Privacy Policy

Frontier Capital Partners LLC
Effective Date: October 1, 2026
Version 2.0

1. Introduction

1.1 Who we are

Frontier Capital Partners LLC ("Frontier Capital," "we," "us," or "our") provides revenue-based funding to small and mid-sized businesses. We work with businesses, their owners, and their authorized representatives. We do not offer consumer products or services to individuals for personal, family, or household purposes.

Principal office:
Frontier Capital Partners LLC
2665 S Bayshore Drive, Suite 445
Miami, FL 33133

Email: info@frontiercapitalpartners.us

1.2 What this policy covers

This Privacy Policy explains how we collect, use, share, and protect personal information when you:

• Visit our website at www.frontiercapital.us (the "Site")
• Submit an application for business funding, including through www.frontiercapital.us/v4/apply
• Use our client portal at app.frontiercapital.us (the "Client Portal") or our internal platform as an authorized user
• Connect a business bank account through our bank-connectivity provider, Plaid
• Receive text messages (SMS) or email from us, or contact us by email or text
• Have a funding agreement with us that we service

1.3 Your agreement

By using the Site, submitting an application, or using our platforms, you acknowledge that you have read this Privacy Policy. If you do not agree with it, please do not use the Site or our services.

2. Information We Collect

2.1 Information you provide

Business and owner information

• Business owner name, title, email address, mobile and business phone numbers
• Business legal name, trade name (DBA), federal tax ID (EIN), business address, industry, time in business, and ownership structure
• Owner identity details needed for verification, such as date of birth, home address, and Social Security number (or a portion of it)

Application information

• Requested funding amount and intended use
• Revenue estimates and information about existing financial obligations
• Bank statements, tax returns, business licenses, voided checks, identification documents, and other documents you upload

Account information

• Email address used to sign in
• Password (stored only as a cryptographic hash) or one-time passcodes used for sign-in
• Profile preferences, including communication preferences and text message consent choices

Communications

• The content and metadata of emails and text messages you send us, and our replies
• Service requests submitted through the Client Portal

2.2 Information from bank connections (Plaid)

If you choose to connect a business bank account through Plaid, we receive:

• Account names, types, and masked account numbers (last four digits only)
• Institution name
• Current and available balances
• Transaction history, including dates, amounts, descriptions, and counterparties

We do not receive or store your bank login credentials; those are handled by Plaid. Plaid access tokens are encrypted before storage. You can disconnect a bank account at any time (see Section 7).

2.3 Information from other sources

• Credit reporting agencies. With your authorization, we obtain credit information about business owners and guarantors. At application, this is a soft inquiry that does not affect credit scores.
• Business verification providers. We obtain public-record business information (for example, registration status, formation date, and registered address) to verify the business.
• Government watch lists. We screen businesses and owners against sanctions lists, such as the U.S. Treasury OFAC list.
• Referral partners. If an independent broker or referral partner introduced your business to us, we receive the information you provided to them.

2.4 Information collected automatically

• Security and sign-in data: IP address, browser and device type, sign-in timestamps, multi-factor authentication events, and audit logs of account activity
• Site usage data: pages viewed, links clicked, referring page, and approximate location (city or region) derived from IP address, collected through our website analytics provider (see Section 9)
• Error and performance data: technical diagnostics used to keep our services working

3. How We Use Your Information

We use personal information to:

• Review applications: verify identity and business information, evaluate an application, prevent fraud, and comply with sanctions screening requirements
• Service funding agreements: process scheduled payments, reconcile account activity, monitor connected bank account balances to support payment scheduling, and communicate with you about your account
• Operate our platforms: authenticate users, maintain account security, and provide the Client Portal
• Communicate with you: send service and security messages by email and, if you opted in, by text message (see Section 5)
• Comply with the law: maintain required records, respond to lawful requests, and meet tax, audit, and regulatory obligations
• Improve our services: analyze how the Site and our platforms are used and fix problems

3.1 Automated tools and human review

We use automated tools, including AI-assisted document analysis and rules-based transaction categorization, to extract information from documents and organize bank data. These tools support our team; they do not replace it. A member of our team reviews the results and makes final funding decisions. You may request human review of any automated assessment by emailing info@frontiercapitalpartners.us.

3.2 No marketing by text message

We do not send marketing or promotional text messages. Our email and text communications relate to your application, your account, or account security.

4. How We Share Your Information

We do not sell personal information. We share information only as described below.

4.1 Service providers

We share information with service providers that perform services for us. They are contractually required to protect it, use it only to provide services to us, and not use it for their own marketing.

We may also use credit reporting agencies, electronic signature providers, banks and payment processors, and professional advisors (such as accountants, auditors, and attorneys) as needed to provide our services.

4.2 Referral partners

If a broker or referral partner introduced your business to us, we may share the status of your application and of your funding agreement with that partner, and information needed to calculate their compensation. We do not share your bank account details, transaction data, credit information, or mobile phone number with referral partners, and we do not share text messaging opt-in data or consent with any third parties (see Section 5).

4.3 Funding participants

Parties that participate in funding our business may receive portfolio-level reports. These reports do not include business names, owner names, contact information, or bank account details.

4.4 Legal and safety

We may disclose information when required by law or legal process (such as a subpoena or court order), to respond to a regulator, to protect our rights or the rights of others, or to prevent fraud.

4.5 Business transfers

If we are involved in a merger, acquisition, financing, or sale of assets, information may be transferred as part of that transaction, subject to this Privacy Policy.

4.6 De-identified data

We may use and share aggregated or de-identified information that cannot reasonably identify you.

5. Text Messaging (SMS)

5.1 When we send text messages

We send text messages only in two situations:

1. Sign-in verification codes. Users of our online platforms who choose text message delivery receive a one-time passcode each time they request one to sign in. We do not send other messages to that number as part of this service.
2. Account servicing messages. Business customers who have a completed funding agreement with us, and who opted in to text messages, may receive account-servicing messages under our "Frontier Capital Account Servicing" program. These include payment reminders, returned-payment notices, requests for documents or for a bank connection update needed to service the account, and replies to questions you send us.

You can opt in to account servicing messages by checking the optional, unchecked text message box on our online application, or by texting our servicing number. Checking the box is not required. Messages begin only if your business has a completed funding agreement with us. We never send text messages to applicants who have not been funded, and we never send marketing or promotional text messages.

Message frequency varies (typically up to 8 messages per month for account servicing). Message and data rates may apply. Reply STOP to any message to opt out. Reply HELP for help, or email info@frontiercapitalpartners.us. Full program terms are in our SMS Messaging Terms at www.frontiercapital.us/sms-terms.

5.2 How we handle mobile information

Mobile information will not be shared with third parties or affiliates for marketing or promotional purposes. Text messaging originator opt-in data and consent will not be shared with any third parties.

The only parties that receive your mobile phone number and message content in connection with text messaging are the service providers that deliver messages for us (such as Twilio) and our hosting providers, under confidentiality obligations and only to provide the messaging service. This exclusion of text messaging opt-in data and consent applies to all other sharing described in this Privacy Policy.

5.3 Records we keep

We keep a record of each text message consent and opt-out (date, time, phone number, and how it was given) and of the messages exchanged, so that we can honor your choices and show that we did. When you reply STOP, we record the opt-out and stop sending account servicing messages to that number.

6. How We Protect Your Information

We use administrative, technical, and physical safeguards designed to protect personal information, including:

• Encryption in transit (TLS 1.2 or higher) and at rest (AES-256)
• Additional encryption of bank connection tokens
• Multi-factor authentication for staff accounts
• Role-based access controls, database-level access policies, and least-privilege access
• Audit logging of sign-in and administrative activity
• Hosting with U.S.-based providers that maintain recognized security certifications, such as SOC 2

No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

6.1 Data breach notification

If a security incident affects your personal information, we will notify you and the appropriate authorities as required by law, including the Florida Information Protection Act (notice to affected Florida residents within 30 days of determining a breach occurred, and notice to the Florida Department of Legal Affairs where 500 or more Florida residents are affected).

6.2 Retention

We keep information as long as needed for the purposes described in this policy and as required by law:

7. Your Choices and Rights

You may contact us at info@frontiercapitalpartners.us to:

• Access a copy of the personal information we hold about you (subject line: "Data Access Request")
• Correct inaccurate or incomplete information (subject line: "Correction Request")
• Delete your personal information, except where we must keep it by law, to service an active agreement, or to prevent fraud (subject line: "Deletion Request")
• Receive a copy of your data in a machine-readable format (subject line: "Data Export Request")
• Request human review of an automated assessment

We respond to verified requests within 30 days, or within the time required by applicable law.

Text messages: reply STOP to opt out of account servicing messages at any time. Reply START to opt back in.

Bank connections: you may disconnect a connected bank account at any time in the Client Portal or by emailing us. Disconnecting stops future data retrieval; data already received is kept as described in Section 6.2. You can also manage connections through Plaid at https://my.plaid.com.

Email: our emails relate to your application, account, or account security. You may opt out of non-essential notifications using the link in the email or by contacting us.

8. Third-Party Services and Links

The Site and our platforms may link to third-party websites and services. We are not responsible for their privacy practices. When you connect a bank account, Plaid's End User Privacy Policy also applies: https://plaid.com/legal/#end-user-privacy-policy.

9. Cookies and Analytics

We use:

• Essential cookies to keep you signed in and to protect against security threats. These are HTTP-only, secure, and limited to our own domains.
• Analytics on the Site, provided by PostHog, to understand how visitors use the Site (for example, which pages are viewed). This uses cookies or similar browser storage.

We do not use advertising cookies, and we do not allow third parties to track you across other websites for advertising. You can block or delete cookies through your browser settings; essential cookies are needed to sign in. We do not currently respond to browser "Do Not Track" signals.

10. California Privacy Rights

If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, "CCPA"), may give you the right to:

• Know the categories and specific pieces of personal information we collect, the sources, the business purposes, and the categories of third parties we disclose it to
• Delete personal information, subject to legal exceptions
• Correct inaccurate personal information
• Limit the use of sensitive personal information (we use it only for the purposes described in this policy)
• Opt out of the sale or sharing of personal information. We do not sell personal information and do not share it for cross-context behavioral advertising.
• Not be discriminated against for exercising these rights

To make a request, email info@frontiercapitalpartners.us with the subject line "California Privacy Request." We will verify your identity using information we have on file and respond within 45 days (extendable to 90 days where permitted). You may use an authorized agent to make a request on your behalf.

Categories of personal information collected in the past 12 months:

California "Shine the Light." We do not share personal information with third parties for their direct marketing purposes.

11. Nevada Privacy Rights

We do not sell personal information as defined by Nevada law. Nevada residents may email info@frontiercapitalpartners.us with questions.

12. Children's Privacy

Our services are intended for adults who own or represent a business. We do not knowingly collect personal information from anyone under 18. If we learn we have, we will delete it.

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will post the updated version on this page with a new "Last Updated" date. For material changes, we will also notify affected customers by email. We will not change our text messaging commitments in Section 5.2 to permit sharing of mobile information or opt-in data without obtaining new consent.

Version history: 1.0 (June 14, 2025); 2.0 (October 1, 2026): added Text Messaging (SMS) section, Twilio, website analytics, bank connectivity for business customers, and updated service providers.

14. Contact Us

Questions about this Privacy Policy or our data practices:

Email: info@frontiercapitalpartners.us (subject line: "Privacy Inquiry")

Mail:
Frontier Capital Partners LLC
Attn: Privacy
2665 S Bayshore Drive, Suite 445
Miami, FL 33133

Our Chief Operating Officer oversees privacy compliance.

This Privacy Policy is governed by the laws of the State of Florida.