Derby Copeland Management Group, LLC Privacy Policy
Effective January 1, 2026
DERBY COPELAND MANAGEMENT GROUP, LLC and its affiliates ("Company", "we", "our", or "us") respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes how we collect, process, retain, and disclose personal data about you in connection with the origination and servicing of any loans or other financing arrangements (our "Services") and our practices for using, maintaining, protecting, and disclosing that information.
This policy applies only to information we collect:
Through the Services.
In communications, including email, text, chat, and other electronic messages, between you and the Services.
Third party cloud-based data information.
It does not apply to information collected by:
Any third party including through any application or content (including advertising) that may link to or be accessible from or through the Services.
Any publicly available information.
Please read this policy carefully to understand our policies and practices regarding your information and how we treat it. By interacting with our Services or providing us with your information, you agree to the collection, use, and sharing of your information as described in this privacy policy.
Children's and Minors' Data
Our Services are not intended for, and we do not knowingly collect any personal data from, children under the age of 18. If we learn we have collected or received personal data from a child under 18 years old without verification of parental consent, we will delete that information.
The Personal Data That We Collect or Process
"Personal data" is information that identifies, relates to, or describes, directly or indirectly, you as an individual, such as your name, email address, telephone number, home address, or payment information (for example, account information such as name, postal address, and email address, bank accounts, social security number, or, lien, litigation, bankruptcy and credit reports we may use.
The types and categories of personal data we collect or process include:
Account and contact information, including name, address (such as home address, work address, or other address), email address, phone number, and other contact information you provide us.
Payment information and information about the payment methods (such as your bank account information) you use.
Demographic information, including your age, gender, income level, education, or family or marital status.
Information you elect to provide as part of the due diligence and loan servicing processes arising from the Services, including, but not limited to, information provided in emails, chats, or other communications sent to us.
Identity document information, such as Social Security and driver's license numbers.
Credit reports and other legal searches.
If you are a California resident, to access our supplemental California privacy statement, please contact us at compliance@derbycopeland.com in order for us to provide additional information and terms.
Some of the information identified above may be considered sensitive data under certain laws, which to the extent you provide us during the diligence process confirms your consent to sharing such information. If you choose not to provide or allow us to collect some information, we may not be able to provide you with the Series.
How We Collect Your Personal and Other Data
You Provide Information to Us
We collect information about you when you interact with our Services.
When you interact with the Services, there are third parties that may use automatic collection technologies to collect information about you or your device.
These third parties may use tracking technologies to collect information about you when you use the Services. The information they collect may be associated with your personal data or they may collect information, including personal data, about your online activities over time and across different websites, apps, platforms, and other online services.
We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
From Service Providers
We may receive personal data about you from other sources and combine that with information we collect directly from you. For example, we may obtain information about you from service providers that we engage to perform services on our behalf, such as appraisers, environmental consultants, attorneys, analytics, security and anti-fraud services. We also may receive personal data from business partners that we engage to share information with us.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal data, to:
Provide you with the Services.
Carry out our obligations and enforce our rights arising from any agreements entered into between you and us, including for billing and collection.
In order to obtain leverage for the loans originated.
In any other way we may describe when you provide the information.
Who We Disclose Your Information To
We may disclose aggregated information about borrowers, guarantors, sponsors and information that does not identify any individual, without restriction.
We may also disclose personal data that we collect or you provide as described in this privacy policy:
To our subsidiaries and affiliates.
To contractors, service providers, and other third parties we use to support our organization and who are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which we disclose it to them.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.
To fulfill the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information.
With your consent.
We may also disclose your personal data:
To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce or apply the applicable loan documentation and other agreements, including for billing and collection purposes.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our organization, our investors, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
The categories of personal data we may disclose include:
Account and contact information.
Payment information.
Account history.
Demographic information.
Any documents or information you elect to provide to us.
Identity document information.
Credit reports and other legal searches.
Your Rights and Choices About Your Information
This section describes mechanisms you can use to control certain uses and disclosures of your information and rights you may have under state law, depending on where you live.
Your State Privacy Rights
Depending on your state of residency, you may have certain rights related to your personal data, including:
Access and Data Portability. You may confirm whether we process your personal data and access a copy of the personal data we process. To the extent feasible and required by state law, depending on your state, data will be provided in a portable format. Depending on your state, you may have the right to receive additional information and it will be included in the response to your access request.
Correction. You may request that we correct inaccuracies in your personal data that we maintain, taking into account the information's nature and processing purpose.
Deletion. You may request that we delete personal data about you that we maintain following the satisfaction of all obligations with the Company and subject to certain exception under applicable law.
Important: The exact scope of these rights vary by state. There are also several exceptions where we may not have an obligation to fulfill your request.
How We Protect Your Personal Data
We use commercially reasonable administrative, physical, and technical measures designed to protect your personal data from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. However, no website, mobile application, system, electronic storage, or online service is completely secure, and we cannot guarantee the security of your personal data transmitted to, through, using, or in connection with the Services. In particular, email, texts, and chats sent to or from the Services may not be secure, and you should carefully decide what information you send to us via such communications channels. Any transmission of personal data is at your own risk.
The safety and security of your information also depends on you. You are responsible for taking steps to protect your personal data against unauthorized use, disclosure, and access.
How We Retain Your Personal Data
We keep the categories of personal data described in this policy for as long as reasonably necessary to fulfill the purposes described or for as otherwise legally permitted or required, such as maintaining the Services, operating our organization, complying with our legal obligations, resolving disputes, and for safety, security, and fraud prevention. This means that we consider our legal and business obligations, potential risks of harm, and nature of the information when deciding how long to retain personal data. At the end of the retention period, personal data will be deleted, destroyed, or deidentified.
If you are a California resident, contact compliance@derbycopeland.com for more information about the retention periods that apply to the personal data categories we collect.
Changes to Our Privacy Policy
We may update this policy from time to time, and we will provide notice of any such changes to the policy as required by law. The date the privacy policy was last updated is identified at the top of the page. We will notify you of changes to this policy by updating the "last updated" date and posting the updated policy on the Services. We may email or otherwise communicate reminders about this policy, but you should check our Services periodically to see the current policy and any changes we have made to it.
Contact Information
To exercise your rights or ask questions or comment about this privacy policy or our privacy practices, contact us at: