Privacy Policy

1. Who we are

Flagler Capital LLC (in formation) ("Flagler Capital," "we," "us," or "our") is a Miami, Florida company that makes commercial, business-purpose fleet loans to limited liability companies, primarily Turo hosts and car-sharing operators. This Privacy Policy applies to the website at https://flagler.capital and the information you submit through it.

2. Information we collect

Information you give us directly

When you complete the qualification form or otherwise contact us, we collect the information you choose to provide, which may include:

• Identity and contact details — your name, email address, and phone number.
• Business and fleet information — your current fleet size, months hosting on Turo, completed trips, host rating, your Turo profile or listing URL, gross monthly platform revenue, the vehicles you plan to finance, loan amount sought, and purchase-vs-refinance intent.
• Creditworthiness indicators — your self-reported personal FICO band and related details about the owners of the borrowing LLC.
• Uploaded financial documents — bank statements, Turo payout statements, and similar records you choose to upload to support your request.

Information collected automatically

Like most websites, we collect limited technical information automatically when you visit:

• Analytics and cookies — we use Google Analytics (GA4), which sets cookies and similar identifiers to measure how the site is used (pages viewed, time on page, referral source, approximate location).
• Device and connection data — IP address, browser type, device type, operating system, and the date and time of your visit.

We do not collect Social Security numbers, dates of birth, or full financial-account credentials through the public website form. Sensitive underwriting details, when required, are collected separately and securely later in the process.

3. Why we use your information and our legal basis

We use the information above solely to evaluate and service business-purpose loan requests. Specifically, we use it to:

• Assess whether your fleet and file meet our lending criteria.
• Verify your platform income and the financial information you submit.
• Communicate with you about your inquiry, your term sheet, and any resulting loan.
• Underwrite, document, fund, and service a loan if one is made.
• Operate, secure, and improve the website, and comply with applicable law.

Legal basis. Because these are commercial transactions between businesses, we process your information to take steps at your request prior to entering a loan, to perform a loan agreement, to pursue our legitimate business interests in evaluating and managing credit risk, and to meet our legal and regulatory obligations. We rely on your consent where it is required, such as for non-essential analytics cookies.

4. Credit inquiries — soft now, hard only on acceptance

Submitting the form places you in our funding queue; it is an inquiry, not a credit application. Our credit review proceeds in two distinct stages:

• Soft inquiry first. Early in review we may perform a soft credit pull, which does not affect your credit score.
• Hard inquiry only later, and only with your authorization. A hard credit pull — which can affect a credit score — is performed only after you accept a term sheet and provide express written authorization to proceed.

5. We do not sell, rent, or share your data for marketing

We do not sell or rent your personal information, and we do not share it with third parties for their own advertising or marketing. We have never engaged in, and do not engage in, the sale of personal information. Your data is used for underwriting and servicing your request — and for nothing else.

6. How we store and protect your information

We treat the financial documents and personal information you provide as confidential. Our safeguards include:

• Encryption. Information is encrypted in transit (TLS/HTTPS) and encrypted at rest in our systems.
• Access limits. Access is restricted to underwriting and servicing staff and to service providers who need it to do their work, each bound by confidentiality obligations.
• Retention and deletion. We keep your information only as long as needed to evaluate your request, service any resulting loan, and meet our legal, tax, and recordkeeping obligations. When it is no longer needed, we securely delete or de-identify it.

Our information-security program is designed to align with the principles of the FTC Safeguards Rule and the Gramm-Leach-Bliley Act (GLBA), and our handling of personal information of Florida residents is informed by the Florida Information Protection Act of 2014 (Fla. Stat. § 501.171), including its requirements to take reasonable measures to protect data and to provide notice in the event of a qualifying breach. No method of transmission or storage is perfectly secure, but we work to protect your information using reasonable, industry-standard measures.

7. Service providers and third parties

We share information only with parties that help us evaluate and service your request, and only as needed for that purpose. These may include:

• Credit bureaus and verification services — to obtain credit reports and verify the information you provide (soft, then hard only with your authorization as described above).
• Underwriting and servicing providers — vendors who support our credit review, document preparation, loan servicing, payment processing, and fraud prevention, each under confidentiality obligations.
• Analytics providers — Google, as the provider of Google Analytics (GA4), processes site-usage data on our behalf.

We may also disclose information when required by law, to respond to lawful requests from authorities, to enforce our agreements, or to protect our rights, property, and safety or those of others. If our business is involved in a merger, acquisition, or financing, information may be transferred as part of that transaction, subject to this policy.

8. Cookies, analytics, and your choices

We use Google Analytics (GA4) to understand how visitors use the site. You can control or limit this in several ways:

• Google Analytics opt-out. Install the Google Analytics Opt-out Browser Add-on to prevent GA from collecting your data across sites.
• Browser controls. Most browsers let you block or delete cookies and send a "Do Not Track" signal through their settings.

Blocking analytics cookies will not affect your ability to submit the form or be considered for financing. To learn how Google handles data, see Google's Privacy Policy.

9. Your privacy rights

Subject to applicable law, you may ask us to access, correct, or delete the personal information you have provided, or to tell you how it has been used. To make a request, contact us using the details below. We may need to verify your identity before acting, and we may retain information we are required to keep by law or that we need to service an active loan.

10. Children's privacy

This website and our financing products are directed to businesses and adults, not to children. We do not knowingly collect personal information from anyone under 18. If you believe a minor has provided us information, contact us and we will delete it.

11. Changes to this policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Last updated" date above and, where appropriate, provide additional notice. Your continued use of the website after an update means you accept the revised policy.

12. Contact us