Privacy Policy

1) Scope, Controller, and Contact Details

Marshall Capital Group, LLC dba Vitality Finance ("Vitality Finance," "we," "our," or "us") is the business responsible for this website and the processing activities described in this Privacy Policy.

This notice applies when you visit our website, use our portal features, submit financing or employment forms, communicate with us by phone, email, or SMS, or otherwise interact with our business.

2) Categories of Information We Collect

Depending on your interaction with us, we may collect the following categories of information:

• ✓Identifiers and contact details: Full name, business name, postal address, email, phone number, and similar account/contact information.
• ✓Commercial and business records: Financing request details, equipment information, lender communications, and transaction administration records.
• ✓Financial and application records: Information included in financing applications, supporting documentation, guarantor/applicant details, and verification materials.
• ✓Employment application records: Application answers, work history, references, uploaded resumes/cover letters, and signature/attestation data.
• ✓Internet/network activity data: IP address, browser/device signals, session IDs, pages viewed, referral source, click path, and UTM/campaign parameters.
• ✓Communications and consent records: Email/SMS preference data, message logs, timestamped opt-in and opt-out records, and support interactions.
• ✓Inferences and scoring data: Lead-intent and engagement scoring generated from website behavior and submitted interactions.
• ✓Sensitive information where applicable: Data elements that may be treated as sensitive under certain laws, for example SSN fragments, financial account context, or government identifiers submitted through application workflows.

3) Sources of Information

We collect personal information from:

• ✓You directly through forms, applications, uploads, calls, SMS, and email.
• ✓Your authorized representatives, references, or business counterparties.
• ✓Service providers that help us host, secure, and operate our systems.
• ✓Campaign and referral data from tagged links and traffic sources.
• ✓Third-party verification and enrichment sources, where permitted by law.

4) How and Why We Use Information

We use personal information to:

• ✓Review, process, and administer financing requests and related servicing workflows.
• ✓Process employment applications and hiring-related workflows.
• ✓Authenticate users, secure accounts, and operate internal portal controls.
• ✓Respond to inquiries, deliver service communications, and provide customer support.
• ✓Deliver consented marketing communications by email/SMS.
• ✓Measure site performance, attribution, and user journey analytics.
• ✓Identify high-intent business opportunities using lead-scoring and company enrichment.
• ✓Prevent fraud, abuse, security incidents, and unauthorized access.
• ✓Meet legal, tax, accounting, compliance, and recordkeeping obligations.

5) Lawful Bases (EEA/UK and Similar Jurisdictions)

Where required by applicable law, we rely on one or more lawful bases: consent, performance of a contract or pre-contract steps, compliance with legal obligations, and legitimate interests such as security, fraud prevention, service analytics, and operational improvement.

6) Financial Privacy and Security Program Commitments

As a financial-services business, we maintain administrative, technical, and physical safeguards designed to protect nonpublic personal information and other sensitive records.

Controls include role-based access controls, secure transport, hardened storage, activity logging, vendor due diligence, and incident response procedures.

We maintain written policies and technical safeguards intended to align with applicable U.S. financial-privacy and security obligations. No method of transmission or storage is guaranteed to be completely secure.

7) When We Disclose Information

We may disclose personal information to the following categories of recipients:

• ✓Hosting, infrastructure, security, communications, and analytics service providers.
• ✓Lenders, participants, and assigns involved in evaluating or administering financing.
• ✓Professional advisors, including legal, accounting, tax, compliance, and insurance advisors.
• ✓Regulators, law enforcement, courts, and authorities where legally required.
• ✓Successors or counterparties in a merger, acquisition, financing, or asset transaction.

8) Cookies, Consent Signals, and Similar Technologies

We use cookies and similar technologies for security, authentication, site reliability, analytics, and campaign attribution. We capture and honor your consent and preference selections as required by applicable law.

• ✓You can adjust browser-level cookie settings at any time.
• ✓Where required, we honor valid browser-based opt-out preference signals, including Global Privacy Control, for the browser/device context from which the signal is sent.
• ✓Essential cookies used for security and authentication may remain active because they are necessary to provide requested services.

9) Analytics, Visitor Intelligence, and Company Enrichment

We use first-party event tracking to measure page views, sessions, referral source, UTMs, device type, returning-visitor activity, and conversion paths. When a visitor identifies themselves, for example through form submission, chat intake, booking flow, or tagged campaign links, we may associate event history with known records.

• ✓We may use enrichment providers to infer company-level context for anonymous B2B sessions where legally permitted.
• ✓We apply behavior-based scoring to prioritize follow-up, for example repeated visits, high-intent page activity, form starts, and form completions.
• ✓Access to visitor-intelligence dashboards is restricted by internal role permissions, MFA, and audit logging controls.

10) Email and SMS Messaging; Consent, Opt-Out, and Records

We send transactional and, where permitted, marketing communications by email and SMS. We maintain suppression and consent records to document your communication preferences.

• ✓SMS Opt-In Language: "I agree to receive SMS communications from Marshall Capital Group, LLC dba Vitality Finance. Message frequency may vary. Standard rates may apply. Text STOP to opt-out."
• ✓SMS Help/Stop: Reply HELP for assistance or STOP to opt out. Opt-out requests are applied as soon as reasonably practicable.
• ✓Email Marketing Opt-Out: Click the unsubscribe link in marketing emails. We process unsubscribe requests within legally required timelines.
• ✓Regulatory Alignment: Our messaging workflows are designed to align with applicable requirements for commercial email and text outreach, including unsubscribe/opt-out handling and consent controls.
• ✓No Forced Consent: Consent to receive marketing SMS/email is not required to obtain financing services.
• ✓Consent Evidence: We may store consent and opt-out metadata such as timestamp, source page/form, and campaign context for compliance records.
• ✓Mobile Data Restriction: Mobile opt-in and consent data is not sold to third parties for their own independent marketing use.

11) Credit Application and Employment Application Processing

Credit and employment forms can include regulated or sensitive data. We process this information only for legitimate business purposes, including underwriting, verification, hiring, compliance, fraud prevention, legal recordkeeping, and responding to lawful requests.

Uploaded documents are handled using restricted-access storage and transmission controls. Application records may be converted into internal PDF records and routed through approved communication channels to authorized personnel.

12) Data Retention and Deletion

We retain data only as long as needed for disclosed purposes and to satisfy legal, accounting, regulatory, dispute, and enforcement obligations. Retention periods vary by data type, contract status, and legal requirements. At end of retention, records are deleted, de-identified, or securely archived.

We maintain suppression records for communication opt-outs to ensure future compliance with your preferences.

13) Your U.S. Privacy Rights (Including California)

Depending on where you live, you may have rights to know/access, correct, delete, and obtain a portable copy of your personal information, and to opt out of certain disclosures, including sale/sharing where defined by law. You may also have rights to limit use/disclosure of sensitive personal information and to appeal certain decisions.

• ✓Submit requests by emailing finance@vitalitylend.com or calling (361) 208-2501.
• ✓We verify requests before disclosure/deletion where legally required.
• ✓Authorized agents may submit requests where permitted by law.
• ✓We do not discriminate for exercising valid privacy rights.
• ✓Nevada residents may request to opt out of certain covered sale activities under applicable Nevada law.

14) EEA/UK and International Rights

If GDPR/UK GDPR applies, you may request access, correction, deletion, restriction, objection, and data portability, and may withdraw consent where consent is the lawful basis. You may also lodge a complaint with your local supervisory authority.

If we transfer personal data across borders, we use legally recognized safeguards appropriate to the transfer context.

15) Automated Processing and Profiling

We use automated rules and scoring signals for lead prioritization and internal workflow routing. Material decisions involving lending, employment, or legal rights are not made solely on anonymous web analytics signals without human review in the corresponding process.

16) Security Incident Response

We maintain controls for incident detection, containment, and response, including escalation processes and forensic review procedures. Where required by law, we provide notices to regulators and/or affected individuals within applicable timelines.

17) Children's Privacy

Our services are intended for business and professional users and are not directed to children under 13. We do not knowingly collect personal information from children under 13.

18) Third-Party Websites and Services

Our site may link to third-party websites or platforms. Their privacy and security practices are governed by their own policies and terms, not this Privacy Policy.

19) Changes to This Privacy Policy

We may revise this Privacy Policy to reflect business, legal, or technical changes. If we make material changes, we will update the "Last Updated" date and post the revised version on this page.

20) How to Contact Us or Submit Privacy Requests

Questions about privacy, data rights, marketing consent, or this policy can be sent to: