Privacy Policy

Effective Date: December 9th, 2025

Last Updated: December 9th, 2025

This Privacy Policy ("Policy") explains how Milford Corporation, doing business as Seaport Funding Group ("Company," "we," "us," or "our") collects, uses, discloses, and protects personal information in the course of offering financial products and brokerage services to individuals and businesses across the United States. This Policy applies to all users of our website, services, applications, and any other interactions with us (collectively, the "Services").

We operate nationally but are based in California. As such, we comply with all applicable U.S. privacy laws, including the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), and provide additional disclosures and rights for residents of states with enhanced consumer privacy protections.

1. Information We Collect

We may collect the following categories of information:

A. Personal Identifiers

Name, address, email address, phone number, IP address, account credentials, and other identifying information.

B. Business Information

Company name, Employer Identification Number (“EIN”), business address, ownership information, and financial or operational data relevant to underwriting.

C. Financial Information

Bank statements, transaction histories, revenue records, credit profiles, and similar data necessary for evaluating financing eligibility.

D. Commercial Information

Records of products or services considered or obtained, transaction details, and communication history.

E. Internet or Network Activity

Browsing and log data, device identifiers, cookies, analytics information, and interaction logs.

F. Geolocation Data

Approximate location inferred from IP address.

G. Professional or Employment Information

Occupation, business role, and related information.

H. Sensitive Personal Information (as defined by CPRA)

Includes account log-ins, government ID numbers, or financial account data when necessary. We do not collect or process highly sensitive categories (e.g., precise geolocation, racial/ethnic data, biometric identifiers) unless required for legal compliance or fraud prevention.

We collect information directly from you, automatically through our Services, and from third parties such as financial institutions, data providers, brokers, partners, and service vendors.

2. Purposes for Collecting and Using Information

We may use personal information for the following purposes:

• To provide, operate, and improve our financing and brokerage Services.

• To process applications, perform underwriting, and verify identity or financial status.

• To communicate regarding offers, applications, approvals, renewals, and support.

• For marketing and advertising, including remarketing where permitted by law.

• To detect, investigate, and prevent fraud, security incidents, or illegal activities.

• To comply with contracts, applicable laws, and regulatory obligations.

• To maintain business records and internal reporting.

• For any other purpose disclosed at the time of collection or with your consent.

We do not use or disclose Sensitive Personal Information for purposes other than those authorized by CPRA §7027(m).

3. Credit Reports and Underwriting Activities

We do not independently obtain or process consumer credit reports. However, our lending and financing partners may obtain consumer or commercial credit reports, credit scores, or other information governed by the federal Fair Credit Reporting Act (FCRA) or similar laws as part of their underwriting and decision-making processes. These partners are solely responsible for complying with FCRA and providing any required notices, including adverse action notices.

We may transmit application information to such partners for the purpose of facilitating financing options, but we do not control or direct their credit-reporting practices.

4. Disclosure of Personal Information

Disclosures of personal information to lenders or financing partners for underwriting, verification, or funding-related purposes are made solely to provide the Services requested by the user. These disclosures are considered business-purpose disclosures, and are not treated as a “sale” or “sharing” of personal information under applicable privacy laws, including the CCPA/CPRA and similar state statutes. Any compensation we receive relates to the performance of brokerage services and not to the transfer or monetization of personal information.

We may disclose information to the following categories of recipients:

• Lenders, financing partners, and funding providers in connection with evaluating and presenting financing options.

• Service providers and contractors performing business functions such as verification, analytics, hosting, customer support, or marketing.

• Affiliates, successors, or assigns for business operations or corporate transactions.

• Financial institutions for verification, payment processing, and underwriting.

• Regulatory or law enforcement agencies as required by law.

• Other third parties with your authorization or as reasonably necessary to provide the Services.

We do not sell personal information in the traditional sense. However, for states that define “sharing” to include cross-context behavioral advertising (including CA under CPRA), we may share limited data for permitted advertising purposes. You may opt out of such sharing as described below.

5. Retention of Personal Information

We retain personal information only as long as reasonably necessary for:

• providing our Services;

• complying with legal obligations;

• preventing fraud and maintaining security;

• resolving disputes; and

• internal business needs and recordkeeping.

Retention periods may vary depending on the category of information and applicable state or federal requirements (including financial record retention laws).

6. Your Privacy Rights

Depending on your state of residence, you may have one or more of the following rights:

A. Right to Know / Access

Right to request disclosure of the categories or specific pieces of personal information we have collected, used, or disclosed.

B. Right to Delete

Right to request deletion of personal information, subject to legal exceptions.

C. Right to Correct

Right to request correction of inaccurate personal information.

D. Right to Opt Out of:

• Sale of personal information

• Sharing of data for targeted advertising / cross-context behavioral advertising

• Profiling in furtherance of decisions that have legal or similarly significant effects (where applicable)

E. Right to Data Portability

You may request a copy of certain personal information in a portable and, to the extent technically feasible, readily usable format so that you can transmit the data to another entity.

F. Right to Limit Use of Sensitive Personal Information (CA and certain other states)

In California and other states with similar laws, you may request that we limit the use and disclosure of your Sensitive Personal Information to what is necessary to perform the services or provide goods that an average consumer would reasonably expect, or as otherwise permitted by law.

G. Right to Non-Discrimination

We will not deny services, charge different prices, or provide a different level or quality of service because you exercise your privacy rights.

H. Right to Appeal

If we deny a request, you may submit an appeal within the timeframe provided in our response, where this right is available under applicable law.

7. State-Specific Disclosures

We provide enhanced rights and disclosures to residents of U.S. states that have enacted comprehensive consumer data privacy laws. As of the Effective Date, those states include:

• California (California Consumer Privacy Act / California Privacy Rights Act)

• Virginia (Virginia Consumer Data Protection Act)

• Colorado (Colorado Privacy Act)

• Connecticut (Connecticut Data Privacy Act)

• Utah (Utah Consumer Privacy Act)

• Iowa (Iowa Consumer Data Protection Act)

• Indiana (Indiana Consumer Data Protection Law)

• Tennessee (Tennessee Information Protection Act)

• Texas (Texas Data Privacy and Security Act)

• Florida (Florida Digital Bill of Rights, as applicable)

• Montana (Montana Consumer Data Privacy Act)

• Oregon (Oregon Consumer Privacy Act)

• Delaware (Delaware Personal Data Privacy Act)

• New Hampshire (New Hampshire consumer data privacy law)

• New Jersey (New Jersey Data Privacy Act)

• Kentucky (Kentucky Consumer Data Privacy statute)

• Nebraska (Nebraska Data Privacy Act)

• Rhode Island (Rhode Island Data Privacy and Protection Act)

• Maryland (Maryland Online Data Privacy Act)

• Minnesota (Minnesota Consumer Data Privacy Act)

Where these laws apply to us, residents of these states may exercise the rights described in Section 5 (subject to any state-specific limitations or conditions). In some cases, we choose to honor these rights more broadly as a matter of policy, even when not strictly required.

A more detailed state-by-state summary of rights and our practices is available upon request.

8. How to Exercise Your Rights

You may submit a request by using any of the following:

• Email: privacy@seaportfunding.com

• Mailing Address: 501 W Broadway, Suite 800, San Diego, CA 92101

• Website Form: https://www.seaportfunding.com/

To protect your information, we may need to verify your identity before processing a request, which may include matching data you provide with information already maintained.

Authorized agents may submit requests on behalf of a consumer in accordance with applicable state laws.

9. Cookies, Targeted Advertising, and Opt-Out Signals

We use cookies, pixels, and similar technologies to:

• improve website performance;

• understand user behavior;

• deliver relevant advertising;

• maintain security and functionality.

Users may opt out of certain tracking through browser settings, industry opt-out tools, or by using any opt-out mechanisms we provide on our Services. Where required by law (for example, in California, Colorado, Connecticut, Montana, Oregon, Texas, and certain other states), we will also recognize and honor valid browser or device-based opt-out preference signals for sales, sharing, or targeted advertising, to the extent technically feasible. Some features of the Services may not function without certain cookies.

10. Children’s Privacy

Our Services are intended exclusively for individuals who are 18 years of age or older. We do not offer services to, conduct business with, or knowingly collect personal information from individuals under the age of 18. If we become aware that we have collected personal information from a minor, we will delete it as required by law.

11. Automated Decision-Making Disclosure

We do not make decisions that have legal or similarly significant effects on consumers using solely automated decision-making technologies. All evaluations, underwriting determinations, funding recommendations, and related actions involve human review and approval. If our practices change in the future, we will update this Policy as required by applicable law.

12. Data Security

We maintain reasonable administrative, technical, and physical safeguards to protect personal information from unauthorized access, disclosure, or misuse. However, no system is fully secure, and we cannot guarantee absolute security.

13. Marketing Communications

You may opt out of marketing emails by clicking "unsubscribe" in any message or contacting us directly. We may still send transactional or legally required communications.

14. Third-Party Links

Our Services may contain links to third-party websites. We are not responsible for their privacy practices or content. We encourage you to review their policies before providing information.

15. Financial Privacy and Other Sectoral Laws

Our Services relate exclusively to commercial and business-purpose financing. We do not offer personal, family, or household lending products, and we do not provide any consumer financial services.

Because our activities are limited to business-purpose transactions:

• The Gramm–Leach–Bliley Act (GLBA) generally does not apply to the information we collect or process. GLBA governs the privacy of consumer financial information, and commercial financing activities fall outside its scope.

• If any financing partner obtains a personal credit report on a business owner or guarantor as part of a commercial underwriting process, that activity is conducted solely by the partner. The partner is responsible for compliance with the Fair Credit Reporting Act (FCRA), including providing any required disclosures or adverse-action notices.

• We do not independently obtain consumer reports and do not engage in any activity regulated as consumer lending.

This Policy governs our handling of personal information collected in the context of evaluating, facilitating, or brokering commercial financing. Nothing in this Policy affects any rights or obligations that may apply to third-party lenders under GLBA, FCRA, or other financial privacy laws.

16. Changes to This Policy

We may update this Policy at any time. The "Last Updated" date reflects the most recent revisions. Continued use of the Services constitutes acceptance of the updated Policy.

17. Contact Us

For questions about this Policy or to exercise your privacy rights:

Seaport Funding Group

501 W Broadway, Suite 800

San Diego, CA 92101

Email: privacy@seaportfunding.com