Privacy Policy

Last Revised: August 2023

1. General

We know that your privacy is important to you, and we work hard to earn and keep your trust. Mainstreet Financial, LLC (“Company,” “the Company,” “we,” “us,” and “our,”) respects your privacy and is committed to protecting your privacy through our compliance with this Privacy Policy (the “Policy”).

This Policy describes:

• The types of information we collect from you or that you may provide when you visit our website available at: https//www.Mainstreetfinancial.com (collectively, our “Website”).
• Our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Policy applies to information we collect on this Website or in emails and other electronic messages between you and this Website, and information gathered when you interact with our advertising on third-party websites if such advertisements include links to this Policy.

This Policy does not apply to information collected by us offline or through any other means, including on any other website operated by the Company or any third party, or information collected by any third party through any application or content (including advertising) that may link to or be accessible from the Website (for further information, see below, “Third-party Websites”).

Please read this Policy carefully to understand our practices regarding your information and how we will treat it. If you do not agree with our policies and practices, then please do not use our Website. By using our Website, you agree to the terms of this Policy. This Policy may change from time to time (see below, “Changes to this Policy”). Your continued use of our Website after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

2. Website Terms of Use; Other Agreements

This Policy should be read in conjunction with any applicable Website Terms of Use and Website Cookie Policy, into which this Policy is incorporated by reference.

3. What We Collect and How We Collect It

To ensure that we provide you with the best possible experience, we will store, use, and share personal information about you in accordance with this Policy. Personal information is information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user, household or device (“Personal Information”).

You may provide us Personal Information as a buyer, seller or user of the Website (referred to throughout this Policy as “you,” “your” and “user”). In particular, the Website has collected the following categories of Personal Information from users of the Website within the last twelve (12) months:

Category

Examples

Collected

Category: Identifiers.

A real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, personal credit score, whether you have been convicted of a felony.

YES

Category: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, address, telephone number.

YES

Category: Protected classification characteristics.

Age range.

YES

Category: Commercial information.

Legal practice name, business address, industry tenure, records of purchasing or consuming histories or tendencies, financing information, AUM, revenue and income information, loan obligations, operating account balance, business equity ownership.

YES

Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

NO

Internet or other similar network activity.

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

YES

Geolocation data.

Physical location or movements.

NO

Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

NO

Professional or employment-related information.

Current or past professional history.

YES

Non-public education information.

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

NO

Inferences drawn from other Personal Information.

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

NO

We obtain the categories of Personal Information listed above from the following categories of sources:

• Directly from you. For example, when you:
  • provide information about your company, business and applicable transaction;
  • submit a questionnaire;
  • subscribe to one of our e-newsletters; or
  • communicate with us, such as request information.
• Indirectly from you. For example, through information we collect from you in the course of providing our services to you.
• Directly and indirectly from activity on our Website. For example, from website usage details that are collected automatically. For more information on automatic information collection, please review our Cookie Policy.

The information that you provide in each case will vary. In some cases, you may be able to provide Personal Information via email or free text boxes, such as contacting the Company to request further information. When providing your Personal Information, please provide only relevant information and do not provide unnecessary sensitive information, such as Social Security numbers, credit card information or other sensitive personal data, unless required for our services.

Information of Other Individuals. As a user of the Website, you may have the opportunity to provide information of another company or other individuals, such as providing seller or buyer information in the pre-approval questionnaire. When providing such information, you are solely responsible for obtaining the necessary consents and authorizations from any individuals in accordance with applicable data security laws and regulations, and the Company shall not be responsible or held liable for your failure to obtain the necessary consents.

4. How We Use Your Information

The information we gather and that you provide is collected to provide you information and the services you request, in addition to various other purposes, including, but not limited to:

• providing the information, products and services you request;
• security, credit or fraud prevention purposes;
• subject to your written consent, requesting a consumer report;
• using your information to run a FINRA Broker Check;
• providing you with effective customer service and support;
• providing you with a personalized experience when you use the Website;
• contacting you with special offers and other information we believe will be of interest to you (in accordance with any privacy preferences you have expressed to us);
• contacting you with information and notices related to your use of the Website;
• inviting you to participate in surveys and providing feedback to us (in accordance with any privacy preferences you have expressed to us);
• better understanding your needs and interests;
• improving the content, functionality and usability of the Website;
• improving our products and services;
• improving our marketing and promotional efforts; and
• any other purpose identified in an applicable privacy notice, click-through agreement or other agreement between you and us.

5. How We Share Your Information

We may share your Personal Information by disclosing it to a third party for a business purpose. For example, when you submit a credit authorization form, we may share relevant information to obtain a consumer report about you or your business. When we disclose your Personal Information, we enter into a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except for the purposes set forth in the contract.

We do not sell or lease your Personal Information to any third party. If we ever decide to sell Personal Information, we will update you via this Policy and provide you with an opportunity to opt out of sales of your Personal Information.

In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for one or more business purposes:

• Identifiers;
• Commercial information;
• Personal information categories listed in the California Customer Records statute;
• Professional or employment-related information; and
• Internet or other network activity information.

We disclose your Personal Information for a business purpose to the following categories of third parties:

• Banks. When you use the Company’s services to obtain a loan, the Company may share your Personal Information with partnered banks in order to fund the loan.
• Prospective Buyers. When you use the Company’s services to assist in selling your business, the Company may share your Personal Information with prospective buyers.
• Our affiliates.
• Third Party Vendors. Third party vendors provide services that enhance our Website, products and services to you (such as vendors for credit card processing, advertising and marketing and customer support).

Except as described in this Policy, we will not share your information with third parties without your notice and consent, unless it is under one of the following circumstances:

• Legal Reasons.
  • We believe that disclosure is reasonably necessary to comply with any applicable law, regulation, subpoena, or court order;
  • To respond to duly authorized information requests from law enforcement or other governmental authorities;
  • To enforce our agreements, policies, or the Terms of Use;
  • To investigate and prevent security threats, fraud, or other malicious activity; or
  • To respond to an emergency that we believe in good faith requires us to disclose such information to assist in preventing the death or serious bodily injury of any person or Company employee.”
• Sale of Business or Merger. There are circumstances where the Company may decide to buy, sell, or reorganize its business in selected countries. Under these circumstances, it may be necessary to share or receive Personal Information with prospective or actual partners or affiliates. In such circumstances, the Company will ensure your information is used in accordance with this Policy.

6. Your Choices and Selecting Your Privacy Preferences

We want to provide you with relevant information that you have requested. When possible, we will always provide options as to what information we collect and how you can manage any preferences that pertains to such information.

If we provide subscription-based services, such as email newsletters, we will allow you to make choices about what information you provide at the point of information collection or at any time after you have received a communication from us while you are subscribed. Transactional or service-oriented messages, such as delivery confirmation messages, are usually excluded from such preferences, as such messages are required to respond to your requests or to provide goods and services, and are not intended for the purposes of marketing.

When you provide your email on the Website, you acknowledge and agree that we may send you marketing emails regarding our products or services. After you receive these emails, you may opt out of them at any time by selecting the “unsubscribe” link at the bottom of each email. Please note that by opting out or unsubscribing you may affect other services you have requested we provide to you, in which email communication is a requirement of the service provided.

7. Text Messaging

You may have the opportunity to receive SMS or "text" messages, pre-recorded voice messages or auto-dialed phone calls from the Company, its affiliates and related entities as well as third parties. Such messaging may be used to authenticate your identity or mobile device, as well as provide you informational updates about services or products you may have requested. In providing your mobile device number or cell phone number to the Company, you knowingly consent to such communications from the Company or for the Company to use your cell phone number or mobile device number in accordance with the Company’s Terms of Use. In providing your number, you represent that you have the authority to agree to receive text messages at the telephone number that you provide to the Company, or from which you sent the text message request to us. You further acknowledge that no purchase is required to opt into this service, and you may opt out at any time by following the instructions provided in our communications to you.

Any such communications you receive from us will be administered in accordance with your preferences and this Policy.

8. Accuracy and Access to Your Personal Information

We strive to maintain and process your information accurately. We have processes in place to maintain all of our information in accordance with relevant data governance frameworks and legal requirements. We employ technologies designed to help us maintain information accuracy on input and processing.

Where we can provide you access to your Personal Information in our possession, we will always ask you for a username and password to help protect your privacy and security. We recommend that you keep your password safe, that you change it periodically, and that you do not disclose it to any other person or allow any other person to use it.

To view and change the Personal Information that you have provided to us, you can contact us directly for assistance.

9. Information of Minors

We do not intentionally seek to gather information from individuals under the age of eighteen (18). We do not target the Website to minors, and would not expect them to be engaging with our Website or services. We encourage parents and guardians to provide adequate protection measures to prevent minors from providing information unwillingly on the internet. If we are aware of any Personal Information that we have collected about minors, we will take steps to securely remove it from our systems.

10. Third-party Websites

This Policy does not apply to websites or other domains that are maintained or operated by third parties or our affiliates. Our Website may link to third-party websites and services. For example, if you click on an advertisement on this Website, you may be taken to another website that we do not control. These links are not endorsements of these websites, and this Policy does not extend to them. Because this Policy is not enforced on these third-party websites, we encourage you to read any posted privacy policy of the third-party website before using the service or website and providing any information.

11. Important Notice & Disclaimers

Your Personal Information will always be processed by the Company in accordance with this Policy unless otherwise agreed to in writing. Nonetheless, it is important to advise you that certain privacy laws do not apply to the Website or our Services.

• Gramm Leach Bliley Act (“GLBA”). Although we facilitate investment advice and lending services, we are not a financial institution and therefore not subject to the requirements of GLBA in the operating of this Website.
• Fair Credit Report Act (the “FCRA”). While the Company may use your information to request a consumer report on your behalf and only subject to your written consent, the Company is not a “consumer reporting agency” or “reseller” as those terms are defined under the FCRA. The Company does not process, assemble, or merge any Personal Information to create or modify any consumer report. Accordingly, the FCRA does not apply to the Company’s processing of Personal Information as described in this Policy.

12. Your California Rights

Shine the Light law. At this time, the Company does not disclose Personal Information to third parties for their direct marketing to you. If the Company decides to make such disclosures to third parties, the Company will update this Policy. If you have questions about such disclosures or if you wish to opt out of any such disclosures, you may send an email to info@MainstreetFinancial.com; or write us at: 601 Carlson Pkwy, Ste 1050, Minnetonka, MN 55305.

Do Not Track Signals. Other than as disclosed in this Policy, the Website does not track users over time and across third-party websites to provide targeted advertising. Therefore, the Website does not operate any differently when it receives Do Not Track (“DNT”) signals from your internet web browser.

WE DO NOT SELL YOUR PERSONAL INFORMATION. If we ever decide to sell Personal Information, we will update you via this Policy and include a link entitled “Do Not Sell My Personal Information,” to provide you with an opportunity to opt out of sales of your Personal Information.

California Consumer Rights. If you are a California consumer, as defined by the California Consumer Privacy Act of 2018 (the “CCPA”), you may be afforded additional rights with respect to your “Personal Information” as that term is explicitly defined under California law. Any Personal Information we collect is collected for the commercial purpose of effectively providing our services to you, as well as enabling you to learn more about, and benefit from, our services. You may exercise each of your rights as identified below, subject to our verification of your identity.

1. Access. You have the right to request that we disclose certain information to you about our collection, use and disclosure of your Personal Information over the past twelve (12) months. Any disclosures we provide will only cover the 12-month period preceding the receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
2. Prohibit Data Sharing. When applicable, you may prohibit the sharing of your Personal Information. In your request, please explain how you wish us to prohibit the sharing of your Personal Information, and which categories of third parties you want to prohibit from receiving your Personal Information. When such prohibitions are not possible to provide our services to you, we will advise you accordingly. You can then choose to exercise any other rights under this Policy.
3. Portability. Upon request and when possible, we can provide you with copies of your Personal Information. When such a request cannot be honored, we will advise you accordingly. You can then choose to exercise any other rights under this Policy.
4. Deletion. You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. Where applicable, we will ensure such changes are shared with trusted third parties.
5. Non-Discrimination. If a California data subject exercises his or her rights under California law, including the CCPA, we shall not discriminate against that California resident by denying our goods or services, charging different prices or rates to similarly situated consumers, providing a different level or quality of our goods or services, or taking any other adverse action.
6. Exercising your rights. If you are a California resident who chooses to exercise the rights listed above, you can:
   1. Submit a request via email at Info@MainstreetFinancial.com; or
   2. Call us at (844) 635-3632 to submit your request.

Only you, or someone legally authorized to act on your behalf, may make a request related to your Personal Information. If an authorized agent makes a request on your behalf, we may require proof that you gave the agent permission to submit the request.

Responding to Your Request. Upon receiving your request, we will confirm receipt of your request by sending you an email confirming receipt. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the Personal Information. In some instances, such as a request to delete Personal Information, we may first separately confirm that you would like for us to in fact delete your Personal Information before acting on your request.

We will respond to your request within forty-five (45) days. If we require more time, we will inform you of the reason and extension period in writing.

In some cases our ability to uphold these rights for you may depend upon our obligations to process Personal Information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, listed below, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request. We may deny your deletion request if retaining the information is necessary for us or our service providers to:

• Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

13. For Website Users Outside of the United States

Our Website is designed for use by individuals in the United States only. We do not warrant or represent this Policy or the Website’s use of your Personal Information complies with the laws of any other jurisdiction. Furthermore, to provide you with our services, we may store, process, and transmit information in the United States and other locations around the world, including countries that may not have the same privacy and security laws as yours. Regardless of the country in which such information is stored, we will process your Personal Information in accordance with this Policy.

14. Safeguarding the Information We Collect

We use reasonable technical, administrative, and physical safeguards in order to protect your Personal Information against accidental loss and from unauthorized access, use, alteration, and disclosure. However, we can never promise 100% security. As a user, you have a responsibility, as well, to safeguard your information through the proper use and security of any online credentials used to access your Personal Information, such as a username and password. If you believe your credentials have been compromised, please change your password. Please also notify us of any actual or suspected unauthorized use.

15. Changes to this Policy

This Policy describes our current policies and practices with regard to the information we collect through this Website. We are continually improving and adding to the features and functionality of this Website along with the products and services we offer through this Website. If we make any changes to this Policy, a revised Policy will be posted on this webpage and the date of the change will be reported in the “Last Revised” block above. You can get to this page from any of our webpages by clicking on the “Privacy Policy” link (usually at the bottom of the screen).

16. How to Contact Us

We value your opinions and welcome your feedback. To contact us about this Policy or your Personal Information, please contact us at:

Mainstreet Financial, LLC
601 Carlson Pkwy,
Suite 1050
Minnetonka, MN 55305
Email: Info@MainstreetFinancial.com