Privacy Policy

Last Updated: January 14, 2021

Bespoke Financial, Inc. (“Bespoke,” “we,” “us,” or “our”), is a licensed commercial lender focused on the cannabis industry.  We do not make loans for personal, family, or household purposes.  Nonetheless, we are committed to protecting your privacy. This Privacy Policy (“Privacy Policy”), describes how we collect, use, and disclose information through our general website https://bespokefinancial.com (the “Site”), through the process of applying for and receiving one of our lending products, and through our borrower financing portal (the “Platform”) (collectively, our “Services”).

By using our Services, you agree to the terms of this Privacy Policy as they may be amended from time to time.  Your use of our Services and any dispute over privacy are subject to this Privacy Policy and any applicable limitations on damages and other terms regarding the resolution of disputes within any terms of service posted to the Site or the Platform.

Because the Services may change and this Privacy Policy may change accordingly, please check back occasionally for updates.

  1. COLLECTION

The information we collect from you depends on how you engage with our Services, including whether you merely browse the Site, whether you apply for and receive a loan from us, and whether you use the Platform.

    1. When you Browse the Site.  We use cookies, web beacons, local storage objects, pixels and other technologies that operate on the Site. These technologies may collect your computer’s Internet Protocol (IP) address, domain name, internet browser and operating system, the time, date, and length of time you visit our Site, mobile device ID, the web pages you view on our Site, including the time spent on each page and clicks on each page, referring URL or the webpage that led you to our Site, and other interactions with the Site (“Technical Data”).  You can adjust the permissions within your browser or device operating system.  However, if you set your browser to disable certain technologies, such as cookies, some features of the Site may not function properly.  Please see the section Cookies and Tracking below for more information.
  • When you Submit Information through the Site.  You may also provide your business email address to subscribe to our marketing updates, request a free consultation by providing us with your name, your email address, your phone number and a message, or use the “Live Chat” feature of the Site to communicate with us.
  • When you Apply for a Loan.  If your business wishes to apply for a commercial loan from us, we will ask you to complete a New Client Application Form.  This form requests information about your company structure, finances, tax filings, and compliance with applicable State cannabis licensing and reporting requirements.  This information will be used to evaluate your business’ eligibility for our lending products.
  • When you use the Platform.  If your business is approved for a commercial loan from us, we will provide you (as a “Borrower”) with access to the Platform.  Borrowers may use the Platform to manage their loans and coordinate certain aspects of their lending products with interested third parties who may also be granted access to the Platform.  For example, if a Borrower is approved for our “Invoice Financing” product, the Borrower and the third party payor will both need to utilize the Platform.  Similarly, if a Borrower is approved for our “Purchase Money Financing” product, the Borrower and the third party payee will both need to utilize the Platform.

All Platform users must provide their name, email address, and phone number.  Users that will receive payments from Bespoke must also provide their bank account information.  We may also collect Technical Data about users’ interactions within the Platform.

  1. From Other Sources.  We may receive your business contact information from a third party who believes you would be interested in our Services.  Please let us know if you do not wish to be contacted again and we will remove your information from our contact list.  We may combine all of the information we collect and receive about you, both online and offline, and use or disclose it in the manner described in this Privacy Policy.

If you disclose to us any personal information relating to other people, you represent that you have the authority to do so and permit us to use this information in accordance with this Privacy Policy.

  1. USE

We use your information for the following purposes:

    • Providing the Services, including to communicate with you about your access to and use of the Site and the Platform, to respond to your inquiries, to provide technical support and troubleshooting, to process the terms of the loans we issue, and for other user service and support purposes;
    • Analyzing and improving the Services, including to better understand how users access and use the Site and the Platform, to evaluate and improve the Site, the Platform and our business operations, and to develop new services, to conduct surveys and other evaluations (such as user satisfaction surveys), and for other research and analytical purposes;
    • Personalizing content and experiences, including to tailor content we send or display on the Site and the Platform, to offer location customization and personalized help and instructions; and to otherwise personalize your experiences;
    • Advertising, marketing and promotional purposes, as permitted by law, including to reach you with more relevant ads and to evaluate, measure and improve the effectiveness of our ad campaigns, to send you newsletters, offers or other information we think may interest you, to contact you about the Site or information we think may interest you, and to administer promotions;
    • Otherwise securing and protecting our business, including to protect and secure our business operations, assets, our Services, network and information and technology resources, to investigate, prevent, detect and take action regarding fraud, unauthorized access, threats to the rights or safety of any person or third party, or other unauthorized activities or misconduct;
  • Defending our legal rights, including to manage and respond to actual and potential legal disputes and claims and to otherwise establish, defend or protect our rights or interests, including in the context of anticipated or actual litigation with third parties;
  • Auditing, reporting, corporate governance, and internal operations, including relating to operational, regulatory, financial, tax and accounting audits and assessment; privacy, security and financial controls; our general business, accounting, record keeping and legal functions; and related to any actual or contemplated merger, acquisition, asset sale or transfer, financing, bankruptcy or restructuring of all or part of our business; and
  • Complying with legal obligations, including to comply with the law, our legal obligations and legal process, such warrants, subpoenas, court orders, and regulatory or law enforcement requests.
  1. DISCLOSURE

We may share your information, including personal information, as follows:

  • With our service providers, to facilitate the services they provide to us.  These may include providers of services such as email delivery, information technology and related infrastructure provision, website hosting, and other services;
    • Pursuant to business transfers if (i) we or our affiliates are or may be acquired by, merged with, or invested in by another company, or (ii) if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company;
    • In response to legal processes to comply with the law, a judicial proceeding, court order, or other legal process (e.g., in response to a court order or a subpoena);
  • To protect us and others if we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, threats to the safety of any person, violations of any terms of service or this Privacy Policy, or as evidence in litigation in which we are involved; and
  • In aggregate, anonymized, or de-identified form with other entities for marketing, advertising, research or similar purposes.
  1. COOKIES AND TRACKING
  1. Technologies. We and our third party service providers use Technical Data as described above. We may combine this information with other information we collect from you (and our third party service providers may do so on our behalf).
  2. Disabling Cookies. Most web browsers automatically accept cookies but you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to the Site who disable cookies will be able to browse certain areas of the Site, but some features may not function.
  3. Third Party Analytics. We use automated devices and applications, such as Google Analytics, to evaluate usage of the Site.  We also may use other analytic means to evaluate our Services.  We use these tools to help us improve our Services performance and user experiences.  These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services.  To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/.  You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.
  4. Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests.  You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies).  You also may opt-out of targeted advertising by following the instructions in the Third Party Ad Network section below.
  5. Third-Party Ad Networks. Advertisers may also use technologies like cookies and web beacons to enable them to recognize your computer each time they send you an advertisement even when you are visiting another site. As a result, the advertiser would have the ability to deliver targeted advertisements that they believe would be of most interest to you.  We do not have access to or control of the cookies that may be placed on your computer by third-party advertisers.

Users may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members.

  1. SECURITY

We have implemented reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.  Please be aware that despite our efforts, no data security measures can guarantee security.

You should take steps to protect against unauthorized access to your information within the Platform by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private.  We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

  1. YOUR CHOICES

If you have provided us with an email address, we may send periodic promotional emails to you.  You may opt-out of promotional emails by following the opt-out instructions contained in the email.  Please note that it may take up to 10 business days for us to process opt-out requests.  If you opt-out of receiving promotional emails, we may still send you emails about your account, our Services, or any other services you have requested or received from us.

  1. THIRD PARTY LINKS

The Site may contain links to third-party websites.  Any access to and use of such linked websites is not governed by this Privacy Policy, but instead is governed by the privacy policies of those third party websites.  We are not responsible for the information practices of such third party websites.

  1. MISCELLANEOUS

Our Services are provided from the United States and are not designed for international use.  Using the Site demonstrates your consent to the transfer and processing of information as described in this Privacy Policy.  The Site is not designed for children under 13. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems.  California residents may request certain information regarding our disclosure of personally identifiable information about you to third parties’ for their own direct marketing purposes.  However, we do not currently disclose personally identifiable information to third parties for their direct marketing purposes.

  1. CHANGES TO THIS PRIVACY POLICY

This Privacy Policy is current as of the effective date set forth above.  We reserve the right to change or update this Privacy Policy, or any other of our policies or practices, at any time, and will notify users of this Site by posting such changed or updated Privacy Policy on this page.  Any changes or updates will be effective immediately upon posting to this Site.  Under certain circumstances, we may also elect to notify you of changes or updates to our Privacy Policy by additional means, such as posting a notice on the front page of this Site or sending you an email.

  1. CONTACT US

If you have questions or would like to make a complaint, please contact us at info@bespokefinancial.com or Bespoke Financial, 1043 12th Street, #5, Santa Monica, CA 90403.

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