Privacy Policy

1. Introduction

Paolo The Source LLC ("Paolo The Source," "we," "us," or "our") operates a capital marketplace that connects operating businesses with third-party lenders. This Privacy Policy explains what information we collect, how we use it, how we protect it, and the choices you have. By using paolothesource.com and apply.paolothesource.com (the "Site") or submitting an application, you agree to the practices described here.

Paolo The Source is not a lender and does not originate loans. We facilitate introductions between applicants and lenders in our network. Lender relationships are governed by each lender's own agreements and privacy practices.

2. Information We Collect

a. Information you provide

• Identity: legal name, date of birth, Social Security Number, mother's maiden name, home address, and demographic information collected for federal fair-lending reporting.
• Contact: email address, phone number, business email, and business phone number.
• Business: legal entity name, EIN, structure, industry, address, formation date, employee count, monthly revenue, and monthly expenses.
• Financial: personal credit score, business credit score, personal income, collateral, existing bank relationship, funding amount requested, and intended use of funds.
• Documents: government-issued photo ID, EIN confirmation letter, and business formation documents uploaded through our application.
• Other forms on paolothesource.com: the strategy-call booking form, the free-course form and the affiliate referral form collect your first and last name, email address and phone number, so we can schedule the call, send the course access or follow up on the referral. The affiliate application collects the same, plus your business name and type, your website or LinkedIn, how many referrals you expect to send and how you heard about us, so we can review the application.

b. Information collected automatically

• Device and usage: IP address, browser type, operating system, pages visited, and time stamps, captured through standard server logs and analytics tools.
• Cookies and similar technologies: used to maintain session state, remember partially completed applications, and measure site performance. On paolothesource.com, an advertising cookie from Meta also measures our ads (see Section 6).

c. Mobile opt-in information

When you provide a phone number and opt in to receive text messages from Paolo The Source LLC, we collect and retain the phone number, opt-in timestamp, opt-in method, and the specific program you opted into. We text only the people who have opted in: ticking the consent box on one of our forms is what authorizes text messages, and the box is never ticked for you.

3. How We Use Your Information

• To evaluate your application and match it to lenders in our network.
• To communicate with you about your application, including status updates, funding offers, document requests, and scheduling.
• To verify your identity, prevent fraud, and comply with anti-money-laundering regulations.
• To meet federal fair-lending reporting obligations under the Equal Credit Opportunity Act.
• To schedule and confirm strategy calls, deliver the course and academy access you signed up for, and act on referrals and affiliate applications submitted on paolothesource.com.
• To operate, maintain, and improve the Site.
• To comply with legal obligations, respond to lawful requests, and enforce our agreements.

4. How We Share Your Information

We disclose information only in the ways described in this section.

• Lenders in our network: to evaluate your application and extend offers to you. Lenders only receive the information required to underwrite your request.
• Service providers: vendors that help us operate the Site and business, including hosting, storage, identity verification, customer support, analytics, and messaging infrastructure. These providers act on our behalf under written agreements that restrict their use of your information.
• Meta (advertising): the Meta Pixel on paolothesource.com sends Meta the visit details described in Section 6, so we can measure and show our ads.
• Legal and safety: when required by law, subpoena, or other legal process, or to protect our rights, your rights, or the rights of third parties.
• Business transfers: in connection with a merger, acquisition, financing, or sale of assets, subject to standard confidentiality protections.

Mobile information disclosure. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties, excluding aggregators and providers of the Text Message services.

5. Mobile Information and SMS Program

The phone number you give us may be used to send you text messages about your application, and we send them only if you opted in by ticking the consent box on one of our forms. Consent to receive text messages is not a condition of applying, of funding, or of any service we provide. Reply STOP to any message to opt out at any time, and reply HELP for help.

No mobile information will be sold or shared with third parties or affiliates for marketing or promotional purposes. Information sharing to subcontractors in support services, such as customer service, is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

We use GoHighLevel, our customer relationship and messaging platform, to send and receive these messages on our behalf, together with the aggregators and carriers it uses to deliver them. That is the support-services sharing the paragraph above permits, and it is the only sharing of your mobile opt-in data we do.

See our Terms of Use for the full messaging program terms, including who sends the messages, message frequency, opt-out instructions (text STOP), help (text HELP), carrier disclaimers, and applicable message and data rates.

6. Advertising Cookies and the Meta Pixel

Our marketing site, paolothesource.com, uses the Meta Pixel, a small piece of code from Meta Platforms, Inc., the company behind Facebook and Instagram. It does not run on this application site or in our affiliate portal.

What it collects

When you visit a page, the pixel sends Meta the page address, the time of your visit, your browser and device details, your IP address, and cookie identifiers, including Meta's own cookies if you are logged in to Facebook or Instagram in the same browser. When you book a strategy call, it also records that a booking happened.

Why we use it

To measure whether our Facebook and Instagram ads lead to visits and booked calls, and to show relevant ads to people who have visited our site, including not showing a booking ad to someone who already booked.

What we don't send

We don't send your contact details to Meta from the pages you see after booking a call. If a page address arrives carrying your name, email or phone number, we remove it before the pixel runs.

How to opt out

• Block or clear cookies in your browser settings, or use a browser or extension that blocks trackers. The site works without them.
• Turn the pixel off on our site in one click on Your Privacy Choices. If your browser sends a Global Privacy Control signal, we treat it the same way and the pixel never loads.
• Turn off personalized ads in your phone's privacy settings.
• Change how Meta uses activity from other sites in your Meta ad preferences.
• Opt out of interest-based ads from participating companies at optout.aboutads.info.

7. Your Privacy Rights

Depending on where you live, you may have the right to request access to, correction of, or deletion of your personal information, and to opt out of certain uses. To exercise these rights, email privacy@paolothesource.com. To stop text messages, reply STOP to any message you receive from us; that works whether or not you make any other request.

California residents have specific rights under the California Consumer Privacy Act as amended by the California Privacy Rights Act. See our Your Privacy Choices page, where you can also opt out of sharing through advertising cookies.

8. Data Security

We use reasonable administrative, technical, and physical safeguards to protect your information, including encryption in transit and at rest, access controls, and audited infrastructure. No method of transmission or storage is perfectly secure, and we cannot guarantee absolute security.

9. Data Retention

We retain personal information for as long as necessary to provide the services, meet legal and regulatory obligations, resolve disputes, and enforce our agreements. When no longer needed, information is deleted or anonymized.

10. Children's Privacy

The Site and our services are not directed to individuals under 18. We do not knowingly collect information from anyone under 18. If you believe a minor has provided information to us, email privacy@paolothesource.com and we will delete it.

11. Changes to This Policy

We may update this Privacy Policy from time to time. The "Last updated" date at the top indicates when it was most recently revised. Material changes will be notified through the Site.

12. Contact Us

Questions about this policy or your information:

• Email: privacy@paolothesource.com
• Web: paolothesource.com