Privacy Policy – Brickly Capital, Inc.

Effective: November 2025

This Privacy Policy is provided for informational purposes only, does not form part of any agreement, and should not be construed as creating any contractual or legal rights or obligations.

Scope of Policy

This Privacy Policy applies to all individuals whose information Brickly Capital, Inc. collects in connection with its business activities, both online and offline, with additional rights provided to California residents under applicable law. It applies to information collected through our website at bricklycapital.com, as well as through direct communications, investor documentation, and loan-related materials.

Table of Contents

  1. Information We Collect
  2. How We Use Information
  3. How We Share Information
  4. Cookies and Tracking
  5. Your Rights Under California Law
  6. Safeguards and Security
  7. Retention of Information
  8. Employee and Contractor Data
  9. Regulatory Oversight
  10. Accessibility
  11. Changes to This Privacy Policy
  12. Contact Us

1. Information We Collect

Brickly Capital, Inc. collects personal information from individuals and entities in connection with its lending, investment, and operational activities. The types of personal information collected may include identifiers, financial details, employment and income information, government identification numbers, and professional or investment-related data.

2. How We Use Information

Brickly Capital, Inc. uses personal information to evaluate and process loan applications, manage investor relationships, comply with legal and regulatory obligations, and operate its business effectively.

Brickly Capital, Inc. also maintains and provides a Financial Privacy Notice as required under the Gramm-Leach-Bliley Act (GLBA). This notice applies to borrowers, guarantors, and other individuals whose information is collected in connection with lending activities.

For investors, Brickly Capital, Inc. collects information necessary for subscription processing, know-your-customer (KYC) verification, and tax reporting. Investor data may include identity information, tax identification numbers, banking details, and accredited investor documentation.

3. How We Share Information

Brickly Capital, Inc. may share personal information with service providers, administrators, custodians, auditors, regulatory authorities, and other third parties as required to operate the fund and comply with applicable laws.

Brickly Capital, Inc. distinguishes between service providers, contractors, and third parties as defined under the California Privacy Rights Act (CPRA). Service providers and contractors are bound by written agreements restricting their use of personal information to authorized purposes only.

4. Cookies and Tracking

Brickly Capital, Inc. uses limited cookies and similar technologies necessary for website functionality and basic analytics. Brickly Capital, Inc. does not use cookies for cross-context behavioral advertising and does not sell or share personal information as defined under the California Privacy Rights Act (CPRA).

5. Your Rights Under California Law

California residents have the right to request access to, correction of, or deletion of their personal information, to limit the use of sensitive information, and to opt out of its sale or sharing. Requests may be submitted by contacting Brickly Capital, Inc. using the information provided below.

Brickly Capital, Inc. does not sell or share personal information as those terms are defined under the California Privacy Rights Act (CPRA).

6. Safeguards and Security

Brickly Capital, Inc. maintains administrative, technical, and physical safeguards designed to protect personal information. Its information security program complies with the FTC Safeguards Rule and the Gramm-Leach-Bliley Act (GLBA), and includes encryption, access controls, and employee training.

7. Retention of Information

Brickly Capital, Inc. retains personal information for as long as necessary to fulfill the purposes for which it was collected, to meet legal and regulatory obligations, and to maintain appropriate business records.

8. Employee and Contractor Data

Brickly Capital, Inc. also collects and maintains personal information relating to its employees, job applicants, and independent contractors. Such information is managed under separate internal privacy policies and notices that address employment-related data handling.

9. Regulatory Oversight

Brickly Capital, Inc. may be subject to examination or oversight by federal and state regulatory authorities with respect to its privacy and information security practices.

10. Accessibility

Brickly Capital, Inc. is committed to ensuring that its website and online services are accessible to individuals with disabilities. If you experience difficulty accessing this Privacy Policy or any part of the website, please contact the company using the information below to request an alternative format.

11. Changes to This Privacy Policy

Brickly Capital, Inc. may update this Privacy Policy from time to time. Any updates will be posted with an updated effective date.

12. Contact Us

If you have any questions about this Privacy Policy or Brickly Capital, Inc.’s data-handling practices, please contact:

Brickly Capital, Inc.
Attn: Privacy Office
12503 Sherman Way
North Hollywood, CA 91605
info@bricklycapital.com
(818) 535-0381