backend systems, fund administration panels, or borrower and investor pipelines requires mandatory, hardware- or app-based multi-factor authentication across all authorized endpoints.
• The Principle of Least Privilege: Access to any NPI or underwriting file is strictly partitioned. Internal data access is restricted solely to MEC Capital’s Managing Partner, Sheldon Holder, and specifically authorized compliance administrators who require the data to execute underwriting or regulatory operations.
• Continuous Security Monitoring & Assessments: Our infrastructure undergoes regular vulnerability monitoring, API security audits, and systemic reviews to discover and remediate potential security threats before they affect our pipeline.
• Secure Destruction Policies: Physical retention of records is avoided. Any physical NPI generated during loan closing or evaluation is maintained in locked, restricted-access facilities and permanently destroyed via commercial cross-cut shredding processes once federal data retention requirements expire.

3. Permitted Permutations of Data Sharing

MEC Capital does not sell, lease, rent, or trade your personal information, corporate details, or financial analytics to third-party marketers or outside data brokers under any circumstances. We disclose collected information strictly as necessary to execute standard business functions, restricted to the following pathways:

• Authorized Institutional Service Providers: Data may be shared with trusted transactional counter-parties—including our fund administrators, certified public accountants (CPAs), closing title companies, independent legal counsel, and third-party investor accreditation verifiers—who are bound by strict contractual non-disclosure agreements (NDAs) and privacy standards.
• Statutory & Regulatory Enforcement: Information will be disclosed when mandated by law, such as to comply with Anti-Money Laundering (AML) and Know Your Customer (KYC) regulations, federal subpoenas, court orders, or direct IRS reporting procedures (e.g., issuing Forms 1099 or Schedule K-1).
• Affiliated Corporate Entities: NPI may be systematically shared between MEC Capital and its wholly owned or controlled corporate affiliates solely to fulfill the financial or lending services you have directly requested.

4. Telephony & SMS Communication Privacy Disclosures

If you opt to provide a mobile telephone number to MEC Capital through any contact form, portal interface, or application module, you acknowledge and agree that we may utilize this number to deliver automated transactional reminders, construction draw updates, and pipeline notifications.

• Strict Non-Sharing Policy: Mobile numbers, opt-in consent records, and data collected specifically for text messaging purposes are entirely excluded from any standard affiliate sharing models. Your mobile data will never be shared, sold, or transferred to any third party or outside affiliate for marketing or promotional reasons.
• Opt-Out Mechanisms: You retain the absolute right to terminate text communications at any time. You can reply “STOP” to any automated text message received from MEC Capital to be immediately purged from our telephony broadcast infrastructure.

5. Digital Tracking, Performance Cookies, & Analytics

Our public-facing website and secure portal landing pages utilize persistent cookies, tracking pixels, and secure browser analytics to enhance platform navability, review user engagement, and assess the performance of our “Fast Funding, Proven Results” digital campaigns.

You retain the ability to adjust your personal web browser settings to block or delete cookies entirely; however, disabling tracking cookies may cause specific interactive tools, user dashboards, and application submission portals to experience reduced functionality.

6. Notification of Policy Modifications

MEC Capital reserves the right to amend this Privacy Policy to reflect shifts in regulatory frameworks or technical security practices. If any material modifications are enacted regarding how we govern, process, or secure your sensitive NPI, we will provide direct notification to all active investors and borrowers via the primary email address on file, alongside publishing the updated framework to our corporate web domain.

7. Office of the Data Privacy Officer

For comprehensive inquiries concerning our encryption protocols, security workflows, or the handling of your financial records under GLBA guidelines, connect directly with our compliance desk:

• Corporate Entity: MEC Capital
• Inbound Communications Routing: info@MECcapitalFund.com