Welcome to our website (“Website”). We know that privacy is an important issue for our visitors and we want them to know that we take privacy seriously. Please take a minute to review our privacy policy (“Privacy Policy”), which describes what types of personally and non-personally identifiable information we collect from visitors; the purposes for which we use this information, and to whom and under what circumstances we disclose this information. The terms “we”, “us”, or “our” as used in this Privacy Policy refer to Griffin Funding.

Your use of this Website and the content and services provided through or in connection with this Website are subject to this Privacy Policy and our Terms of Use Agreement (“Agreement”). Each time you use our Website, you agree to be bound by this Privacy Policy and the current Agreement. If you do not agree to this Privacy Policy and Agreement, you must immediately discontinue use of this Website.

Personally Identifiable Information

In this Privacy Policy, personally identifiable information means information that identifies a particular individual, such as an individual’s name, postal address, e-mail address, and phone number. The following are certain situations in which we may collect personally identifiable information from you:

  • When you fill out forms or fields on this Website;
  • When you communicate with us or request information about us, this Website and our services, whether via email or other means;
  • When you participate in forums or provide user-generated content or submissions;
  • When you participate in online surveys;
  • When you participate in any of our marketing initiatives, including contests, events, or promotions;
  • When you provide your email address for identity resolution and cross-device tracking purposes;
  • When you log into your account or authenticate your identity on our Website;

It is also possible that we may collect personally identifiable information about you from sources other than you, such as through the use of tools on our site, other users of our products and services, and our business partners.

If you use any functionality on this Website allowing you to send content to a friend, then please be aware that: (a) we may display your email address to your friend; and (b) we may use information you provide about your friend to facilitate the communication and as otherwise set forth in this Privacy Policy.

Non-Personally Identifiable Information

We may collect demographic information about you, such as gender, zip code, and birth date, as well as information regarding your preferences and usage. This type of information is not, by itself, personally identifiable information. However, if we link such information with personally identifiable information in a manner that identifies a particular individual, then we will treat all such information as personally identifiable information for purposes of this Privacy Policy.

We may collect non-personally identifiable information about you through a variety of technical methods, including the following:

Collection of Usage Details and IP Address

While you use this Website, we may collect details of your visits, including, but not limited to, traffic data, location data, logs, the resources that you access, and information about your computer and internet connection, including your IP address, operating system, and browser type. We may use this information for system administration and to report aggregate information to our advertisers and business partners.

Advanced User Tracking and Analytics

We use SuperPixel v3, an advanced tracking and analytics system that automatically collects the following types of data:

  • Page Views: URLs visited, page titles, referrer information, and navigation patterns
  • User Engagement: Scroll depth, time spent on pages, exit intent behavior, and content interaction
  • Content Interaction: Video engagement (play, pause, complete), file downloads, text copying, and form interactions
  • User Behavior: Click patterns, navigation flow, idle time detection, and browsing preferences
  • Technical Information: Browser type, device information, screen resolution, viewport dimensions, and connection details

Identity Resolution and Cross-Device Tracking

When you provide your email address through forms, logins, or other interactions, we may:

  • Hash your email address using SHA256 encryption for secure identity resolution
  • Link your activities across different devices, browsers, and sessions
  • Build comprehensive user profiles that may include demographic and behavioral insights
  • Enrich data with publicly available information for marketing and service improvement purposes
  • Track cross-device behavior to provide consistent experiences across all your devices

Collection with Cookies

“Cookies” are pieces of information that a Website sends to your computer while you are viewing a Website. We may set and access cookies on your computer to track and store preferential information about you. You consent to our placement of cookies on your computer. Please note that most Internet browsers will allow you to stop cookies from being stored on your computer and to delete cookies stored on your computer. If you choose to do so, however, your use of certain aspects of this Website may be restricted.

We use the following types of cookies:

  • Essential Cookies: Session management, security, and basic website functionality
  • Analytics Cookies: SuperPixel v3 tracking system, user behavior analysis, and website optimization
  • Marketing Cookies: Facebook Pixel, Google Analytics, retargeting, and advertising campaigns
  • Preference Cookies: User settings, language preferences, and personalized content

Collection with Web beacons

“Web beacons” are electronic images, tags or scripts that allow a Website to access cookies and help track general usage patterns of visitors to a Website. Web beacons can recognize certain types of information, such as cookies, time and date of a page view, and a description of the page where the Web beacon is placed. We may use Web beacons to compile information regarding use of this Website.

How Is Your Information Used?

We may use non-personally identifiable information collected from visitors to conduct reviews of our Website, guide decisions about its development, and enhance our visitors’ online experience. We may also use such information to identify, on an aggregate basis, general trends that may, for example, assist us in determining which products our web visitors need.

We may use personally identifiable information collected from visitors for any of the following purposes: (1) to answer visitors’ questions, (2) to provide services, newsletters, and other information that visitors specifically request or register for through our Website, (3) to develop and improve our services, (4) to protect the security and integrity of our services, or (5) for internal business purposes.

We may use the information we collect to:

  • Confirm and complete transactions requested by you;
  • Provide customer support (including responding to your requests), troubleshoot and resolve problems and disputes;
  • Contact you to verify the information you provide to us;
  • Protect the security and integrity of this Website;
  • Understand and anticipate your needs, preferences, and ability to use the site efficiently;
  • Ensure this Website is of interest to you (including customization of advertising and content) and help us better understand your use of this Website;
  • Provide administrative communications to you;
  • Manage our business and operations;
  • Conduct internal reviews of this Website and administer this Website’s systems;
  • Comply with, monitor compliance with, and enforce this Privacy Policy, our Terms of Use, and any other applicable agreements and policies;
  • Provide you with promotional materials, offers, and personalized information;
  • Meet legal and regulatory requirements;
  • Analyze user behavior and engagement patterns to improve website functionality and user experience;
  • Create targeted marketing campaigns and personalized content based on your interests and behavior;
  • Integrate with third-party marketing tools (Google Analytics, Facebook, HubSpot) for enhanced analytics and advertising;
  • Build comprehensive user profiles for better service delivery and personalized experiences;
  • Track cross-device usage to provide consistent experiences across all your devices;
  • For other purposes as may be disclosed when you provide personally identifiable information or in this Privacy Policy.

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

If you do not want your personally identifiable information shared as described above, then you should not submit a Request.

Third-Party Integrations and Data Sharing

Your data may be shared with the following third-party services for the purposes described:

  • Google Analytics: Website analytics, user behavior reporting, and performance optimization
  • Facebook/Meta: Advertising campaigns, retargeting, and audience building
  • HubSpot: Customer relationship management, marketing automation, and lead nurturing
  • SuperPixel v3 Platform: Advanced user tracking, identity resolution, and behavioral analytics
  • Other marketing platforms, as configured in our tracking system

We ensure that all third-party integrations comply with applicable privacy laws and maintain appropriate data protection standards.

Choices About How We Use and Disclose Your Information

Below are some mechanisms that provide you with control over certain information:

Cookie Management

If you do not wish us to collect cookies, you may set your browser to refuse cookies, or to alert you when cookies are being sent. If you do so, please note that some parts of this Website may then be inaccessible or may not function properly.

You can also manage your cookie preferences through our cookie consent management system, which allows you to:

  • Accept all cookies for full functionality
  • Accept essential cookies only for basic website operation
  • Customize your preferences for different types of tracking
  • Withdraw consent at any time through our cookie settings

Advanced Tracking Opt-Out

You can opt out of certain advanced tracking activities by:

  • Browser Settings: Disable cookies and tracking in your browser preferences
  • Email Requests: Contact us at compliance@griffinfunding.com to opt out of data enrichment and cross-device tracking
  • Marketing Communications: Unsubscribe from marketing emails using the provided links
  • Data Deletion: Request deletion of your tracking data and user profile by contacting us

Email Offers from Us

If you do not wish to receive email offers or newsletters from us, you can opt out of receiving email information from us by using the unsubscribe process at the bottom of the email.

Data Retention

We retain your information for the following periods:

  • Behavioral and Engagement Data: Up to 2 years for analytics and marketing purposes
  • Identity Resolution Data: Up to 3 years for cross-device tracking and user profiling
  • Enriched Profile Data: Up to 2 years or until you request deletion
  • Form Submission Data: According to our standard data retention policy
  • Marketing Communications: Until you opt out or request deletion

Your Rights Regarding Tracking Data

You have the right to:

  1. Access: Request a copy of all tracking data we have collected about you
  2. Rectification: Correct any inaccurate tracking or profile data
  3. Erasure: Request deletion of your tracking data and user profile
  4. Portability: Receive your data in a structured, machine-readable format
  5. Restriction: Limit how we process your tracking data
  6. Objection: Object to certain types of data processing for marketing purposes

To exercise these rights, contact us at compliance@griffinfunding.com with your request. We will respond within 30 days.

Business Transfers

At some point, we may merge with or be acquired by another company. When that happens, then we may disclose to them the information you have provided to us, in which case we will request them to abide by this policy. We may also disclose some information to a potential acquirer, although such disclosure would be subject to restrictions on use. We specifically and expressly reserve the right to disclose, lease, sell, assign or transfer your personally identifiable information collected through this Website, and any of its databases, together with any personally identifiable information contained in such data bases, to third parties in connection with a Business Transfer. A “Business Transfer” means a sale, acquisition, merger, consolidation, reorganization, bankruptcy or other corporate change involving us and/or our affiliates, even if the Business Transfer is only being contemplated and regardless of whether the Business Transfer relates to a part or a whole of our business.

Third Party Website Links

This Website may contain links to third-party websites. Our Privacy Policy does not apply to these linked websites. In addition, we do not endorse and are not responsible for the privacy practices or content of any of the linked websites. We are not responsible for the privacy policy, terms and conditions, practices or the content of such third parties or third-party websites. These third-party websites may send their own cookies to you and independently collect data. If you visit a Website that is linked from this Website or our emails, we encourage you to read any privacy statements and terms and conditions of that third party’s website before providing any personally identifiable information.

Security

We maintain physical, electronic, and procedural safeguards to maintain the confidentiality, security, and integrity of visitors’ personally identifiable information.

We allow access to personally identifiable information only to persons and entities engaging in activities permitted by this Privacy Policy.

Although we strive to maintain the highest standards of privacy, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. We cannot guarantee or warrant the security of any information visitors transmit to us and visitors do so at their own risk.

Changes

We reserve the right to revise or change the terms of this Privacy Policy in the future to reflect modifications to our Website. We recommend that visitors check this website periodically to ensure that they are aware of our current privacy practices.

Click the link below to read through our Privacy Policy

California Consumer Privacy Act (CCPA) Policy

This Privacy Notice for California Residents supplements Griffin Funding, Inc.’s privacy policy, which is also available on our website. It applies to all visitors and users who reside in the State of California (“consumers” or “you”). Griffin Funding, Inc. has incorporated this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and other applicable laws.

If you are a California resident, you have the right to:

  1. Request we disclose to you, free of charge, the following information covering the 12 months preceding your request: a. The categories of personal information about you that we collected b. The category of sources from which the personal information was collected c. The purpose for collecting personal information about you d. The categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed and the purpose for disclosing the personal information about you e. The specific pieces of personal information we collected about you
  2. Request that we delete your personal information, unless the CCPA recognizes an exception
  3. Be free from unlawful discrimination for exercising your rights under the CCPA

Categories of Personal Information Collected (CCPA)

We collect the following categories of personal information:

  • Identifiers: Email addresses, device identifiers, IP addresses, account information
  • Internet Activity: Browsing history, search history, website interactions, click patterns
  • Geolocation Data: General location information based on IP address
  • Commercial Information: Loan applications, product interests, transaction history
  • Inferences: User profiles, preferences, behavioral patterns, demographic insights
  • Professional Information: Employment status, income information, business details

You will receive an acknowledgment of receipt of your request and an estimated completion time. Verification of your identity will be required to process any request.

If a request is submitted by a third party, on behalf of the consumer, we may require authorization and verification of identity directly from the consumer to which the private information belongs.

In some instances, we may not be able to honor your request. For example, we will not honor your request if we cannot verify your identity or if we cannot verify that you have the authority to make a request on behalf of another person. Additionally, we will not honor your request where an exception applies, such as where the disclosure of personal information would adversely affect the rights and freedoms of another consumer or where the personal information that we maintain about you is not subject to the CCPA’s access or deletion rights.

If we are not able to honor your request, you will be notified. We will not provide social security numbers, driver’s license numbers, or government-issued identification numbers, financial account numbers, account passwords or security questions and answers, or any specific pieces of information if the disclosure presents the possibility of unauthorized access that could result in identity theft or fraud or unreasonable risk to data or systems and network security.

Pursuant to the CCPA, we will work to process all verified requests within 45 days. If an extension is needed, you will be notified of the reason for the delay.

How to exercise your rights:

Complete the Online Personal Information Request form located here, and either email or print and mail to:

Griffin Funding, Inc

Attn: Compliance

2245 5th Ave, Suite 401

San Diego, CA 92101

E-mail: compliance@griffinfunding.com

Consent Management

Cookie Consent Banner

By using our website, you consent to our use of advanced tracking technologies, including SuperPixel v3 for user behavior analysis, cross-device tracking, and marketing optimization. You can customize your preferences or learn more in our Privacy Policy.

Email Consent Language

By providing your email address, you consent to:

  • Identity resolution and cross-device tracking
  • Data enrichment with demographic insights
  • Marketing communications and personalized content
  • Sharing anonymized data with marketing partners

You can opt out at any time by contacting us at compliance@griffinfunding.com or using the unsubscribe link in our emails.

Last Updated: 9/15/2025

Effective Date: 9/15/2025