⚑ LEGAL REVIEW REQUIRED. This is a structural template only. Every section below contains placeholder language pending review by counsel. Final policy must be reviewed against: CA DFPI requirements, GLBA (Gramm-Leach-Bliley Act privacy notice rules for financial institutions), CCPA / CPRA (CA consumer privacy), TCPA / CTIA SMS rules, state-level money transmission / lending licensee privacy obligations, and applicable cookie/tracking laws.
Effective Date: [CONFIRM] · Last Updated: [CONFIRM] · Version: [CONFIRM]
1. Scope & Applicability
This Privacy Policy applies to information collected by FJM Management, LLC and FJM Capital, Inc., each doing business as First Bridge Lending, and their affiliated lending entities (collectively, "First Bridge," "we," "us"), in connection with:
- Visitors to firstbridgelending.com and related properties
- Prospective and current borrowers, brokers, guarantors, and signatories
- Loan applicants and inquiries submitted through our website, by phone, by email, or via partner channels
[CONFIRM] Exact list of legal entities covered; whether policy covers servicing-only customers; whether it covers third-party investor / fund LP relationships.
2. Information We Collect
2.1 Information you provide directly
- Contact information (name, email, phone, mailing address)
- Property information (address, type, value, lien status)
- Loan request information (amount, purpose, target close date, use of proceeds)
- Financial information necessary to evaluate creditworthiness
- Identification documents required by law for KYC / OFAC screening
- Communications you send to us
2.2 Information collected automatically
- Device, browser, IP address, and approximate location
- Pages visited, referring URL, session duration, interactions
- Cookies and similar technologies (see §6)
2.3 Information from third parties
- Credit reporting agencies (where applicable and authorized)
- Public records, title companies, appraisers, property data providers
- Broker / referral partners introducing your transaction
- Identity verification and fraud-prevention services
[CONFIRM] Specific data categories collected; whether biometric, geolocation precision, or any "sensitive personal information" (CCPA) categories apply; specific third-party data sources used.
3. How We Use Information
We use information to:
- Evaluate loan inquiries and underwrite loan requests
- Originate, fund, and service loans
- Comply with legal, regulatory, and licensing obligations (DFPI, DRE, NMLS, OFAC, BSA/AML, etc.)
- Communicate with applicants, borrowers, brokers, and counterparties
- Protect against fraud, unauthorized access, and misuse of our services
- Operate, improve, and secure our website and infrastructure
- Send transactional communications and, with consent, marketing communications
4. How We Share Information
We share information only as needed and with appropriate safeguards. Categories of recipients include:
- Affiliated lending entities listed in our footer disclosures
- Service providers (title, appraisal, escrow, doc-prep, e-signature, hosting, analytics)
- Regulators and authorities as required by law or subpoena
- Successors in interest in the event of a corporate transaction
- Loan participants, assignees, or servicers in connection with the loan
We do not sell personal information for monetary consideration. [CONFIRM whether any "sharing" for cross-context behavioral advertising under CPRA applies.]
5. SMS & Telephone Communications
If you opt in to SMS, you may receive marketing and/or transactional messages from First Bridge Lending.
- Marketing SMS: Message frequency varies. Message and data rates may apply. Reply HELP for help, STOP to opt out.
- Transactional SMS: Account notifications and 2FA. Message frequency may vary. Message and data rates may apply. Reply HELP for help or STOP to opt out.
- Consent to receive SMS is not a condition of any purchase or loan.
- Mobile information will not be shared with third parties for marketing/promotional purposes. [CONFIRM exact carrier-approved disclosure language].
6. Cookies & Tracking Technologies
We use first-party and third-party cookies to operate the site, remember preferences, measure usage, and (where applicable) deliver advertising. You can manage cookies through your browser settings.
[CONFIRM] Final cookie inventory (analytics, advertising, session, preferences); whether a cookie banner / consent management platform is required; CCPA "Do Not Sell or Share" link requirements.
7. Data Retention
We retain information for as long as necessary to fulfill the purposes described in this Policy, satisfy legal, accounting, lending, and regulatory recordkeeping obligations, and resolve disputes. [CONFIRM specific retention schedules — typically 7+ years for loan files under federal and state law.]
8. Security
We maintain administrative, technical, and physical safeguards intended to protect information against unauthorized access, alteration, disclosure, or destruction. No system is perfectly secure; we encourage you to use strong, unique passwords and to notify us promptly of suspected unauthorized activity.
9. California Privacy Rights (CCPA / CPRA)
California residents have the right to:
- Know what personal information we collect, use, disclose, and share
- Request a copy of personal information we have collected about you
- Request deletion of personal information (subject to legal exceptions)
- Correct inaccurate personal information
- Opt out of "sale" or "sharing" of personal information (if applicable)
- Limit use of sensitive personal information (if applicable)
- Non-discrimination for exercising privacy rights
To exercise a right, contact us using the details below or via [CONFIRM intake URL or email]. We will verify your request before responding.
10. GLBA Financial Privacy Notice
As a financial institution, First Bridge is subject to the Gramm-Leach-Bliley Act. We provide a separate GLBA Privacy Notice describing the categories of nonpublic personal information we collect and share, and your right to limit certain sharing.
[CONFIRM] Whether a separate GLBA notice exists; cadence of delivery (initial & annual); whether any "opt-out" sharing occurs; exact text of model GLBA notice.
11. Third-Party Sites & Services
Our site may link to third-party sites or embed third-party services. We are not responsible for the privacy practices of those parties. Review the privacy notices of any third-party site or service you use.
12. Children's Privacy
Our services are not directed to children under 13 (or under 16 where applicable). We do not knowingly collect personal information from children. If you believe a child has provided us information, contact us so we can take appropriate action.
13. Changes to this Policy
We may update this Policy from time to time. Material changes will be reflected by updating the "Last Updated" date and, where required, by additional notice.
Questions about this Policy or our privacy practices:
First Bridge Lending — Privacy Office
5341 Old Redwood Highway, Suite 200
Petaluma, CA 94954
Email & phone: [CONFIRM]