This Policy operates separately from the Terms of Service and the Capital4Trade Membership Agreement, works together with the Cookie Policy and any transaction-specific notice, and does not replace a Data Processing Addendum when Capital4Trade processes personal information solely on behalf of a Member.
1. Scope and Who We Are
1.1 Scope
This Policy applies to personal information processed through Capital4Trade, the Capital4Trade member portal, applications, forms, communications, support channels, onboarding and due-diligence processes, and other services that link to or expressly incorporate this Policy (collectively, the "Services"). It also applies to personal information received in connection with membership, program participation, transaction evaluation, financing, insurance, logistics, payments, documentation, monitoring, and related business activities.
This Policy does not apply to information that cannot reasonably be linked to an identified or identifiable individual, including properly aggregated or de-identified information, except where applicable law treats that information as personal information.
1.2 Business and Controller Role
For the processing described in this Policy, Capital4Trade generally acts as the business, controller, or similar responsible party that determines why and how personal information is processed. In some circumstances, Capital4Trade may process personal information solely on behalf of a Member or another organization. Section 14 explains that separate role.
1.3 Business Users and Other Individuals
The Services are intended for business use. This Policy may apply to representatives, owners, directors, officers, employees, contractors, authorized users, counterparties, beneficial owners, guarantors, payors, payees, suppliers, buyers, debtors, funders, insurers, brokers, logistics contacts, professional advisers, website visitors, and other individuals whose personal information is processed in connection with the Services.
1.4 Related Documents
The Terms of Service, Membership Agreement, Program Terms, Transaction Documents, Cookie Policy, notices presented at collection, and any applicable Data Processing Addendum may provide additional or more specific terms. If a transaction participant or third party independently determines how it processes personal information, its own privacy notice governs that processing.
2. Personal Information We Collect
2.1 Identity and Contact Information
Names, business and personal contact details, job titles, employer or organization, signatures, preferred language, account identifiers, usernames, and similar information used to identify or communicate with an individual.
2.2 Account, Authentication, and Acceptance Information
Login and authentication data, account roles and permissions, multi-factor authentication events, password-reset information, accepted document versions, electronic signatures, dates and times of acceptance, IP addresses, user-agent information, device identifiers, and records used to attribute electronic actions.
2.3 Business, Ownership, and Compliance Information
Business affiliations, ownership and control information, beneficial-owner details, identification documents, tax or registration numbers, licenses, sanctions and watchlist results, anti-money laundering and know-your-business information, litigation or regulatory information, references, background information, and other data reasonably required for identity, eligibility, risk, fraud, or compliance reviews.
2.4 Financial, Banking, and Payment Information
Bank account details, account ownership information, payment instructions, transaction history, balances, cash-flow and financial-statement information, credit-related information, invoices, receivables, payables, purchase orders, fees, payment status, and information received through authorized financial-data or payment integrations.
2.5 Program, Transaction, and Commercial Information
Applications, requested amounts, proposed terms, approvals, commitments, underwriting or risk information, insurance information, transaction parties, communications, supporting evidence, decisions, conditions, exceptions, performance history, disputes, and records concerning financing, purchases, sales, factoring, payables, receivables, or other commercial programs.
2.6 Logistics and Trade Documentation
When relevant to a requested service or transaction: commercial invoices, packing lists, bills of lading, airway bills, customs and export documentation, shipment references, cargo descriptions, locations, routes, delivery records, inspection information, claims, photographs, signatures, and contact information for shippers, consignees, carriers, warehouses, brokers, and other logistics participants. We may also collect or generate information through our internal systems when a Member uses the Platform, submits a service request, participates in a transaction, or communicates with us, including when information is synchronized between the member portal and Capital4Trade's internal ERP system.
2.7 Platform, Device, and Usage Information
IP address, browser and device type, operating system, language, session identifiers, pages and features used, timestamps, clicks, workflow events, access logs, error records, security signals, and similar diagnostic or usage information, collected automatically.
2.8 Communications and Support Information
Emails, messages, meeting records, call or support details, survey responses, feedback, uploaded files, and other communications with Capital4Trade or through the Platform. If a call or meeting is recorded, we will provide any notice or obtain any consent required by applicable law.
2.9 Sensitive Personal Information
Depending on the service and applicable requirements, some information may be considered sensitive, such as government identification numbers, financial-account credentials, precise identification data, biometric identifiers used for verification, or information revealing sanctions or criminal-risk screening results. We process sensitive personal information only when reasonably necessary for authorized purposes, with consent where required, or as otherwise permitted by law.
3. Sources of Personal Information
We may obtain personal information directly from you; from the organization you represent; from account owners or authorized users; from applicants, counterparties, transaction participants, guarantors, suppliers, buyers, debtors, or professional advisers; from documents uploaded to the Platform; and from interactions with the Services.
We may also receive information from public records and government sources; sanctions, corporate-registration, fraud-prevention, identity-verification, credit, business-information, insurance, banking, payment, electronic-signature, logistics, communications, and analytics providers; integration partners; and other lawful sources. Information received from another organization may be subject to its instructions and privacy notice as well as this Policy.
4. How We Use Personal Information
4.1 Provide and Administer the Services
To create and manage accounts; authenticate users; administer membership; receive and evaluate applications; operate workflows; exchange documents and information; support programs and transactions; provide customer support; process payments and fees; maintain records; and deliver requested features.
4.2 Identity, Due Diligence, Risk, and Compliance
To verify identity, authority, ownership, and business information; perform sanctions, anti-money laundering, fraud, credit, eligibility, reputation, and other risk checks; monitor transactions; investigate suspected misconduct; respond to legal process; and satisfy legal, contractual, audit, insurance, or funding requirements.
4.3 Facilitate Programs and Transactions
To connect and coordinate Members and potential participants; evaluate proposed programs or transactions; request and compare terms; support documentation and closing; monitor milestones, payments, shipments, claims, and performance; and communicate with funders, purchasers, insurers, brokers, administrators, logistics providers, advisers, and other relevant participants.
4.4 Secure, Maintain, and Improve the Services
To secure accounts and systems; detect abuse and technical failures; maintain availability; troubleshoot; perform testing; analyze usage and performance; develop or improve features; create aggregated or de-identified insights; and enforce applicable agreements and policies.
4.5 Communicate and Market
To send transactional, service, security, compliance, legal, and administrative communications and, where permitted, information about Capital4Trade services, events, or opportunities. Recipients may opt out of marketing communications, but not essential account, transaction, security, or legal communications.
4.6 Other Disclosed or Authorized Purposes
For another purpose disclosed at collection, with the individual's direction or consent, to protect rights and safety, or as otherwise permitted or required by law. We will not use personal information for a materially incompatible purpose without providing any notice or choice required by applicable law.
4.7 Internal ERP and System Integration
The Capital4Trade member portal communicates with our internal enterprise resource planning (ERP) system and related backend services through secure server-to-server APIs. Information submitted through or generated by the member portal may be transferred to, synchronized with, and processed within these internal systems, including account, business, service-request, transaction, financing-term, document, and communication records.
These communications occur exclusively between Capital4Trade-controlled backend systems and do not involve direct communication between the ERP and a user's browser. This internal transfer is not a sale of personal information or a disclosure to an unaffiliated third party. Access is restricted to authorized personnel and service providers with a legitimate business, technical, security, or compliance need.
5. Legal Bases for Processing
Where applicable law requires a legal basis, Capital4Trade relies on one or more of the following: performance of a contract or steps requested before entering a contract; compliance with legal obligations; legitimate interests in operating, securing, improving, and protecting the Services and facilitating legitimate business transactions; consent; and establishment, exercise, or defense of legal claims.
Our legitimate interests may include account administration, due diligence, fraud prevention, network and information security, business communications, service improvement, transaction coordination, recordkeeping, and protection of Capital4Trade, Members, users, and other participants. Where consent is the legal basis, it may be withdrawn prospectively, subject to legal and contractual limits.
6. Automated Tools & Artificial Intelligence
Capital4Trade may use rules-based systems, data extraction, matching tools, analytics, machine learning, or artificial intelligence to organize documents, identify potential matches, detect anomalies or fraud indicators, support risk and compliance review, summarize information, assist communications, and improve workflows. Outputs may be incomplete or inaccurate and are subject to appropriate review before material reliance.
Automated tools may support, but do not by themselves guarantee, membership, eligibility, financing, insurance, logistics, payment, or transaction outcomes. Third-party participants may apply their own models and decision processes under their own notices and agreements. Where applicable law provides rights concerning a decision based solely on automated processing that produces legal or similarly significant effects, Capital4Trade will provide the required information and process applicable requests.
7. How We Disclose Personal Information
7.1 Organizations and Authorized Users
Within the organization associated with an account and to its account owners, authorized users, affiliates, advisers, and representatives according to configured roles, permissions, instructions, and applicable agreements.
7.2 Program and Transaction Participants
To prospective or actual funders, insurers, logistics providers, and other participants when reasonably necessary to evaluate, structure, administer, monitor, or complete a requested program or transaction.
7.3 Service Providers
To providers that support document processing, analytics, artificial intelligence, identity and business verification, sanctions and fraud screening, financial-data connections, and other business operations. These providers may process information only for authorized purposes and subject to appropriate contractual obligations.
7.4 Professional Advisers, Insurers, and Affiliates
To affiliates and to legal, insurance, compliance, and other professional advisers when reasonably necessary for legitimate business, risk-management, or legal purposes.
7.5 Legal, Regulatory, Safety, and Enforcement Purposes
When we reasonably believe disclosure is required by law, court order, regulatory request, sanctions requirement, or other legal process; to establish or defend legal claims; to investigate fraud or misuse; to protect the rights, property, security, or safety of Capital4Trade or others; or to enforce agreements and policies.
7.6 At Your Direction or With Consent
When you or the organization you represent directs us to do so, authorizes an integration, requests an introduction, submits a transaction, or otherwise consents to the disclosure.
8. Sale, Sharing & Targeted Advertising
Capital4Trade does not sell personal information for monetary consideration. We do not knowingly sell or share sensitive personal information, or personal information concerning individuals under 18, for cross-context behavioral advertising.
Some website analytics, advertising, or similar technologies may be treated as a "sale," "sharing," or processing for targeted advertising under certain privacy laws even when no money is exchanged. Where required, Capital4Trade will provide a method to opt out, honor legally recognized browser-based opt-out preference signals, and describe the relevant technologies in the Cookie Policy or consent interface. An opt-out may apply only to the browser and device used to submit it unless the individual is authenticated or applicable law requires otherwise.
10. Data Retention
Capital4Trade retains personal information for as long as reasonably necessary for the purposes described in this Policy, including to maintain an account or membership; evaluate or administer a program or transaction; provide the Services; comply with legal, tax, sanctions, anti-money laundering, insurance, audit, and recordkeeping obligations; prevent fraud; resolve disputes; enforce agreements; and preserve evidence.
Retention periods vary according to the type and sensitivity of information, the nature and duration of the relationship, transaction status, legal or contractual requirements, applicable limitation periods, risk of harm, and technical considerations. When information is no longer required, Capital4Trade may delete, anonymize, or securely isolate it. Residual copies may remain in backups until overwritten through ordinary cycles, subject to access restrictions and legal holds.
11. Security
Capital4Trade maintains reasonable administrative, technical, and organizational safeguards designed to protect personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, misuse, and other reasonably foreseeable risks. Safeguards may include role-based access controls, authentication measures, encryption in transit and where appropriate at rest, logging and monitoring, vulnerability and patch management, backups and recovery procedures, secure development practices, vendor-risk controls, incident-response procedures, workforce confidentiality obligations, and periodic review of security measures.
Safeguards are selected in light of the nature and sensitivity of the information, the context and purposes of processing, available technology, implementation cost, and the likelihood and severity of potential harm. Capital4Trade may update its safeguards as technology, operations, identified risks, and legal or contractual requirements evolve.
No method of transmission, storage, or security is completely secure. Capital4Trade therefore cannot guarantee that unauthorized access, loss, misuse, or a security incident will never occur. Individuals should protect credentials, maintain secure devices, and promptly report suspected compromise to support@capital4trade.com.
12. International Data Transfers
Capital4Trade is based in the United States and may process information in the United States and other countries where Capital4Trade, its providers, or transaction participants operate. Privacy and data-protection laws in those locations may differ from the laws where an individual resides.
When required for a restricted international transfer, Capital4Trade will use an approved legal mechanism and supplementary safeguards appropriate to the circumstances, which may include contractual protections, adequacy decisions, or another lawful transfer basis. Transaction participants that independently receive information are responsible for their own transfer and processing obligations.
13. Privacy Rights & Choices
13.1 Account and Communication Choices
Users may review or update certain account information through available Platform controls or by contacting Capital4Trade. Marketing communications may be declined through the unsubscribe method in the message or by contacting us. Capital4Trade may continue sending non-marketing messages concerning accounts, security, transactions, legal notices, or requested Services.
13.2 Rights Available Under Applicable Law
Depending on your location, relationship with Capital4Trade, and applicable law, you may have rights to request access to or a copy of personal information; correction; deletion; portability; restriction or objection; withdrawal of consent; information about categories, sources, purposes, and recipients; limitation of certain uses of sensitive information; opt-out of sale, sharing, or targeted advertising; opt-out of certain profiling or automated decisions; and freedom from unlawful discrimination for exercising a privacy right.
These rights are not absolute. Capital4Trade may deny or limit a request where permitted, including when information is required to provide a requested service, complete a transaction, protect security, prevent fraud, comply with law, preserve legal claims, honor another person's rights, or maintain records that cannot lawfully or reasonably be deleted.
13.3 Submitting a Request
To submit a privacy request, email support@capital4trade.com with the subject line "Privacy Request," or use any privacy-request method made available on the Capital4Trade website. Describe the request and identify the relevant account or relationship. Do not send passwords, full financial-account credentials, or unnecessary sensitive information by email.
Capital4Trade may verify identity and authority before acting on a request. Verification may require matching information already held, confirming control of an email address or account, or requesting additional evidence proportionate to the sensitivity of the request. If Capital4Trade cannot verify a request, it may ask for more information or decline the request as permitted by law.
13.4 Authorized Agents and Appeals
Where permitted by law, an authorized agent may submit a request on an individual's behalf, subject to proof of authorization and identity verification. If applicable law provides a right to appeal a refusal, you may appeal by replying to the decision or emailing support@capital4trade.com with the subject line "Privacy Appeal."
13.5 California and Other United States State Disclosures
If a United States state privacy law applies to Capital4Trade and the individual, the categories in Section 2, the sources in Section 3, the purposes in Sections 4 and 6, and the recipients in Section 7 provide the required overview of collection, use, and disclosure. Capital4Trade will provide any additional notice, metrics, or opt-out mechanism required by that law, and does not use or disclose sensitive personal information to infer characteristics about an individual except as permitted by law.
13.6 European Economic Area, United Kingdom, and Similar Jurisdictions
Where the GDPR, UK data-protection law, or a similar law applies, individuals may have the rights described in Section 13.2 and may lodge a complaint with the competent supervisory authority. We encourage individuals to contact us first so we can attempt to address the concern. Capital4Trade will identify a representative or data protection officer if and when applicable law requires one.
14. Organization Data & Processor Activities
A Member or other organization may upload or provide personal information concerning its personnel, customers, suppliers, counterparties, or other individuals and may determine the purposes and means of that processing. When Capital4Trade processes such information solely on the organization's documented instructions, the organization is responsible for providing required notices, obtaining required rights or consents, responding to individuals, and ensuring the lawfulness of the information and instructions.
Capital4Trade will process that information under the applicable agreement and, where required, a Data Processing Addendum. A privacy request concerning information controlled by an organization may be referred to that organization. Capital4Trade may still act as an independent controller for account administration, security, fraud prevention, legal compliance, billing, service analytics, and protection of its rights.
15. Children
The Services are intended exclusively for business users and are not directed to children or minors. Individuals under eighteen (18) years of age may not create an account or use the Services.
Capital4Trade does not knowingly collect personal information through the Services from individuals under eighteen (18) years of age. If Capital4Trade learns that it has collected personal information from a minor in violation of this Policy or applicable law, it will take reasonable steps to delete or otherwise appropriately restrict that information, subject to any legal obligation to retain it.
A parent or legal guardian who believes that a minor has provided personal information through the Services may contact Capital4Trade at support@capital4trade.com using the subject line "Child Privacy."
16. Third-Party Services & Links
The Services may contain links to, integrations with, or content from third-party websites, platforms, data providers, or transaction participants. Their privacy practices are governed by their own notices when they independently control processing. Capital4Trade is not responsible for a third party's privacy practices, security, or content, except to the extent expressly required by law or a written agreement.
17. Changes to This Policy
Capital4Trade may update this Policy prospectively to reflect changes in law, technology, business operations, Services, or privacy practices. The revised Policy will state its updated date. If a change is material, Capital4Trade will provide additional notice through the Platform, by email, or through another reasonable method when required by law. If consent is legally required for a new processing activity, Capital4Trade will request it before relying on that consent.
18. Contact Us
Questions or requests concerning this Policy or Capital4Trade's privacy practices may be submitted as follows, or through the contact form available on our website:
Transport Networks LLC, doing business as Capital4Trade Network
Email: support@capital4trade.com · Subject line: Privacy Request
Mail: 11410 NW 20 Street, Suite 224, Miami, Florida 33172, United States
Please do not include passwords, full financial-account credentials, or unnecessary sensitive information in an initial request. Capital4Trade may direct a requester to a secure channel when additional documentation is required.