Privacy Policy

This Privacy Policy explains how Star Advantage Funding LLC ("Star Advantage," "we," "us" or "our") collects, uses, shares, protects and keeps information when you visit staradvantagefunding.com, submit a form, use our client portal or lender intake, sign documents with us, or otherwise communicate with us (together, the "Services"). It is a notice of our practices; it is not a contract. Our Terms of Use and any signed engagement agreement govern our services.

Our Services are designed for businesses and for people acting for a business, such as hotel owners, real estate investors, business buyers, their owners and guarantors, and lenders and other capital providers.

1. Information we collect

Contact and inquiry information. Name, company, title, email address, phone number, mailing address, how you heard about us, and the basics of your deal or need, such as property type and address, purchase price, loan amount, timing and the kind of financing you are seeking.

Client portal information and documents. Information and documents you upload or that we request to prepare your financing request. These may include:

• business and personal tax returns and Schedules K-1;
• business and personal financial statements, including personal financial statements;
• bank and brokerage statements;
• rent rolls, operating statements and other property or business records;
• driver's licenses, passports, and green cards, visas or other immigration documents; and
• organizational documents and information about owners, members, guarantors and affiliates.

These documents often contain Social Security or taxpayer identification numbers, government identification numbers, dates of birth, account numbers, income, assets and liabilities, and citizenship or immigration status. We treat all of this as sensitive.

Information about other people. If you give us information about another person, such as a co-owner, spouse, guarantor or key employee, you confirm that you have their permission to do so and that you have told them how we will use it.

Lender and capital-provider information. If you are a lender or capital provider, we collect your contact details and the lending criteria you share, such as loan types, size ranges, geographies, property types, pricing indicators, fees and compensation terms.

Account and sign-in information. Your email address, the one-time codes and links we send you, a password if you choose to set one (stored only in a protected, hashed form), and, if you sign in with Google, the name, email address and account identifier Google shares with us. We do not receive your Google password.

Electronic signature records. Your typed name, the date and time, your IP address and browser, the verification code steps, and a digital fingerprint of the document you signed.

Communications. Emails, messages, call notes and meeting notes.

Technical and security information. IP address, browser and device type, pages requested, dates and times, and security signals used to detect bots and abuse (including through Cloudflare Turnstile). We also keep audit logs that record who accessed or changed a portal record or document, and when.

Information from others. With your authorization, information from lenders, capital providers, sellers, brokers, your accountants and other advisers involved in your transaction. We may also use publicly available business information, such as company registrations, property records and professional profiles.

We do not use facial recognition, and we do not create biometric identifiers (such as face geometry or fingerprints) from the documents you provide. Identification documents are read only for the printed text and data on them, such as name, date of birth, document number and expiration date.

Please do not send us bank or other account passwords or login credentials. Where a document we do not need contains a Social Security number or account number, you may redact it. We will tell you when a lender requires the full document.

2. How we use information

• respond to inquiries and decide whether we can help;
• provide the advisory, transaction and financing-coordination services you request, including preparing and presenting your financing request or package to prospective lenders and capital providers you authorize;
• match lenders' criteria with client needs;
• verify identity, run the client portal, deliver documents securely, and keep audit records;
• send sign-in codes, security notices, reminders and status updates;
• send occasional business emails about our services, which you can opt out of at any time;
• protect the Services and our clients, including preventing fraud, spam and unauthorized access;
• comply with law and legal process, keep business and tax records, and establish, exercise or defend legal claims; and
• for other purposes we describe to you at the time and, where required, with your consent.

3. Automated processing and artificial intelligence

To work faster and more accurately, we use an artificial-intelligence service, currently Anthropic's Claude API, to sort uploaded documents into categories and match them to your document checklist, read the printed text on identification documents, and prepare first drafts of loan summaries and packages for our team.

• Our contract with the provider, as of the effective date of this Policy, states that the provider may not train its models on our content.
• Information is sent to the provider only to perform these tasks.
• Our team reviews automated results before we rely on them or share them with a lender.
• We do not use automated processing to make decisions about you that have legal or similarly significant effects. Lenders and capital providers make their own credit decisions.
• You may ask us not to use automated processing for your documents. We will then handle them manually, which may take longer.

4. How we share information

With parties you authorize. We share your information with prospective and actual lenders, capital providers, SBA lenders, hotel brands, sellers, and other parties to your transaction, but only for the transaction and as you authorize. With your authorization, we also share it with independent professionals such as CPAs, insurance agents, attorneys and appraisers. Once a lender or other party receives your information, its own privacy policy and legal obligations govern its use of that information. We do not control how those parties handle your information.

With our service providers, which process information on our behalf under contract and only to provide services to us:

• Cloudflare: website hosting, database, encrypted temporary file storage, bot protection (Turnstile) and staff access controls;
• Dropbox: secure document storage;
• Anthropic: AI document processing, as described in Section 3;
• Resend: delivery of emails such as sign-in codes and notices;
• HubSpot: contact and relationship management. We do not store client documents, Social Security numbers or identification numbers in HubSpot; and
• Google: optional sign-in.

With professional advisers to Star Advantage, such as our attorneys, accountants and insurers, under duties of confidentiality.

For legal, safety and security reasons: to comply with law, subpoenas, court orders or regulator requests; to protect the rights, property or safety of our clients, Star Advantage or others; and to investigate fraud or security incidents.

In a business transfer, such as a merger, acquisition, financing or sale of all or part of our business. Any successor must protect the information consistent with this Policy.

We do not sell personal information, and we do not share it for targeted or cross-context behavioral advertising. When we send your information to a lender or other party because you asked us to arrange financing or a service, that is a disclosure you directed. It is not a sale, even though lenders may compensate us when a financing closes.

5. Cookies and similar technologies

We use only cookies and similar technologies that are strictly necessary: a session cookie that keeps you signed in to the client portal, and security technologies (such as Cloudflare Turnstile) that help tell people from bots. We do not currently use analytics, advertising or social-media tracking cookies. If that changes, we will update this Policy first and, where required, ask for your consent. Because we do not track you across sites, we do not change our practices in response to "Do Not Track" signals. We will honor Global Privacy Control signals where the law requires.

6. How we protect information

• encryption of data in transit;
• encryption of uploaded documents while they are held in temporary storage, and storage of delivered documents with a provider that encrypts data at rest;
• deletion of documents from temporary storage after they are delivered to our document storage;
• never sending client documents as email attachments;
• sign-in with one-time email codes or links, an optional password, or Google sign-in, and a second one-time code to confirm electronic signatures;
• limiting staff access to those who need it, with protected, multi-factor staff sign-in; and
• logging access to records and documents.

No system is perfectly secure, and we cannot guarantee that information will never be accessed without authorization. Please keep your email account secure, because it is used to sign in. Tell us right away if you suspect unauthorized access.

If we learn of a security breach that affects your personal information, we will notify you, and regulators where required, as required by applicable law. Under Texas law this is no later than 60 days after we determine that a breach occurred.

7. How long we keep information

We keep information only as long as needed for the purposes in this Policy, and then delete it or make it unreadable. Typical periods:

• Inquiries that do not become engagements: up to [3] years after our last contact.
• Client transaction files and documents: [7] years after the matter closes or our last activity on it, to meet business, tax and legal-record needs and to respond to lender, SBA or legal requests.
• Files in temporary encrypted storage: deleted once delivery to our document storage is confirmed.
• Signed documents and signature certificates: for the life of the agreement plus [7] years.
• Lender and capital-provider information: while the relationship is active plus [3] years.
• Email marketing preferences: we keep a record of opt-outs so we can honor them.
• Security and audit logs: kept without a fixed deletion date, because they are the record of who accessed client files and signed documents. They contain account identifiers, email addresses, IP addresses, dates, times and actions taken. They do not contain the contents of your documents.

We may keep information longer if the law requires it, or if it is needed for a legal claim, investigation or legal hold.

8. Your choices and rights

• Access and correction. You can review and update much of your information in the portal, or ask us to do so.
• Deletion. You can ask us to delete your personal information. We will do so unless we need to keep it for the reasons in Section 7. When we cannot delete something, we will tell you why. Information already delivered to a lender is held by that lender under its own policies.
• Automated processing. You can ask us not to use AI processing for your documents (see Section 3).
• Marketing email. Use the "unsubscribe" link in any marketing email, or contact us. We will still send messages about your account, security and open transactions.
• State privacy rights. Depending on where you live and how you deal with us, you may have legal rights to confirm whether we process your personal data, to access, correct, delete or obtain a copy of it, to opt out of sale, targeted advertising or certain profiling, and to not be discriminated against for using these rights. We do not sell personal data or use it for targeted advertising or profiling. We will consider requests from anyone and will honor them as required by applicable law.
• How to make a request. Email loans@staradvantagefunding.com with the subject "Privacy Request," use our contact page, or write to us at the address below. We will verify your identity, usually by confirming control of the email address we have for you. You may use an authorized agent where the law allows. We will respond within 45 days, and if we need more time (up to 45 more days) we will tell you why.
• Appeals. If we decline your request, you may appeal by replying to our decision or emailing loans@staradvantagefunding.com with the subject "Privacy Appeal." We will respond in writing within 60 days. If you are still not satisfied, you may contact your state attorney general.

9. Email and calls

We will use the email address and phone number you give us to respond to you and to communicate about your inquiry, account and transaction. We do not send marketing text messages.

10. Children

The Services are for adults acting for business purposes. They are not directed to children, and we do not knowingly collect information from anyone under 18. If you believe a minor has given us information, contact us and we will delete it.

11. Third-party sites and sign-in

Our Services may link to other websites, public data sources and sign-in providers, such as Google. Their own privacy policies govern what they collect. We are not responsible for their practices.

12. Where information is processed

We are based in the United States, and our service providers process information in the United States and, in some cases, other countries, under contractual protections. The Services are intended for use in the United States.

13. Accessibility

We want our website to be usable by everyone. If you have difficulty accessing any part of the site or this Policy, contact us and we will provide the information in another format.

14. Changes to this Policy

We may update this Policy. We will post the new version with a new effective date and, for material changes, notify account holders by email or in the portal. We will not use personal information we already hold in a materially different way without telling you and, where required, getting your consent.

15. Contact us

Star Advantage Funding LLC, Attention: Privacy
4951 Airport Parkway
Suite 570
Addison, TX 75001
Email: loans@staradvantagefunding.com
Phone: [PHONE]
Contact page