Privacy Policy

At Sienna Marketing & Consulting, Inc. (d/b/a Creative Capital Solutions) and its subsidiaries and affiliates (collectively, “Creative Capital Solutions,” “we,” “us,” or “ours”), we take seriously protecting the privacy of personal information. Creative Capital Solutions provides this Privacy Policy to its website visitors, users, and businesses that access services provided by or through Creative Capital Solutions. We encourage you to read this notice to understand our privacy practices.

When you use, access, or interact with a Creative Capital Solutions website (including all sub-sites) or other interface that links to this Privacy Policy, (collectively, “the site”) or otherwise apply for or use our business financial products and related services (together with the site, the “Services”), you are agreeing to our Privacy. Among other terms, you affirm that you are over the age of 18 and are fully able to form a binding, legal agreement with Creative Capital Solutions.

Creative Capital Solutions reserves the right at its sole discretion to change, modify, add, or remove portions of these terms, at any time. It is your responsibility to check these terms periodically for changes. Your continued use of the site following the posting of changes will mean that you accept and agree to the changes. As long as you comply with these terms, Creative Capital Solutions grants you a personal, non-exclusive, non-transferable, limited privilege to enter and use the site.

We are committed to protecting your personal information (i.e., information that identifies an individual, such as a name and email address) and have implemented controls to protect information that is furnished to us directly, as well as information that we may obtain, with authorization, from third party sources.

This Privacy Policy is designed to be accessible to consumers with disabilities and follows the Web Content Accessibility Guidelines – a recognized industry standard. Text elements are designed to be accessible and audible through voice assistant programs, such as JAWS, NVDA, and Orca. All graphic elements are designed to contain properly descriptive alternate text to assist disabled consumers with audio assist needs.

If you have any questions or complaints regarding our Privacy Policy, or if you need assistance in exercising any privacy choices under this Privacy Policy, please contact us at info@ccapsolution.com.

Site Security

As a condition of your use of the site, you agree that you will not take any action intended to: (i) access data that is not intended for you; (ii) invade the privacy of, obtain the identity of, or obtain any personal information about any customer or user of the site; (iii) probe, scan or test the vulnerability of the site or the Creative Capital Solutions network or breach security or authentication measures without proper authorization; (iv) attempt to interfere with service to any user, host or network or otherwise attempt to disrupt our business, including, without limitation, via means of submitting a virus to the site, overloading, “flooding,” “spamming,” “mail bombing” or “crashing;” or (v) send unsolicited mail, including promotions and/or advertising of products and services. Violations of system or network security may result in civil or criminal liability.

We take reasonable measures, including administrative, technical, and physical safeguards to protect your information from loss, misuse, unauthorized access, disclosure, alteration, and destruction. These security measures include firewalls, data encryption, physical access controls to our data centers, and information access authorization controls.

Personal Information We May Collect

In connection with our provision of Services, we collect business information, as well as your personal financial information. We collect most of this information during your enrollment and application process. We may gather additional information during your subsequent use of the site or when we communicate with you via telephone, email, or other means. As described below, we may collect additional information, with your authorization, from third parties.

Certain personal information must be supplied during the application processes in order to meet our legal obligations, verify your identity, facilitate determinations for credit eligibility, protect against fraud, and complete your transaction. The following categories of information may be collected:

Information Collected from Third Parties

In connection with an application, we will collect information from credit bureaus and other third parties to make determinations for financing eligibility, perform analyses, and assess risks related to your potential financing. If you are approved for financing, we also collect information throughout the life of our business relationship with you in order to assess risks associated with your financing and perform analyses.

• Basic consumer identifying information (name, account name, address, email, phone, date of birth) or similar identifiers.
• Basic business information (business name, address, email, URL, phone, structure, industry, ownership, date of incorporation).
• Credit score, credit history, and other creditworthiness and identity information.
• Bank account information.
• Financial, tax, and transactional information from third parties such as financial institutions, credit card processors, vendors, and publicly available sources.

Information Gathered Based on Your Activity on the Site

For all users, Creative Capital Solutions collects information about your visits to the site and the computer or device through which you access the site, such as your IP address, geographical location, operating system, browser type, referral source, time and length of visit, button clicks and/or page views, and your mobile device identifier (IDFA or AAID).

We use technologies such as but not limited to cookies, beacons, tags, and scripts, to analyze trends, administer the site, track users' movements around the site, and gather information about our user base.

We use cookies when you interact with the site to keep track of your personal session, help authenticate your account, and detect fraud. Cookies are also used to gather statistical data, such as which pages are frequently visited, and what is downloaded, as well as for marketing and advertising purposes. You can control the use of cookies within your web browser. However, if you reject cookies, your ability to use some features or areas of the site may be limited.

How We Use Your Information

We may use the information we collect to:

• Process your business's application and determine its qualification for financial products.
• Facilitate servicing and collections activities.
• Verify your identity, conduct appropriate diligence, and keep your information current.
• Provide customer support.
• Understand, personalize, and enhance your experience.
• Show advertisements for our products on third party sites.
• Measure and improve the performance and functionality of the site.
• Manage the security of the site.
• Compile data analytics reports to better understand you and improve the user experience.

How We Share Your Information

We will share your personal information with nonaffiliates and among affiliates only in the ways described in this Privacy Policy. By law, you are permitted to limit some types of sharing, but not others.

Co-Applicants / Co-Borrowers

We may share your information with your co-applicant / co-borrower in order to process your business application and as needed to provide our Services.

Third Party Service Providers

We rely on third party service providers to help us conduct our business. We may share any information we receive with such parties as is necessary for the provision of the Services.

Other Sources of Commercial Financing

In connection with your request for commercial financing, we may share your information with financial institutions, lenders, purchasers of accounts receivable, factoring companies, equipment finance or leasing companies, or other similar sources.

Your Consent

We may share your personal information with third parties at your direction or whenever you consent.

Legal Requests & Regulatory Requirements

We may also share information to comply with any applicable law, regulation, legal process or governmental request; for limiting fraud; or in connection with an audit or the sale of Creative Capital Solutions to a third party.

Important Privacy Choices

You may choose to stop receiving marketing emails by following the unsubscribe instructions included in those emails. You may also request that we do not call you for marketing-related purposes. Contact us at info@ccapsolution.com or (929) 604-0993. Opting out of marketing communications will not stop non-marketing emails and notifications related to our Services.

How We Use Cookies

Our website uses tracking technologies such as cookies to provide you with a high quality, fluid and personalized experience. We use Cookies to:

• Monitor applications
• Evaluate traffic patterns and behavior usage on our website
• Oversee search engine findings for advertisements
• Temporarily save your inputted data in case of server shut down
• Enhance your browsing experience, serve personalized ads or content, and analyze traffic
• Help you navigate efficiently and perform certain functions

You can choose to customize, enable or disable cookies but disabling some may affect your browsing experience. You may also block cookies through your internet browser settings.

Notice to California Residents (CPRA)

Effective January 1, 2023, the California Privacy Rights Act (“CPRA”) provides specific rights to California residents related to their “personal information.” This section enumerates the CPRA required disclosures and details those rights.

Right to Know / Right to Access

California residents have the right to request that we disclose what information we have collected, used, disclosed, or sold over the past 12 months.

Right to Delete

California residents have the right to request that we delete any personal information that we collected and retained, subject to certain exceptions.

Right to Opt-Out of Sale

Creative Capital Solutions does not and will not sell or otherwise share personal information of consumers.

Right to Non-Discrimination

We will not discriminate against you for exercising any of your CPRA rights.

Exercising Your CPRA Rights

Submit a verifiable consumer request by contacting us at info@ccapsolution.com or (929) 604-0993.

Changes to Privacy Policy

We may update this Privacy Policy from time to time. If the revised version includes a substantial change, we will provide a more prominent notice prior to the change becoming effective. Your continued use of the site shall constitute your acceptance of such updated Privacy Policy.