Privacy Policy

Effective Date: July 1, 2026 · Last Updated: July 1, 2026

1. Scope and Applicability

This Privacy Policy ("Policy") describes how AspireFunds, LLC and its subsidiaries, affiliates, and managed fund vehicles (collectively, "AspireFunds," "we," "our," or "us") collect, use, disclose, and protect information about individuals ("you") who visit www.AspireFundsBank.com (the "Site"), submit borrower or investor inquiries, engage with our email and communications, or otherwise interact with us.

This Policy applies to consumers, prospective borrowers, prospective and current limited partners, professional service providers, and website visitors. It does not create any rights beyond those required by applicable law and is intended to be read together with any fund offering documents, subscription agreements, and loan documentation, which may include additional or superseding privacy terms.

2. Information We Collect

Information you provide directly

• Identity and contact information: name, business affiliation, title, mailing address, email, and telephone number submitted through forms, subscription documents, or loan applications.
• Investor information: accredited investor and qualified purchaser certifications, source-of-funds representations, tax identification numbers, wire and banking instructions, subscription amounts, and beneficial ownership information required under anti-money-laundering, know-your-customer, and Corporate Transparency Act obligations.
• Borrower and guarantor information: credit application details, financial statements, tax returns, entity documentation, property and collateral information, insurance certificates, appraisals, environmental reports, and any related third-party diligence outputs.
• Correspondence: emails, call notes, meeting materials, and any files or comments you submit.

Information collected automatically

• Device and usage data: IP address, browser type, operating system, referring URLs, pages visited, and time-stamped activity captured through server logs and standard analytics tooling.
• Cookies and similar technologies: session cookies, persistent cookies, and pixel tags used to operate the Site, remember preferences, and measure engagement. See Section 9.

Information from third parties

• Credit bureaus, background-check providers, and sanctions-screening services.
• Fund administrators, transfer agents, custodians, and banking partners.
• Public records, secretary-of-state filings, property records, and litigation databases.
• Referral sources, professional service providers, brokers, and correspondents.

3. How We Use Information

We use personal information to:

• Evaluate, underwrite, and service loans; conduct credit and collateral diligence; and manage borrower relationships.
• Evaluate investor eligibility; process subscription documents; maintain capital accounts; distribute quarterly and annual reporting; and administer LP relationships.
• Perform anti-money-laundering, sanctions, know-your-customer, beneficial-ownership, and fraud-prevention screening.
• Operate, secure, and improve the Site and our communications channels.
• Comply with applicable law, including SEC, FINRA, Treasury, FinCEN, state banking, and state securities requirements.
• Respond to inquiries, provide requested information, and communicate about our funds, insights, and events.
• Enforce our terms and protect the rights, safety, and property of AspireFunds and its investors, borrowers, and personnel.

4. How We Share Information

We do not sell personal information. We may share information with:

• Service providers: fund administrators, auditors (PricewaterhouseCoopers), legal counsel (LePore Law Group), technology and hosting providers, banking partners, custodians, KYC/AML vendors, appraisers, environmental consultants, title insurers, and loan servicers, each engaged under confidentiality obligations.
• Regulators and authorities: where disclosure is required by law, subpoena, court order, or regulatory examination.
• Affiliates: our subsidiaries, general partner entities, and managed fund vehicles for operational, reporting, and compliance purposes.
• Business transactions: in connection with a proposed or actual merger, financing, sale, or reorganization of AspireFunds or a portfolio position.
• With your consent: for any other purpose disclosed to you at the time of collection.

5. Gramm-Leach-Bliley Act (GLBA) Notice

To the extent AspireFunds or any affiliate is a "financial institution" under the Gramm-Leach-Bliley Act, we provide the following notice regarding nonpublic personal information ("NPI") of consumers.

6. Data Security

We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction, including encryption in transit, access controls, vendor due diligence, employee training, and incident response procedures. No system, however, can be guaranteed against all threats. If we become aware of a security incident affecting your information, we will notify you and applicable regulators as required by law.

7. Data Retention

We retain personal information for the period required to fulfill the purposes described in this Policy, to comply with legal, tax, accounting, and regulatory obligations (including SEC Rule 204-2, IRS record-retention rules, and state banking record requirements), to resolve disputes, and to enforce our agreements. Investor and borrower records are generally retained for a minimum of seven years following the end of the applicable relationship.

8. State Privacy Rights

Depending on your state of residence, you may have rights under state privacy laws, including the California Consumer Privacy Act (CCPA/CPRA), the Virginia Consumer Data Protection Act, and comparable laws in Colorado, Connecticut, Texas, Utah, and other states, to:

• Request access to categories and specific pieces of personal information we have collected.
• Request deletion or correction, subject to legal and regulatory exceptions.
• Opt out of "sale" or "sharing" of personal information (we do not sell or share personal information as those terms are defined in the CCPA/CPRA).
• Limit the use of sensitive personal information.
• Appeal a denial of a rights request in states that provide an appeal mechanism.

Personal information collected in connection with a financial product or service is generally exempt from state consumer privacy laws to the extent it is subject to GLBA. To exercise a right, email [email protected]. We will verify your identity before responding.

9. Cookies and Tracking Technologies

The Site uses cookies and similar technologies to operate essential functions, remember preferences, measure engagement, and improve performance. You can manage cookies through your browser settings. Blocking essential cookies may impair Site functionality. We do not use cross-context behavioral advertising and do not permit third-party advertising trackers on the Site.

10. Children's Privacy

The Site is directed to institutional and accredited investors, business borrowers, and professional service providers. We do not knowingly collect personal information from children under 13, and no service offered on the Site is intended for children.

11. International Users

AspireFunds operates in the United States. If you access the Site from outside the United States, your information will be transferred to, stored, and processed in the United States, which may not offer the same data-protection protections as your home jurisdiction.

12. Changes to This Policy

We may update this Policy from time to time. The "Last Updated" date at the top reflects the most recent revision. Material changes will be posted on the Site and, where required, communicated directly to current investors and borrowers.

13. Contact Us

Questions or requests may be directed to:

AspireFunds — Privacy Office
1910 Pacific Ave, Suite 2000
Dallas, TX 75201
[email protected]
972.945.5050