Privacy Policy

Strattington Capital is a commercial finance platform focused on asset-based financing, equipment finance, and sale-leaseback structures for business-purpose transactions. This Policy is intended to provide clear notice about our information practices. It does not create a client, advisory, fiduciary, lending, or agency relationship, and it does not modify any confidentiality agreement, financing agreement, engagement letter, term sheet, nondisclosure agreement, or other written agreement you may have with Strattington Capital.

1. Scope of this Policy

This Policy applies to information collected through strattingtoncapital.com, related web pages, contact forms, email communications, phone calls, business development communications, referral communications, and financing inquiry processes. It also applies when business owners, officers, employees, brokers, advisors, referral sources, capital providers, vendors, or other representatives submit information to us.

Strattington Capital focuses on commercial, business-purpose financing. The website is not intended for consumer loans, personal credit products, residential mortgage loans, deposit accounts, investment advice, tax advice, legal advice, or securities offerings. If a separate financial privacy notice, confidentiality agreement, engagement letter, or transaction-specific notice applies to a particular relationship or transaction, that separate notice or agreement will control to the extent it conflicts with this Policy.

2. Information we collect

We may collect the following categories of information, depending on how you interact with us and what you choose to provide.

3. Sources of information

We may collect information directly from you, from your company, from a broker or referral source, from a sponsor or advisor, from lenders and capital providers, from service providers, from publicly available sources, from business databases, from government records, from UCC or lien searches, from credit or background information providers where permitted, and from other parties involved in evaluating or documenting a commercial financing opportunity.

4. How we use information

We may use information for the following business and operational purposes:

• To respond to inquiries and communicate with you.
• To evaluate potential financing fit, structure options, collateral value, transaction timing, and referral opportunities.
• To conduct diligence, underwriting support, risk review, fraud prevention, sanctions screening, identity or authority verification, and conflict checks where appropriate.
• To connect relevant financing inquiries with potential lenders, lessors, capital sources, appraisers, professional advisors, service providers, or referral partners.
• To prepare indications, proposals, term sheets, engagement documents, closing documentation, or other transaction materials.
• To administer relationships with borrowers, sponsors, brokers, advisors, capital providers, vendors, and service providers.
• To operate, secure, troubleshoot, maintain, and improve the website and related systems.
• To maintain records, comply with legal and regulatory obligations, enforce agreements, protect rights, and respond to lawful requests.
• To send business communications about our services, subject to applicable opt-out rights.

5. How we disclose information

We may disclose information in the following circumstances:

• Lenders, lessors, and capital sources: We may share financing inquiry information, business information, collateral information, and diligence materials with potential capital sources to evaluate financing options.
• Service providers: We may share information with website hosting providers, form processors, cloud storage providers, email and communications providers, analytics providers, customer relationship management providers, diligence providers, and other vendors that support our operations.
• Brokers, sponsors, advisors, and referral sources: If you come to us through a broker, sponsor, advisor, referral source, or other intermediary, we may communicate with that party about the inquiry or transaction unless you instruct us otherwise and we are able to honor that instruction.
• Professional advisors: We may share information with attorneys, accountants, auditors, consultants, insurance providers, appraisers, valuation firms, and other professional advisors.
• Legal, compliance, and protection purposes: We may disclose information to comply with law, regulation, subpoena, court order, governmental request, sanctions or anti-fraud obligations, dispute resolution, collections, enforcement of rights, or protection of our business, users, counterparties, or others.
• Business transactions: We may disclose or transfer information in connection with a merger, acquisition, financing, reorganization, sale of assets, joint venture, assignment, or similar business transaction involving all or part of our business.

We do not knowingly sell personal information for money. We also do not knowingly share personal information for cross-context behavioral advertising. If we later use advertising technologies or data practices that constitute a sale or sharing under applicable law, we will update this Policy and provide any required opt-out mechanism.

6. Cookies, analytics, and similar technologies

The website may use cookies, pixels, tags, log files, and similar technologies to operate the website, remember preferences, understand website traffic, troubleshoot performance, improve content, and protect against misuse. These technologies may collect website and device information such as IP address, browser type, pages viewed, referring page, date and time of visit, and approximate location.

You can usually set your browser to block or delete cookies. Blocking cookies may affect website functionality. At this time, because there is no uniform industry standard for browser-based “Do Not Track” signals, the website may not respond to all such signals. Where required by applicable law, we will honor recognized universal opt-out mechanisms, such as a Global Privacy Control, if the website uses technologies that require such an opt-out.

7. Retention

We retain information for as long as reasonably necessary for the purposes described in this Policy, including to evaluate inquiries, communicate with you, maintain business and transaction records, satisfy legal or regulatory obligations, resolve disputes, prevent fraud, enforce agreements, and support legitimate business operations. Retention periods may vary depending on the type of information, the nature of the relationship, transaction status, legal requirements, and whether the information is needed for active or potential financing activity.

8. Security

We use reasonable administrative, technical, and physical safeguards designed to protect information in our possession. These safeguards may include access controls, vendor review, secure storage practices, confidentiality expectations, and technical measures appropriate to the nature of the information. No website, email system, form provider, cloud platform, or transmission method is completely secure. You should use secure channels when transmitting confidential financial, ownership, banking, tax, identity, collateral, or diligence materials.

9. Your privacy choices and rights

Depending on where you live and the nature of your relationship with us, you may have rights under applicable privacy laws. These rights may include the right to request access to personal information, correction of inaccurate information, deletion of personal information, a copy of personal information, information about categories of personal information collected or disclosed, limitation of certain sensitive personal information uses, opt-out of certain sales, sharing, or targeted advertising, non-discrimination for exercising privacy rights, and appeal of certain denied requests.

To submit a privacy request, contact us using the methods in the Contact section below. We may need to verify your identity and authority before processing a request. We may deny or limit a request where permitted by law, including where we cannot verify the request, where information is subject to legal, regulatory, contractual, security, transaction, recordkeeping, fraud prevention, privilege, confidential business, or other exceptions, or where the information relates to a commercial transaction or business contact that is exempt from certain consumer privacy laws.

California privacy notice

If California privacy law applies to us and to your information, the categories of personal information we may collect are described in Section 2 above, the sources are described in Section 3, the purposes are described in Section 4, and the categories of recipients are described in Section 5. We do not knowingly sell or share personal information for cross-context behavioral advertising. We do not knowingly use sensitive personal information for purposes other than those permitted by applicable law, such as providing requested services, security, legal compliance, and transaction evaluation.

Other U.S. state privacy laws

Residents of certain U.S. states may have similar rights under their state privacy laws. If a state privacy law applies to us and to your information, you may submit a request using the Contact section below. We will respond consistent with applicable law and may provide instructions for appeal if required.

Marketing choices

You may opt out of non-transactional marketing communications by using the unsubscribe instructions in an email, replying with an opt-out request, or contacting us. We may still send transactional, relationship, legal, security, or service-related communications.

10. Children

The website and our services are intended for business users and are not directed to children. We do not knowingly collect personal information from children under 13. If you believe a child has provided personal information to us, contact us and we will take appropriate steps to delete the information where required.

11. International visitors

Strattington Capital is based in the United States. If you access the website or submit information from outside the United States, your information may be collected, processed, stored, and disclosed in the United States and other jurisdictions where our service providers operate. Those jurisdictions may have data protection laws different from those in your location.

12. Changes to this Policy

We may update this Policy from time to time. The “Last updated” date identifies the latest version. Material changes will be posted on this page or otherwise communicated where required by law. Your continued use of the website after an updated Policy is posted means you acknowledge the updated Policy.

13. Contact us

For privacy questions or requests, contact Strattington Capital through the website contact form, by phone, or by mail: