Privacy Policy

This Privacy Policy describes how DLC Enterprise, LLC, a California limited liability company (“we,” “us,” or “our”) collects, uses, discloses, and protects information in connection with the software platform currently or formerly marketed as “AssetFlowPro” (the “Platform”). It is incorporated by reference into our Terms of Use. By accessing the Platform you acknowledge this Policy.

1. Scope

This Policy applies to information processed through the Platform. The Platform is a business-to-business tool used by real estate finance professionals. Some information processed through the Platform relates to third-party borrowers, counterparties, and other individuals (“Subject Individuals”) and is uploaded or entered by our business customers, who are responsible for their own privacy practices and for having a lawful basis to provide that information to us.

2. Information We Collect

We collect the following categories of information:

1. Account & identity data — name, username, email address, display name, role, and password (stored only as a salted cryptographic hash).
2. Usage & device data — IP address, browser and device characteristics (user-agent), pages accessed, timestamps, and audit-log events recording actions taken in the Platform.
3. Customer-supplied asset data — loan, property, borrower, valuation, financial, bankruptcy, and servicing information uploaded or entered by our business customers, which may include Subject Individuals’ names, addresses, contact details, loan balances, payment history, and credit-related information.
4. Documents & communications — files, notes, and correspondence uploaded to or generated within the Platform.
5. Acceptance records — records of your acceptance of our Terms of Use, including version, timestamp, IP address, and user-agent.

We do not intentionally solicit Social Security numbers or financial account numbers from Platform users for account-creation purposes. To the extent customer-supplied asset data contains such identifiers, it is handled as described in Sections 6 and 9.

3. How We Collect Information

We collect information (a) directly from you when you create or use an account; (b) automatically through your use of the Platform (logs, cookies, and similar technologies); and (c) from our business customers when they upload or enter asset data.

4. How We Use Information

We use information to:

1. provide, operate, secure, maintain, and improve the Platform;
2. authenticate users and administer access controls;
3. generate reports, statements, and analyses requested by customers;
4. monitor for, investigate, and prevent fraud, abuse, and security incidents;
5. maintain audit logs and comply with legal and regulatory obligations;
6. develop aggregated or de-identified analytics and product improvements; and
7. communicate with you about the Platform.

5. How We Disclose Information

We disclose information only as follows:

1. Service providers / processors — hosting, infrastructure, security, analytics, and similar vendors that process information on our behalf under written confidentiality and data- protection obligations;
2. Within a customer’s account — to other authorized users of the same customer, according to the access controls the customer configures;
3. Legal & safety — when required by law, subpoena, or legal process, or to protect the rights, property, or safety of DLC Enterprise, LLC, our customers, or others;
4. Business transfers — in connection with a merger, acquisition, financing, or sale of assets, subject to this Policy.

We do not sell personal information, and we do not “share” personal information for cross-context behavioral advertising as those terms are defined under the California Consumer Privacy Act, as amended (the “CCPA”).

6. Notice at Collection (California)

Consistent with the CCPA, at or before the point of collection we inform you of the categories of personal information collected (Section 2), the purposes for which it is used (Section 4), whether it is sold or shared (it is not — Section 5), and the retention period (Section 8). This Section, together with Sections 2, 4, 5, and 8, constitutes our “Notice at Collection.”

7. Your Privacy Rights

Depending on your jurisdiction and subject to legal exceptions, you may have the right to:

1. Know / access the personal information we hold about you and how it is processed;
2. Correct inaccurate personal information;
3. Delete personal information, subject to exceptions (including records we must retain for legal, audit, or security purposes);
4. Opt out of any sale or sharing of personal information (note: we do not sell or share personal information);
5. Limit the use of sensitive personal information; and
6. Non-discrimination — we will not discriminate against you for exercising these rights.

Because much of the asset data on the Platform is supplied and controlled by our business customers, a request from a Subject Individual relating to that data may be directed by us to the relevant customer, who acts as the controller of that data. We will cooperate reasonably with our customers to facilitate such requests.

8. How to Exercise Your Rights

To exercise any right above, contact us using the details in Section 16. We will verify your request by confirming control of the account or email associated with the information and will respond within the timeframes required by applicable law. You may use an authorized agent to submit a request on your behalf with proof of authorization.

9. Financial Information & GLBA

To the extent we or our customers are “financial institutions” under the Gramm-Leach-Bliley Act (“GLBA”), nonpublic personal financial information is handled in accordance with GLBA and the FTC Safeguards Rule. We maintain administrative, technical, and physical safeguards designed to protect such information, and we limit its use and disclosure to what is permitted by law and necessary to provide the Platform.

10. Data Retention

We retain personal information for as long as needed to provide the Platform, and thereafter as required to comply with legal, regulatory, audit, tax, and recordkeeping obligations, to resolve disputes, and to enforce our agreements. Audit-log and acceptance records are retained on a longer, immutable basis for evidentiary and compliance purposes.

11. Data Security

We employ reasonable administrative, technical, and physical safeguards designed to protect information, including encrypted transport (TLS), access controls, authentication controls, session management, audit logging, and content-security protections. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for safeguarding your account credentials.

12. Cookies & Tracking Technologies

The Platform uses strictly necessary cookies and similar technologies (including session storage) for authentication, security, and performance. We do not use cookies for cross-context behavioral advertising. Your browser settings can be used to manage cookies, though disabling strictly necessary cookies will impair the Platform.

13. Children’s Privacy

The Platform is a business tool not directed to children, and we do not knowingly collect personal information from anyone under 18. If you believe a minor’s information has been provided to us, contact us and we will delete it.

14. Third-Party Services & Links

The Platform may integrate with or link to third-party services (for example, mapping and property-data providers). Their handling of information is governed by their own privacy policies, which we do not control.

15. Changes to This Policy

We may update this Policy from time to time. The “Effective Date” above reflects the latest revision. Material changes will be communicated through the Platform or by other reasonable means.

16. Contact Us

For privacy questions or to exercise your rights, contact DLC Enterprise, LLC at the email or postal address designated for privacy inquiries.