Privacy Policy

Turning Point Capital Group ("Company," "we," "us," or "our"), a registered trade name of AVDRW Inc., provides commercial financing solutions to businesses. This Privacy Policy describes the types of information we may collect from you, or that you may provide, when you visit our website at TPCGcorp.com and any associated sub-domains, applications, and online services (collectively, the "Website"), and our practices for collecting, using, maintaining, protecting, and disclosing that information.

By accessing or using the Website, or by submitting an inquiry or application, you agree to the practices described in this Privacy Policy. If you do not agree, please do not use the Website. This policy may change from time to time; please review it periodically for updates.

Information you provide. We collect information by which you may be personally identified when you voluntarily provide it — for example, when you complete a form, submit an application, or contact us. This may include:

• Name and the name of your business
• Email address, telephone number, and mobile number
• Mailing or business address
• Business details such as industry, time in business, entity type, and revenue
• Financial information submitted with an application, such as bank statements and tax returns
• Records and copies of your correspondence if you contact us
• Responses to surveys or requests for information

Information collected automatically. When you browse the Website, we may automatically collect certain information that does not by itself identify you, to help us operate and improve the Website. This may include:

• IP address, device identifiers, and browser type
• Operating system and general location information
• Pages viewed, links clicked, and time spent on the Website
• Referring website and search terms used to reach us
• Data collected through cookies and similar tracking technologies

We collect information from the following sources:

• Directly from you, when you submit forms, applications, or documents or otherwise communicate with us
• Automatically, through cookies, server logs, and similar technologies as you interact with the Website
• From third parties and partners involved in evaluating or processing a financing request, such as credit reporting agencies, bank-data verification providers, and identity-verification services, where permitted by law

We use the information we collect for legitimate business purposes, including to:

• Evaluate, process, and respond to commercial financing requests
• Verify your identity and the information you provide, and prevent fraud
• Communicate with you about your inquiry, application, or account
• Provide customer support and respond to your questions
• Operate, maintain, improve, and personalize the Website and our services
• Send you administrative, transactional, and — where permitted — marketing communications
• Comply with legal, regulatory, and recordkeeping obligations
• Establish, exercise, or defend legal claims

We do not sell your personal information. We may share information in the following circumstances:

• With financing partners, lenders, and funders involved in evaluating, underwriting, or funding your request
• With service providers who perform functions on our behalf, such as hosting, data storage, email delivery, analytics, identity verification, and document handling
• With professional advisors such as auditors, attorneys, and accountants
• In connection with a merger, acquisition, financing, or sale of all or part of our business or assets
• With legal, regulatory, or law-enforcement authorities when required by law, legal process, or to protect our rights, property, or safety, or that of others
• With your consent or at your direction

If you provide your mobile number and consent to receive text (SMS) messages, we may send you messages related to your inquiry, application, or account. Message and data rates may apply, and message frequency varies. You can opt out of text messages at any time by replying STOP, and you can reply HELP for assistance.

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Text-messaging originator opt-in data and consent are not shared with any third parties.

Our Website may use cookies, web beacons, and similar technologies, including analytics tools, to recognize your device, remember your preferences, understand how visitors use the Website, and improve performance. Most browsers allow you to refuse or delete cookies; however, some parts of the Website may not function properly if you disable them. For more detail, see our Cookie Policy.

The Website may contain links to third-party websites, plug-ins, and applications that we do not operate or control. We are not responsible for the privacy practices or content of those third parties. We encourage you to review the privacy policy of every website you visit.

We maintain commercially reasonable administrative, technical, and physical safeguards designed to protect the information you provide, including encryption of documents in transit and at rest and access controls that limit information to authorized personnel involved in reviewing your file. However, no method of transmission over the Internet or method of electronic storage is completely secure, and we cannot guarantee the absolute security of your information.

We retain personal information for as long as necessary to fulfill the purposes described in this policy, including to provide our services, comply with our legal, accounting, and recordkeeping obligations, resolve disputes, and enforce our agreements. When information is no longer needed, we take reasonable steps to securely delete or de-identify it.

Subject to applicable law and our legal and recordkeeping requirements, you may contact us to:

• Request access to the personal information we hold about you
• Request correction of inaccurate or incomplete information
• Request deletion of your personal information
• Opt out of non-essential or marketing communications

To exercise any of these choices, contact us using the details at the end of this policy. We may need to verify your identity before acting on your request.

If you are a California resident, you may have additional rights under the California Consumer Privacy Act, as amended (the "CCPA"), including the right to know what personal information we collect, use, and disclose; the right to request deletion or correction of your personal information; and the right not to be discriminated against for exercising your rights. We do not sell personal information. To submit a request, contact us using the information below. You may designate an authorized agent to make a request on your behalf, subject to verification.

The Website is intended for businesses and individuals who are at least 18 years old. We do not knowingly collect personal information from children under 18. If we learn that we have collected personal information from a child under 18, we will take steps to delete it.

We may update this Privacy Policy from time to time. When we do, we will revise the "Last updated" date above. Your continued use of the Website after changes are posted constitutes your acceptance of the revised policy.

If you have questions about this Privacy Policy or our handling of your information, or if you would like to exercise your privacy rights, contact us at: