RED ROCK CAPITAL

Privacy Policy

PLEASE NOTE

Red Rock Capital makes loans exclusively for business, commercial, and investment purposes, secured by non-owner-occupied 1–4 unit residential investment property and other investment real estate. We do not originate consumer-purpose mortgage loans, and our loans are not made for personal, family, or household purposes.

CONTENTS
1. Scope of This Policy
2. Information We Collect
3. Where We Get It
4. How We Use Information
5. Credit Reports & Background Checks
6. How We Disclose Information
7. Cookies, Analytics & Advertising
8. Your Choices
9. Text Messaging (SMS)

10. State Privacy Rights
11. Additional California Disclosures
12. Data Retention
13. Information Security
14. Children’s Privacy
15. Third-Party Sites
16. Changes to This Policy
17. How to Contact Us

1. Scope of This Policy

This Privacy Policy explains how Island View Mortgage, Inc. d/b/a Red Rock Capital (“Red Rock Capital,” “we,” “us,” or “our”) collects, uses, discloses, and safeguards information in connection with:

  • our website at www.fundwithredrock.com and any related pages, forms, or portals we operate (the “Site”);
  • loan inquiries, term sheet requests, and loan applications submitted to us;
  • loans we originate, fund, purchase, sell, service, or arrange; and
  • our relationships with mortgage brokers, referral partners, correspondents, capital partners, investors, vendors, and other business contacts.

Your use of the Site is also governed by our Terms & Conditions , which include the terms of our text messaging program.

This Policy applies to information about individuals. It also describes our handling of information about business entities to the extent that information identifies or relates to an individual — for example, a manager, member, officer, or personal guarantor of a borrowing entity.

A note on financial privacy law

The federal Gramm-Leach-Bliley Act (“GLBA”) privacy rules generally govern nonpublic personal information about individuals who obtain financial products or services for personal, family, or household purposes. Because Red Rock Capital extends credit solely for business and investment purposes, most of the information we collect in connection with a loan is business or commercial information rather than GLBA-regulated consumer financial information, and we do not generally deliver GLBA privacy notices in connection with our loans. Nevertheless, we apply the protections described in this Policy to personal information we hold about individuals — including guarantors and principals — and we comply with applicable state privacy laws, the Fair Credit Reporting Act, and other applicable requirements.

2. Information We Collect

2.1 Information you give us

Inquiry and contact information.
Name, business name, email address, telephone number, mailing address, the subject property address, loan amount and product sought, your role in the transaction, and any information you include in a message to us.

Loan application and underwriting information.
When an entity applies for financing, we collect information about the borrowing entity and about the individuals behind it, which may include:

  • name, date of birth, Social Security number or ITIN, taxpayer identification number, government-issued identification, and citizenship or residency status;
  • contact and residence information;
  • ownership percentages, entity organizational documents, operating agreements, articles, EINs, and certificates of good standing;
  • real estate investing experience, track record, and schedule of prior and current projects;
  • bank statements, proof of funds, liquidity and reserve documentation, asset and liability schedules, tax returns, and financial statements;
  • credit reports, credit scores, and credit history for guarantors and principals;
  • background, litigation, bankruptcy, foreclosure, and lien history;
  • property information including purchase contracts, rehab budgets and scopes of work, rent rolls, leases, appraisals, valuations, title commitments, insurance policies, payoff statements, inspection reports, and photographs; and
  • escrow, closing, wire instruction, and payment information, including bank account and routing numbers for funding, draws, and loan payments.

Broker and partner information.
If you work with us as a broker, referral source, correspondent, vendor, or capital partner, we collect your business contact details, licensing and NMLS information where applicable, W-9 and payment details, and records of our dealings with you.

Communications.
Emails, text messages, form submissions, and — where permitted by law and with any required notice or consent — recordings or notes of telephone calls.

2.2 Information collected automatically

When you visit the Site, we and our service providers automatically collect: IP address, general location inferred from IP address, browser and device type, operating system, device identifiers, referring and exit URLs, pages and content viewed, search terms, links clicked, dates and times of access, and similar diagnostic and usage data. See Section 7 for details on the technologies used.

2.3 Information we do not seek

We do not ask for, and request that you not send us, sensitive information that is not required for a loan file — such as health or medical information, biometric data, precise geolocation, or information about your race, ethnicity, religion, sexual orientation, or political or union affiliation. If we collect government-issued identifiers, financial account numbers, or credit information, we treat that information as confidential and use it only for the purposes described in this Policy.

3. Where We Get It

We obtain information from:

  • You, through the Site, applications, emails, calls, and documents you provide;
  • Mortgage brokers, loan officers, and referral partners who submit scenarios or applications on your behalf;
  • Consumer reporting agencies and credit bureaus, for credit reports and scores on guarantors and principals;
  • Background, fraud, identity-verification, and OFAC/sanctions screening providers;
  • Appraisers, valuation providers, inspectors, title and escrow companies, insurance agents, and contractors involved in the transaction;
  • Public records and commercial data sources, including county recorder, assessor, secretary of state, court, MLS, and property data vendors;
  • Loan servicers, sub-servicers, prior lenders, and payoff agents; and
  • Analytics and advertising providers, and platforms where we advertise.

4. How We Use Information

We use the information described above to:

  • respond to inquiries, provide quotes and term sheets, and communicate with you about a scenario or loan;
  • evaluate, underwrite, approve, decline, document, close, and fund loans;
  • verify identity, confirm entity authority and good standing, and assess creditworthiness, experience, liquidity, and collateral;
  • order and review appraisals, title, insurance, inspections, and draw reports;
  • administer, service, and collect loans, including draws, payoffs, extensions, modifications, defaults, and workouts;
  • sell, assign, participate, securitize, pledge, or otherwise transfer loans and servicing rights, and to respond to diligence requests from prospective purchasers and capital partners;
  • maintain our business records, accounting, and internal reporting;
  • detect, investigate, and prevent fraud, wire fraud, money laundering, and other unlawful activity, and to screen against sanctions and watch lists;
  • comply with applicable law, licensing requirements, examinations, audits, subpoenas, court orders, and lawful requests from regulators and law enforcement;
  • establish, exercise, or defend legal claims;
  • operate, secure, troubleshoot, analyze, and improve the Site and our products and services; and
  • market our lending programs to real estate investors, brokers, and business contacts, including through email, direct mail, and online advertising, subject to Section 8.

We do not use loan application information to make automated decisions that produce legal or similarly significant effects without human involvement. Underwriting decisions at Red Rock Capital are made by our credit personnel.

5. Credit Reports & Background Checks

As part of underwriting a business-purpose loan, we obtain consumer reports (credit reports) and background information on individual guarantors and principals from consumer reporting agencies, in accordance with the federal Fair Credit Reporting Act (“FCRA”) and applicable state law. By submitting an application or guaranty, or by authorizing us in writing, each guarantor and principal authorizes Red Rock Capital and its assigns, servicers, and prospective loan purchasers to obtain and re-obtain such reports in connection with the origination, review, servicing, collection, sale, or enforcement of the loan.

If we take adverse action based in whole or in part on information in a consumer report, we will provide the notices required by the FCRA. If you believe information in your credit file is inaccurate, you should contact the consumer reporting agency that furnished the report — we cannot correct information held by a credit bureau.

6. How We Disclose Information

We do not sell personal information for money. We disclose information as follows:

6.1 Transaction and lending partners

Brokers and referral partners.
If a broker or referral source brought you to us, we share loan status and file information with that party as necessary to process the transaction and to calculate compensation. If you contact us directly and we refer you to a broker or another lender better suited to your scenario, we will share your inquiry information with that party for that purpose.

Capital partners, warehouse lenders, table funders, investors, and loan purchasers.
We disclose loan files and related information to entities that fund, participate in, purchase, pledge, or conduct due diligence on our loans, and to their advisors, custodians, and rating or audit firms. Where a loan is sold or transferred, the acquiring party’s own privacy practices will apply to its use of the information.

Servicers and sub-servicers,
for boarding, billing, draw administration, collections, and default management.

Settlement service providers,
including title and escrow companies, appraisers and appraisal management companies, inspectors, insurance agents and carriers, surveyors, recording services, and closing attorneys.

6.2 Service providers

We use vendors that process information on our behalf and under contract, including loan origination and CRM systems, document storage and e-signature platforms, email and marketing platforms, telephony providers, payment and ACH processors, accounting and tax professionals, IT and cybersecurity providers, identity and fraud verification services, and website analytics and hosting providers. These vendors are permitted to use the information only to perform services for us.

6.3 Advertising partners

We work with advertising and analytics platforms — including Google and Meta — that place cookies, pixels, or similar technologies on the Site. Through these technologies, identifiers and browsing activity may be made available to those platforms and used to measure campaigns and to show you ads for Red Rock Capital on other sites and apps. Under certain state privacy laws, this kind of disclosure is treated as a “sale” or as “sharing” for cross-context behavioral advertising, even though no money changes hands. See Sections 7 and 10 for how to opt out.

Mobile numbers and SMS consent data are never included.
We do not disclose mobile telephone numbers, text-message opt-in data, or consent records to advertising partners, data brokers, affiliates, or any other third party for their own marketing purposes. See Section 9.

6.4 Legal, safety, and corporate transactions

  • To regulators, licensing authorities, examiners, auditors, courts, and law enforcement, in response to subpoenas, court orders, examinations, or other lawful requests, or where we believe disclosure is required or permitted by law;
  • To attorneys, accountants, insurers, and other professional advisors;
  • Where necessary to investigate suspected fraud or wire fraud, protect the rights, property, or safety of Red Rock Capital, our clients, or others, or enforce our agreements; and
  • In connection with a merger, acquisition, financing, reorganization, sale of assets, or similar transaction involving all or part of our business, including during diligence.

6.5 With your direction

We disclose information to any other party you direct us to, such as your attorney, CPA, business partner, contractor, or 1031 or self-directed IRA custodian.

7. Cookies, Analytics & Advertising

The Site uses cookies, web beacons, pixels, tags, local storage, and similar technologies for the following purposes:

Category What it does
Strictly necessary Enables core Site functions such as page delivery, security, load balancing, and form submission. These cannot be turned off through our Site.
Performance & analytics Helps us understand how visitors find and use the Site so we can improve it — for example, Google Analytics.
Advertising & retargeting Used by us and our advertising partners — including Google Ads and the Meta pixel — to measure campaign performance and to deliver Red Rock Capital ads to you on other websites, apps, and social platforms.

Managing cookies. Most browsers let you refuse or delete cookies through their settings. Blocking cookies may affect how parts of the Site function. You can also opt out of certain interest-based advertising through the tools at optout.aboutads.info (DAA), optout.networkadvertising.org (NAI), and, for Google specifically, adssettings.google.com. These opt-outs are browser- and device-specific and must be reset if you clear cookies or use a different device.

Global Privacy Control.
Where required by law, we treat an opt-out preference signal such as Global Privacy Control (GPC) transmitted by your browser as a valid request to opt out of the sale or sharing of personal information, and of targeted advertising, for that browser or device. We do not otherwise respond to browser “Do Not Track” signals, as no common standard for them has been adopted.

8. Your Choices

Email.
You can unsubscribe from our marketing emails using the link in any such email, or by emailing us at the address in Section 17. We may still send you transactional and servicing messages about a loan or application, which are not marketing.

Telephone and text.
You may ask to be placed on our internal do-not-call list by contacting us, and you may stop text messages at any time as described in Section 9.

Advertising.
See Section 7 for interest-based advertising opt-outs.

Declining to provide information.
You may decline to provide information, but we may be unable to evaluate a scenario, issue a term sheet, or close a loan without it.

9. Text Messaging (SMS/MMS)

Red Rock Capital may send text messages to mobile numbers provided to us by borrowers, guarantors, brokers, and business contacts. This section describes our SMS program.

No sharing of mobile data

We do not sell, rent, or share mobile telephone numbers, SMS opt-in data, or consent records with any third party or affiliate for their own marketing or promotional purposes. Mobile opt-in and consent information is used solely to operate our own messaging program, and is disclosed only to the vendors that deliver messages on our behalf (such as our messaging platform and telecommunications carriers) and only for that purpose. This information is also excluded from any disclosure to advertising partners described in Section 6.3.

9.1 What we send

Transactional and servicing messages — loan status and approval updates, requests for missing documents or conditions, appraisal and inspection scheduling, draw request and disbursement notices, closing and funding coordination, wire confirmation callbacks, payment reminders, and payoff or maturity notices.

Conversational messages — replies from our loan officers and processors to questions you send us.

Marketing messages — program updates, rate and product announcements, and event invitations, sent only to recipients who have given prior express written consent to receive them.

9.2 How consent is obtained

We send text messages only where we have your consent, which you may give by checking the consent box on a form on the Site, by providing your mobile number on a loan application or broker registration and agreeing to be contacted by text, by texting us first, or by telling one of our representatives that you agree to receive texts. Consent to receive marketing texts is obtained separately and is never a condition of applying for, receiving, or the terms of any loan.

If a broker, partner, or other person provides us with your mobile number, we rely on their representation that they have obtained any consent required to contact you. Please tell us if you believe your number was provided to us in error.

9.3 Message frequency, rates, and delivery

Message frequency varies based on the status and activity of your loan, application, or account.

Message and data rates may apply. Your mobile carrier’s standard rates apply to all messages you send and receive; we do not charge for the messages themselves.

Mobile carriers are not liable for delayed or undelivered messages. Delivery is not guaranteed, and you should not rely on text messages for time-sensitive matters.

Our messaging program is supported on major U.S. carriers. Carrier participation and features may change.

9.4 How to stop messages or get help

To stop:
reply STOP to any message from us. You may also reply QUIT, END, CANCEL, UNSUBSCRIBE, OPT OUT, or REVOKE. We will send a single confirmation message and then stop sending texts to that number. You may also revoke consent by any other reasonable method — by calling us, emailing us, or telling one of our representatives — and we will honor your request within 10 business days, or sooner where required.

To get help: reply HELP to any message, call us at
719-900-5400,
or email
sales@fundwithredrock.com.

Opting out of marketing texts does not automatically stop transactional messages about an active loan or application, and opting out of text messages does not stop email or telephone communications. Tell us if you want to opt out of more than one channel, and we will honor that request. If you opt out and later want to resume messages, you may text START or contact us to opt back in.

9.5 Please do not text sensitive information

Text messaging is not a secure channel. Do not send Social Security numbers, account or routing numbers, credentials, or images of identification documents by text. Ask us for a secure upload link instead. As noted in Section 13, we will never send you new or changed wire instructions by text or unsecured email.

9.6 Reassigned and shared numbers

If you give up or change a mobile number you have provided to us, please notify us promptly so we do not text a number that has been reassigned to someone else. We check numbers against reassigned-number resources where appropriate.

10. State Privacy Rights

Depending on where you live, state law may give you rights over personal information we hold about you. Note that several state privacy laws — including Colorado’s — apply only to individuals acting in an individual or household context and do not cover information about individuals acting in a commercial or employment context. Because our loans are business-purpose, much of the information in a loan file falls outside those laws. California law is broader and reaches business-to-business contacts. We honor verified requests in accordance with applicable law.

10.1 Rights that may be available to you

Know / access.
Confirm whether we process your personal information and obtain a copy or a description of the categories collected, used, disclosed, and sold or shared.

Correct.
Ask us to correct inaccurate personal information.

Delete.
Ask us to delete personal information, subject to exceptions — including information we must retain for loan files, servicing, legal, regulatory, audit, tax, and recordkeeping purposes, and to detect or prevent fraud.

Portability.
Obtain a copy in a portable, readily usable format where technically feasible.

Opt out of targeted advertising and of the sale or sharing of personal information.

Limit use of sensitive personal information, where applicable.

Non-discrimination.
We will not deny services, charge different prices, or provide a different level of quality because you exercised a privacy right.

Appeal.
If we decline your request, you may appeal by replying to our decision or contacting us at the address in Section 17. We will respond within the period required by your state’s law. In Colorado, if your appeal is denied you may contact the Colorado Attorney General at
coag.gov/file-complaint.

These rights are currently provided in some form under the laws of California, Colorado, Connecticut, Virginia, Utah, Texas, Oregon, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island, and Arkansas, among others. The specific rights and exceptions vary by state.

10.2 How to submit a request

Submit requests by email to
privacy@fundwithredrock.com,
by phone at
719-900-5400,
or by mail to the address in Section 17. Please state the right you are exercising and the state you reside in.

Verification.
To protect your information, we will take reasonable steps to verify your identity before acting on a request — typically by matching information you provide against our records, and in some cases by requesting additional documentation. We will not use verification information for any other purpose.

Authorized agents.
An authorized agent may submit a request on your behalf with written permission signed by you, or a valid power of attorney. We may still contact you directly to confirm the agent’s authority and to verify your identity.

Timing.
We will acknowledge and respond within the timeframe required by applicable law, generally within 45 days, with an extension where permitted.

11. Additional California Disclosures

This section supplements the rest of this Policy and applies to California residents under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”). It applies to the extent the CCPA covers us and the information at issue.

11.1 Categories collected in the past 12 months

CCPA category Examples we may collect Disclosed for a business purpose to Sold or shared?
Identifiers Name, postal address, email, phone, IP address, online identifiers, SSN/ITIN, driver’s license or passport number Brokers and referral partners; capital partners and loan purchasers; servicers; settlement service providers; service providers; advisors; regulators No, except online identifiers as noted below
Customer records information (Cal. Civ. Code § 1798.80) Signature, address, telephone, bank account and financial account numbers, credit and debit card numbers, insurance and employment information Same as above No
Commercial information Loan products requested, transaction and property records, project history, payment history Same as above No
Internet or network activity Pages viewed, referring URLs, clicks, session and device data Analytics and advertising providers; hosting and security providers Yes — shared for cross-context behavioral advertising
Geolocation data General location inferred from IP address; property addresses Analytics and advertising providers; transaction partners Yes — general IP-based location, via advertising technologies
Professional or employment information Occupation, business role, ownership interests, real estate investing experience Transaction and lending partners; service providers No
Audio and electronic information Emails, form submissions, and call recordings where applicable Service providers; advisors; regulators No
Sensitive personal information SSN/ITIN, driver’s license or state ID number, financial account numbers and access credentials, and account log-in information Transaction and lending partners; service providers; regulators No
Inferences Assessments of borrower experience, credit profile, and product fit Transaction and lending partners; service providers No

Sensitive personal information.
We use and disclose sensitive personal information only for the purposes permitted under CCPA § 1798.121(a) and its regulations — such as verifying identity, underwriting and servicing a loan, preventing fraud, and complying with law. We do not use or disclose it to infer characteristics about you, and we do not sell it. Accordingly, the right to limit its use does not apply, but you may still contact us with questions.

Retention.
We retain each category for the periods described in Section 12.

11.2 Do Not Sell or Share My Personal Information

We do not sell personal information for monetary consideration and we do not knowingly sell or share the personal information of consumers under 16 years of age. However, our use of advertising and analytics technologies may constitute “sharing” for cross-context behavioral advertising, and in some cases a “sale,” under the CCPA. To opt out:

  • Enable Global Privacy Control in your browser or extension, which we honor automatically for that browser; or
  • Email

    privacy@fundwithredrock.com

    with the subject line “Do Not Sell or Share.”

11.3 Shine the Light

California Civil Code § 1798.83 permits California residents to request information about disclosures of personal information to third parties for their direct marketing purposes. We do not make such disclosures.

12. Data Retention

We keep information for as long as needed for the purposes described in this Policy and to meet our legal, regulatory, tax, audit, investor, and recordkeeping obligations. In general:

  • Website and analytics data:
    typically up to 26 months.
  • Inquiries and scenarios that do not become loans:
    typically up to 3 years.
  • Loan files, closing documents, and servicing records:
    for the life of the loan and generally at least 5 to 7 years after payoff, release, or final disposition, or longer where a longer period is required by law, by a loan purchaser or investor, or by an unresolved claim or investigation.
  • Marketing contact records:
    until you unsubscribe or ask us to remove you, plus a suppression record so we can honor your request.

When information is no longer needed, we delete it or de-identify it using reasonable measures.

13. Information Security

We maintain administrative, technical, and physical safeguards designed to protect information against unauthorized access, use, alteration, disclosure, and destruction. These include access controls and least-privilege permissions, encryption of data in transit, secure document portals for the exchange of sensitive files, vendor due diligence and contractual confidentiality obligations, employee training, and monitoring. We also maintain an information security program consistent with applicable law, including the FTC Safeguards Rule where it applies to us.

Wire fraud warning

Wire fraud targeting real estate transactions is common and costly. Red Rock Capital will never send you new or changed wire instructions by unsecured email. Always call a known, verified phone number for our office or your title or escrow company to confirm wire instructions verbally before sending funds. Do not rely on contact information contained in an email requesting a wire.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security. Please do not send Social Security numbers, account numbers, or other sensitive information to us by unencrypted email — ask us for a secure upload link instead.

14. Children’s Privacy

The Site is intended for business and investment professionals and is not directed to children. We do not knowingly collect personal information from anyone under 16. If you believe a child has provided us information, contact us and we will delete it.

15. Third-Party Sites

The Site may link to third-party websites, calculators, application portals, or social media pages that we do not control. This Policy does not apply to those services. Review the privacy policy of any third-party site before providing information to it.

16. Changes to This Policy

We may update this Policy from time to time. When we do, we will revise the “Last updated” date above and post the new version on this page. Material changes will be identified more prominently where required by law. Your continued use of the Site or continued dealings with us after an update constitute acceptance of the revised Policy.

17. How to Contact Us

For questions about this Policy, to exercise a privacy right, or to request a copy of this Policy in an alternative accessible format:

Island View Mortgage, Inc. d/b/a Red Rock Capital

Attn: Privacy

6547 N Academy Blvd #402

Colorado Springs, CO 80918

Phone:

719-900-5400

Email:

privacy@fundwithredrock.com

General inquiries:

sales@fundwithredrock.com

Red Rock Capital provides loans for business, commercial, and investment purposes only, secured by non-owner-occupied

Red Rock Capital provides loans for business, commercial, and investment purposes only, secured by non-owner-occupied residential and other investment real estate. Loans are not available for personal, family, or household purposes. Not all applicants will qualify. Terms and availability are subject to underwriting, credit approval, and applicable state licensing requirements.