Privacy Policy and KYC Policy

Fallbrook Financial Services

Fallbrook Financial Services (“Fallbrook,” “we,” “our,” and/or “us”) values the privacy of individuals who use our websites and related services (collectively, our “Services”). This Privacy Policy and KYC Policy (the “Privacy Policy”) explains how we collect, use, and disclose information from users of our Services (“Users,” “you,” and/or “your”).

By using our Services, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes.

Information we collect

We may collect a variety of information from or about you from various sources, as described below.

A. Information you provide to us

Communications.
If you contact us directly, we may ask you for information such as your name, email address, phone number, job title, employer, employer address, and other relevant business or financial information. We may receive additional information about you, including the contents of messages, attachments, or any other information you choose to provide.

When you communicate with us online, we may use trusted third-party service providers to facilitate and securely store these communications on our behalf. If you subscribe to our newsletter, we will collect certain information such as your email address. When we send you emails, we may track engagement (such as whether emails are opened) to improve our Services and communications.

Careers.
If you apply for a position with us, we may collect your contact information and resume, including education and employment history. You may also apply through third-party platforms such as LinkedIn, in which case we will collect the information you make available through those platforms.

Project information.
We may also collect information regarding tax credit monetization projects across a range of asset classes, including but not limited to low-income housing, renewable energy, film and entertainment, historic preservation, brownfield remediation, and other state and federal incentive programs. This information may include, without limitation, project name, location, descriptions, photos or videos, project specifications, credit value, applicable incentives or adders, counterparties, timelines, and related insurance or compliance documentation.

Tax credit buyer and counterparty information.
We may collect information regarding tax credit buyers, sellers, sponsors, developers, and other transaction participants, including, where applicable, location, experience with tax credits, general transaction preferences, and other relevant business information necessary to support transactions.

B. Information we collect when you use our Services

Information from cookies and similar technologies.
We and our third-party partners may collect information using cookies, pixel tags, or similar technologies. These technologies help us understand user behavior, improve our Services, and support advertising efforts.

Cookies are small text files stored on your device. We and our third-party partners may use both session cookies (which expire when you close your browser) and persistent cookies (which remain on your device for a period of time).

You can modify your browser settings to decline cookies; however, doing so may limit certain functionality of our Services.

C. Information we receive from third parties

Information from third-party services.
If you choose to connect or interact with third-party services, we may receive information such as profile details or usage data, subject to your privacy settings on those platforms.

Analytics partners.
We use analytics services, such as Google Analytics, to better understand how users interact with our Services. These providers may collect information about your use of our website and other online services. You can learn more about Google’s practices at: https://www.google.com/policies/privacy/partners/.

Advertising partners.
We work with third-party advertising partners, including Google and Microsoft, to deliver advertisements that may be relevant to you. These partners may use cookies, pixels, and similar technologies to collect information about your interactions with our website and other websites in order to provide interest-based advertising.

Some of these partners participate in industry self-regulatory programs such as the Network Advertising Initiative (https://optout.networkadvertising.org) and the Digital Advertising Alliance (https://optout.aboutads.info), which provide mechanisms for opting out of personalized advertising.

How we share information

As required by law and similar disclosures.
We may access, preserve, and disclose your information if required to do so by law, legal process, or governmental request, or if we believe such action is necessary to protect our rights, your safety, or the safety of others.

Transaction-related sharing.
We may share information with parties involved in transactions you are participating in, including counterparties, advisors, legal counsel, and other relevant stakeholders, solely as necessary to facilitate such transactions.

Aggregated and de-identified information.
We may use aggregated and de-identified information for internal business purposes, such as analytics, benchmarking, and improving our Services. Such information will not identify you or your organization. Fallbrook does not sell personal or identifiable client information.

Consent.
We may disclose your information with your permission.

Your choices

Marketing communications.
You may opt out of receiving promotional emails by following the unsubscribe instructions included in those emails. You may still receive administrative or transactional communications from us.

If you choose not to provide certain information, some features of our Services may not function as intended.

Third parties

Our Services may contain links to third-party websites or services that we do not control. This Privacy Policy does not apply to those third parties, and we encourage you to review their privacy policies before providing them with your information.

Security

We implement reasonable administrative, technical, and physical safeguards designed to protect the information we collect and maintain. While we strive to protect your information, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

Children’s privacy

Our Services are not directed to children under the age of 13, and we do not knowingly collect personal information from children.

International visitors

Our Services are hosted in the United States and intended for users located within the United States. If you access our Services from outside the U.S., you understand that your information may be transferred to, stored, and processed in the United States.

Know Your Customer (KYC) and compliance

As part of our commitment to compliance, risk management, and maintaining the integrity of the transactions we support, we may conduct due diligence on current or prospective users of our Services.

This may include identity verification, Know Your Customer (KYC) procedures, anti-money laundering (AML) screening, fraud prevention, sanctions screening, and other compliance-related checks (“Due Diligence Checks”).

By using our Services, you agree to cooperate with such Due Diligence Checks and provide requested information as reasonably necessary. These checks may be conducted directly by Fallbrook or through trusted third-party service providers.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page, and the revised version will be effective upon posting. If we make material changes, we may notify you through our Services or by other means.

Contact information

If you have any questions, comments, or concerns about this Privacy Policy or our data practices, please contact us at:

team@fallbrookfinance.com