Privacy Policy

Siteworks Capital, LLC (“Siteworks Capital,” “we,” “us”) is a commercial real estate lender. This policy explains what information we collect through 33holdings.com, through the borrower, broker, and investor portals, and through the loan origination and servicing process, and what we do with it.

It covers applicants, borrowers, guarantors, principals and owners of borrowing entities, broker partners, investors, and ordinary site visitors. It does not cover the practices of third parties whose services we use — appraisers, title agents, consumer reporting agencies, and payment processors each maintain their own notices.

Information you give us

• Identity and contact details: name, entity name, mailing address, email, and telephone number.
• Application information: entity type and formation details, EIN, ownership percentages, estimated credit score, project history, and the property, budget, and loan request itself.
• Financial information: liquidity and reserve balances, bank statements, schedules of real estate owned, tax identification numbers, and payoff or takeout details.
• Documents you upload: government identification, articles of organization, operating agreements, contractor licenses, purchase contracts, plans, permits, insurance certificates, and lien waivers.
• Draw evidence: progress photographs, which may carry embedded location and timestamp data, and inspection reports.
• Broker information: brokerage name, contact details, states covered, production volume, and your compensation arrangement.

Information we collect automatically

• Device and connection data: IP address, browser and operating system, and referring page.
• Usage data: pages viewed, actions taken in the portal, and timestamps, which we also retain as an audit trail of loan-file activity.
• Cookies and similar technologies, described in section 6.

Information we obtain from others

• Consumer and business reporting agencies, once you authorize a credit inquiry.
• Background screening and fraud-prevention vendors.
• Public records: secretary of state filings, county assessor and recorder data, court records, and lien and title searches.
• Appraisers, inspectors, title companies, and closing attorneys engaged on your file.
• Your broker, if one submitted an application on your behalf.

• To evaluate an application, underwrite credit, price a loan, and issue terms.
• To verify identity, ownership, entity standing, and the accuracy of what was submitted.
• To close, fund, service, and administer loans, including draws, inspections, insurance tracking, payments, and payoffs.
• To operate AI-assisted intake and pre-screening, which organizes a file and evaluates it against our published credit box. A person always makes the final credit decision; you are never approved or denied solely by automated processing.
• To communicate with you about your application, your loan, and this platform.
• To detect and prevent fraud, and to secure our systems.
• To comply with law, including anti-money-laundering, sanctions screening, recordkeeping, and lending regulations.
• To maintain an immutable audit record of submissions, decisions, and disbursements.
• To improve our products and, where permitted, to market our services to you.

We do not sell personal information, and we do not share it for cross-context behavioral advertising.

Starting an application does not trigger a credit inquiry. You provide an estimated credit score, and we pre-screen and underwrite on that basis. A hard credit inquiry and a background check occur only after you accept terms and elect to proceed into diligence, and only after you give a separate, explicit authorization at that step.

Where a consumer report is obtained and we take adverse action based in whole or in part on it, we will provide the notice the Fair Credit Reporting Act requires, including the identity of the reporting agency and your right to obtain a free copy of the report and to dispute its accuracy.

We disclose information only as described here:

• Service providers acting on our behalf under contract: hosting, e-signature, document storage, payment processing, identity verification, background screening, appraisal management, inspection, title, escrow, and closing counsel.
• Consumer and business reporting agencies, once authorized.
• Your broker, if one submitted your file, limited to the status and terms of that file.
• Insurers and their agents, to confirm coverage naming us as loss payee.
• Investors and fund administrators, in aggregated or de-identified form for portfolio reporting. Loan-level detail is disclosed only where our loan documents permit it.
• Successors in interest in a merger, acquisition, financing, or sale of assets.
• Government authorities, regulators, and parties to legal process where required by law or to protect rights and safety.

We hold what we originate. We do not sell loans into the secondary market, so your file is not routinely transferred to a purchaser or a replacement servicer.

We use strictly necessary cookies to keep you signed in, to maintain your session, to remember your light or dark theme preference, and to protect forms against automated abuse. These cannot be switched off without breaking the site.

Where we use analytics, we configure it to avoid collecting more than we need and we do not permit our providers to use the data for their own purposes. We honor Global Privacy Control signals where applicable law requires it.

• Marketing email: use the unsubscribe link in any marketing message. Transactional messages about your application or loan will continue while your relationship with us is active.
• Text messages: reply STOP to any message to opt out of that program. Message and data rates may apply.
• Electronic records: see our E-Sign consent for how to request paper copies or withdraw consent to electronic delivery.
• Account information: sign in to review or correct what you submitted, or contact us for help.

Withdrawing a consent does not affect the lawfulness of what we did before you withdrew it, and some records must be retained regardless of your preferences.

Depending on where you live, you may have the right to know what personal information we hold about you, to obtain a copy of it, to correct it, to delete it, and to appeal a refusal. To exercise any of these, contact us using section 12. We will verify your identity before acting, and we will not discriminate against you for exercising a right.

Much of what we hold about applicants and borrowers is subject to the Gramm-Leach-Bliley Act or the Fair Credit Reporting Act, and those laws — not general state privacy statutes — govern how that information may be handled. Where a state exemption applies, we will say so in our response.

We protect information with encryption in transit and at rest, role-based access controls, least-privilege database policies enforced at the row level, phishing-resistant authentication for staff, audit logging of privileged actions, and vendor due diligence.

No method of transmission or storage is perfectly secure. Never send a full bank account or social security number by unsecured email; use the document vault in your portal. We confirm every wire instruction by telephone callback to a number we already have on file, and we will never send you changed wire instructions by email alone. If you receive one, it is fraudulent — call us before you send anything.

We keep loan files, decision records, and the associated audit trail for the life of the loan and for the period our regulators, lending laws, and record-retention obligations require afterward — generally at least seven years from payoff or from the date of a declination. Documents in your reusable vault are kept until you ask us to remove them or until they are no longer needed for an active or contemplated loan. Marketing contact data is kept until you unsubscribe.

Our services are for businesses and their principals. They are not directed to anyone under 18, and we do not knowingly collect information from children. If you believe a child has given us information, contact us and we will delete it.

We may update this policy. When we do, we will change the effective date at the top and, if the change is material, give notice through the platform or by email before it takes effect. Prior versions are available on request.

Questions, requests, and complaints about this policy go to our privacy contact:

Siteworks Capital, LLC
1000 Peachtree Industrial Boulevard, Suite 200
Atlanta, GA 30000
hello@siteworkscapital.com · (000) 000-0000

See also our E-Sign consent and licensing disclosures.