Privacy Policy
Aquify Group LLC
Effective Date: [DATE]
Last Updated: [DATE]
Summary
- We collect what is needed to evaluate a financing request and nothing else.
- We do not sell, rent, or trade your personal information. Not to lead buyers, not to affiliates, not to anyone.
- Your Social Security number goes to lenders to run your inquiry. It is encrypted, it is never sent in an email, and it is not kept longer than it needs to be.
- Marketing messages are opt-in and separate from service messages about your file.
- You can ask us what we hold, correct it, or delete it.
The rest of this document is the detail behind those five sentences.
1. Who this applies to
This policy covers https://meetaquify.com and the services provided by Aquify Group LLC ("Aquify," "we," "us"). It does not cover the practices of the lenders we introduce you to. Once your information is transmitted to a lender, that lender's own privacy notice governs what they do with it, and you will receive it from them directly.
2. Gramm-Leach-Bliley Act notice
Because we arrange loans, Aquify is a "financial institution" under the Gramm-Leach-Bliley Act, and this section serves as our GLBA privacy notice.
What we collect. Information you give us on applications and forms — name, address, date of birth, Social Security number, income, employment, property details, and business financials. Information about your transactions with us. Information from consumer reporting agencies obtained by our lending partners in connection with your application.
Why we share it. We share your information only for the everyday business purpose of processing the financing you asked us to arrange, and where required by law.
| Reason we can share | Do we share? | Can you limit it? |
|---|---|---|
| Everyday business purposes — processing your application, responding to court orders and legal investigations | Yes | No |
| Our marketing — offering our own products and services to you | Yes, if you opt in | Yes |
| Joint marketing with other financial companies | No | — |
| Affiliates' everyday business purposes | No — we have no affiliates | — |
| Non-affiliates to market to you | No | — |
How we protect it. We restrict access to those who need it to do their jobs, and we maintain physical, electronic, and procedural safeguards. Section 6 describes them specifically.
3. What we collect
You give us:
- Name, email address, phone number, mailing address
- Date of birth
- Social Security number — for the purpose described in Section 5
- Property address, occupancy, how title is held, estimated value, existing loan balance
- For rental property: market rent and monthly carrying costs
- For business financing: legal entity name, DBA, EIN, entity type, state of formation, industry, time in business, revenue, existing business debt
- Documents you upload, including business bank statements and identification
- Estimated credit score band, and what the financing is for
- Anything you write in a message field
We collect automatically:
- IP address, browser and device type, operating system
- Pages viewed, time on page, and how far you scroll
- Which step of an application you reached, and whether you completed it
- Referral source, including UTM parameters and partner referral codes (
?ref=) used to attribute an introduction to the partner who made it
We do not collect precise geolocation, biometric data, or information about your race, religion, health, sexual orientation, or political views. We do not knowingly collect anything from anyone under 18.
4. How we use it
- To evaluate a financing request and match it to lenders
- To communicate with you about your inquiry
- To send marketing communications only if you opted in
- To understand where our traffic comes from and where people abandon our forms, so we can improve them
- To attribute an introduction to a referral partner
- To detect fraud and secure the Site
- To meet legal, regulatory, and recordkeeping obligations
Automated decision-making. We do not make automated decisions about you that produce legal or similarly significant effects. Lenders may use automated underwriting; that is described in their disclosures.
5. Your Social Security number and other sensitive information
This section is deliberately specific, because vague language here is how sensitive data gets mishandled.
Why we need it. Lenders require full legal name, date of birth, and Social Security number to run the soft credit inquiry that produces your terms. We collect it, transmit it to the lender, and use it for nothing else.
How it is handled:
- Encrypted in transit over TLS
- Encrypted at rest, stored separately from the rest of your record, and accessible only to those who need it to submit your inquiry
- Never included in the body of an email. Our internal notification shows only the last four digits and links to a secured record. If we ever need something sensitive from you, we send a secure link rather than asking you to email it.
- Excluded from analytics, from event logging, and from any log line
- Not retained beyond the period needed to process your application and satisfy recordkeeping obligations — see Section 9
Documents. Bank statements, identification, and similar files go to private encrypted storage. They are never attached to email. Access links expire.
6. Security
We maintain a written information security program appropriate to our size and the sensitivity of what we hold, including:
- Encryption of sensitive data in transit and at rest
- Role-based access control and multi-factor authentication on administrative accounts
- Vendor due diligence on providers who touch personal information
- Logging and monitoring of access to sensitive records
- An incident response procedure, including notification to affected individuals and regulators where required by law
No system is perfectly secure. If we become aware of a breach affecting your personal information, we will notify you and applicable regulators as required by law and without unreasonable delay.
7. Who we share with
Lenders and lending partners — to obtain the financing you requested. This is the core purpose of the Service.
Service providers, limited to what they need to perform their function:
- Website hosting and database infrastructure
- Email and SMS delivery
- Encrypted document storage
- Product analytics
- Identity and income verification services used by lenders
Legal and safety — where required by subpoena, court order, or law, or to protect our rights, your safety, or the safety of others.
Business transfer — if Aquify is involved in a merger, acquisition, or sale of assets, your information may transfer, subject to this policy.
We do not sell your personal information. We do not share it with data brokers, lead aggregators, or other financing companies looking for customers. We are not a lead generator. If a partner referred you to us, we record that they did so; we do not send them your information in return.
8. Communications and your choices
Service messages relate to a transaction you started — status, document requests, appointment confirmations, and replies. You receive these because you asked us to work on something.
Marketing messages are separate and opt-in. They are governed by an unchecked, optional box, and declining does not affect your application or your terms in any way.
How to stop:
- Text — reply STOP to any message. Reply HELP for help.
- Email — use the unsubscribe link in any marketing email.
- Anything — write to john@aquifygroup.com.
Opting out of marketing does not stop service messages about an application in progress.
9. How long we keep it
| Category | Retention |
|---|---|
| Application records | Duration of the application plus |
| Social Security number | Only as long as needed to process the inquiry and satisfy recordkeeping obligations, then deleted |
| Uploaded documents | Same as application records, in encrypted storage |
| Communication records | Up to 3 years |
| TCPA consent records | At least 5 years — retained specifically to evidence consent, including the exact language shown and the timestamp |
| Analytics | Aggregated and de-identified data may be retained indefinitely |
You can request deletion at any time (Section 10). We honor requests except where a legal or regulatory obligation requires retention, in which case we will tell you which category applies.
10. Your rights
Regardless of where you live, you may:
- Access — request a copy of the personal information we hold about you
- Correct — have inaccurate information fixed
- Delete — request deletion, subject to legal retention obligations
- Withdraw consent — for marketing, or for electronic communications generally
- Opt out — of marketing at any time
To exercise any of these, email john@aquifygroup.com. We will verify your identity and respond within 30 days, or 45 days where a longer period is permitted.
State privacy rights
California (CCPA/CPRA). You have the right to know the categories and specific pieces of personal information collected, the purposes, and the categories of third parties it was disclosed to; to delete; to correct; to limit use of sensitive personal information; and to non-discrimination for exercising these rights. We do not sell or share personal information for cross-context behavioral advertising.
Other states. Residents of states with comprehensive privacy laws — including Connecticut, Delaware, Iowa, Maryland, Montana, Nebraska, New Hampshire, Tennessee, and Texas, all of which are in our operating footprint — have similar rights of access, correction, deletion, portability, and opt-out.
An important qualification. Most state comprehensive privacy laws contain exemptions for financial institutions subject to the Gramm-Leach-Bliley Act, or for information governed by GLBA. Depending on the state, that exemption may apply at the entity level or only to the specific data. We honor access, correction, and deletion requests from residents of all states regardless of whether an exemption technically applies, because it is the right posture even where it is not strictly required.
Appeals. If we decline a request, you may appeal by replying to our decision. We will respond within 45 days. If we deny the appeal, you may contact your state attorney general.
Authorized agents. You may use an authorized agent, with written permission and identity verification.
11. Cookies and tracking
We use cookies and similar technologies to keep the Site working, remember your preferences, understand which pages people use, and see where applications are abandoned. You can disable cookies in your browser, though parts of the Site may stop working.
We do not use third-party advertising cookies or cross-site tracking pixels for behavioral advertising.
We honor Global Privacy Control signals as an opt-out where applicable.
12. Children
The Site is not directed to anyone under 18, and you must be 18 to use the Services. We do not knowingly collect information from anyone under 18. If we learn we have, we delete it.
(The prior version said 13, which conflicted with the Terms' 18+ requirement. 18 is correct for a financial services site.)
13. External links
The Site links to third-party sites, including lenders and government resources. We do not control them and are not responsible for their content or privacy practices.
14. Changes
We may update this policy. Material changes will be posted with a revised Effective Date, and where required we will provide additional notice. Continued use after changes take effect constitutes acceptance.
15. Contact
Aquify Group LLC
39 Wooster Street, New York, NY 10013
(619) 277-5736
john@aquifygroup.com
For privacy requests, put "Privacy Request" in the subject line.