Privacy Policy

Information We Collect
We collect the following categories of information from you, which may include the following:
Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number/tax ID number, driver’s license number, passport number or other similar identifiers. We use this information to identify you, process your application and access your personal credit bureau report, if you are a guarantor or business owner. Personal Information such as your name, signature, social security number, address, telephone number, passport number, driver’s license or state identification card number, employment history, bank account number or other financial information. We use this information to identify you, process your application and access your personal credit bureau report, if you are a guarantor or business owner. Protected classification characteristics under California or Federal Law such as age (date of birth). We use this information to confirm your identity and that you are old enough to enter a loan contract. Commercial information, including records of personal property and personal credit information. We may consider this information when processing your application. Internet or other electronic network activity information, including, but not limited to, browsing history (Working Capital Marketplace pages visited), device ID, device type and information regarding a consumer’s interaction with Arkadian Capital Internet Web site, application, or advertisement. We use this information to analyze the use of our website and for fraud screening.
Geolocation Data
We collect this information for fraud prevention purposes.
Audio, or similar information
Interactions with Working Capital Marketplace sales staff, underwriters and customer service agents are recorded for monitoring and training purposes.
Professional or employment-related information
We may use this when underwriting our loans.
Inferences drawn from any of the information categorized above
This information may be used for credit and fraud analysis and to target future offers.
Personal information does not include:
Publicly available information from government records.
De-identified or aggregated information.
Information excluded from the CCPA’s scope, such as:
Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA).
Personal information is covered by certain privacy laws, such as the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), the California Financial Information Privacy Act (FIPA) and the Driver’s Privacy Protection Act of 1994.
We obtain the categories of personal information listed above from the following categories of sources:
Directly from our applicants, clients, or their agents. For example, information provided as part of the loan application or related processes.
Indirectly from our clients or their agents. For example, through information we collect from our clients while providing services to them.
Directly and indirectly from activity on our website (Working Capital Marketplace.com). For example, from submissions through our website portal or website usage details collected automatically.
From third parties that interact with us in connection with the services we perform. For example, from referral partners and brokers who provide us with loan applications or credit reporting agencies that provide us with information regarding a guarantor’s or business owner’s credit history.

Use of Information:
We use the information we collect to:
Compile, save, use, and analyze your Personal Information in both a personally identifiable form and as part of aggregated data.
Operate, maintain, improve, and provide you with services.
Conduct our business, including our own lending, and refer your business to third party small business lenders.
Verify your identity and conduct appropriate diligence.
Review for potentially fraudulent activity.
Register you as a user and identify you when you sign into your account.
Process your business’ application and determine whether your business qualifies for one of our loan products.
Process your business loan product account, including deducting automatic payments from your business bank account.
Communicate with you to send order confirmations, respond to customer service requests, send marketing communications, and send account update notifications related to your business.
Post and review your comments on our blog.
Conduct research and analysis to better understand our customers.
Produce data analytics and reports containing de-identified summaries of Personal Information and other information that is not Personal Information (such information, “General Information”) that we share with business partners. General Information may include Personal Information that has been aggregated and will not identify you.
Sharing Personal Information
Arkadian Capital may share your information with its affiliated entities for business purposes, such as financial reporting. Should you apply to Arkadian Capital or its affiliated entities for a financial product or service, Arkadian Capital may share your application status, borrowing history, and loan performance. Arkadian Capital will share your Personal Information with third parties only in the ways that are described in this Privacy Policy and as required by law. We do not sell your Personal Information to third parties. We will provide your Personal Information, which may include application information, to our trusted business partners, third party lenders of Arkadian Capital products, service providers, and subsidiaries and affiliates to provide financing and/or to provide services to help us with our business activities, such as offering customer service, processing credit checks or secure data storage, and other similar services. These companies are authorized to use your Personal Information only as necessary to provide these types of services to us. In addition, we may share your basic information (name, company name, phone number, email address and requested loan amount) with one of our business partners to market their services to you, provided, however, if you do not want us to share your Personal Information in these circumstances with these business partners you can opt out at the email or mailing address provided in Arkadian Capital’s Privacy Policy Part 1, which precedes this policy. In addition, we may also share General Information for the same reasons as we provide Personal Information and for business partners and others to conduct analyses and research and track marketing performance or as otherwise provided in the Tracking Technologies part herein. Some of our pages utilize framing or white-labeling techniques to serve content from our partners while preserving the look and feel of our Website. For example, our Careers page utilizes white-labeling techniques. Please be aware that in these instances you are providing your Personal Information to these third parties and not to Arkadian Capital. We may also disclose your Personal Information:
As required by law, such as to comply with a subpoena, or similar legal process, including in a bankruptcy proceeding.
When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a request from a governmental entity.
If Arkadian Capital is involved in a merger, acquisition, or sale of all or substantially all of its assets or equity, in which case, you will be notified via email and/or a prominent notice on our Website of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information; and
To any other third party with your prior consent to do so.
In the preceding 12 months, we may have disclosed personal information for a business purpose from each of the categories listed previously where we collect information.

Sale of Personal Information

We do not sell personal information.

Your Rights and Choices

The CCPA provides consumers, including owners/guarantors of small business loans (California residents), with specific rights regarding their personal information. Arkadian Capital is providing these rights to California consumer residents who have provided their personal information as part of a Working Capital Marketplace application or loan. This section describes the CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights:

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (“Request”), we will disclose to you:

The categories of information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
If we disclosed your personal information for a business purpose, a list identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights:

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

Exceptions

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code Section 1546 seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to other applicable ethics and privacy laws, when the deletion of the information may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with expectations based on your relationship with us.
Comply with a legal obligation, such as retaining personal information collected to verify/identify under federal anti-money laundering laws (“AML”).
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access. Data Portability and Deletion Rights
To exercise the access, data portability and deletion rights described above, please submit a verifiable request to us by one of these methods:
Call:
+1 (855)-786-1190 or
E-mail:
admin@arkadiancapital.com
Only you or a person registered with the California Secretary of State or other state agency that you authorize to act on your behalf, may make a Request related to your personal information.
You may only make a Request for access or data portability twice within a 12-month period. The Request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.
We can’t respond to your request or provide you with personal information if we are unable to verify your identity or authority to make the request and confirm the personal information relates to you. Making a Request does not require you to create an account with us. We will only use personal information provided in a Request to verify your identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a Request in writing within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will cover the 12-month period preceding the receipt of the Request. The response we provide will also explain the reasons we can’t comply with a request, if applicable. For data portability requests, we will select a format to provide the information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or response to your Request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why and provide you with a cost estimate before completing your request.
Non-Discrimination
We will not discriminate against you for exercising any of these rights. Unless permitted by the CCPA, we will not, because you have exercised rights under the CCPA:
Deny you goods or services.
Charge you different prices for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Changes to Our CCPA Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.