Privacy Policy

Keane-Ventures, LLC D.B.A. Liminal Lending Company (“Liminal,” “we,” “us,” or “our”) respects your privacy and is committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit our website and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This privacy policy applies to our loan matching platform and is subject to the Gramm-Leach-Bliley Act and other federal financial privacy regulations.

Geographic Service Area

We currently operate only in Texas. Our services are not available to residents of other states at this time. All lender partners are verified to be appropriately licensed in Texas. Users outside of Texas may not use our services.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our platform, including information:

• By which you may be personally identified, such as name, postal address, email address, telephone number, social security number, or any other identifier by which you may be contacted online or offline (“personal information”)
• Financial and Loan-Related Data: If you submit an SBA loan application through the platform, we collect additional financial and business information necessary for matching with lending partners
• That is about you but individually does not identify you, such as usage patterns and preferences
• About your internet connection, the equipment you use to access our platform, and usage details

Detailed Information Categories

• Identity Information: Name, Social Security Number, driver's license number, date of birth
• Contact Information: Email address, phone number, mailing address
• Financial Information: Credit score, bank account information, financial statements, tax returns, income information
• Business Information: Business name, EIN, business financial data, ownership structure
• Application Information: Loan application details, supporting documents, business plans
• Technical Information: IP address, browser type, device information, usage data

Information from Third Parties

We may receive information about you from credit bureaus, banks, government agencies, and other financial institutions to verify your information and assess creditworthiness, including:

• Soft Credit Inquiries: We may perform soft credit pulls that do not affect your credit score
• Credit Data Retention: Credit scores and related data may be retained with your application and shared with approved lenders
• Verification Services: Identity and business verification from third-party services

Disclaimer: All credit estimates and approval odds provided by our platform are informational only and not official credit reports.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To match borrowers with SBA lenders and partners
• To present our platform and its contents to you
• To provide you with information, products, or services that you request from us
• To fulfill any other purpose for which you provide it
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us
• To notify you about changes to our platform or any products or services we offer
• To fulfill legal and regulatory obligations
• To conduct analytics and improve our offerings
• For any other purpose with your consent

Information Sharing and Disclosure

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

With SBA Lenders and Partners

We share your information with verified lenders and financial institutions when you submit a loan application through our platform.This sharing generates revenue for our business through lead sales and funding commissions.

Service Providers

We may share information with third-party service providers who perform services on our behalf, including:

• Identity verification services
• Credit reporting agencies
• Document processing services
• Technology and security providers
• Customer support services

Other Disclosures

• To our subsidiaries and affiliates
• To contractors, service providers, and other third parties we use to support our business
• 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 our assets
• 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 do not sell your personal information to third parties for their marketing purposes.

Data Security

We implement administrative, technical, and physical safeguards designed to protect your Personal Information, including:

• Encryption of data in transit and at rest
• Multi-factor authentication for admin access
• Regular security assessments and updates
• Limited access controls to authorized personnel and approved lenders
• Employee training on data protection

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our platform, you are responsible for keeping this password confidential.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our platform.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

General Rights

• Tracking Technologies: You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent
• Promotional Communications: If you do not wish to receive promotional emails, you can opt-out by checking the relevant box or by sending us an email at contact@liminallending.com
• Targeted Advertising: You can opt-out by adjusting your preferences or contacting us

State Privacy Rights

California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:

• Confirm whether we process their personal information
• Access and delete certain personal information
• Correct inaccuracies in their personal information
• Data portability
• Opt-out of personal data processing for targeted advertising, sales, or profiling
• Either limit (opt-out of) or require consent to process sensitive personal data

To exercise any of these rights, please contact us at contact@liminallending.com.

Retention of Information

We retain your Personal Information for as long as necessary to fulfill the purposes outlined in this policy, comply with legal obligations, resolve disputes, and enforce our agreements.

• Financial Records: May be retained for up to seven years as required by federal regulations
• Active Applications: Retained indefinitely for business purposes and potential lender matching
• Purchased Lead Data: Retained according to lender agreements and transferred ownership rights

Children Under the Age of 18

Our platform is not intended for individuals under 18 years of age. No one under age 18 may provide any information to or on the platform. We do not knowingly collect personal information from individuals under 18. If you are under 18, do not use or provide any information on this platform. If we learn we have collected or received personal information from an individual under 18 without verification of parental consent, we will delete that information.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we will notify you through a notice on our platform homepage. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our platform and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at: