This Privacy Policy (“Policy”) explains how Manna Capital Partners, LLC (“Company,” “we,” “us,” or “our”) collects, uses, shares, and protects personal information obtained through our websites, including member portals and any other site that links to this Policy (collectively, the “Sites”).

We may update this Policy from time to time to reflect changes in our practices. Any updates will become effective upon posting to the Sites.

By using the Sites, you agree to comply with our Terms of Service.

If you enter into a separate agreement with the Company, including a loan application or service contract, the terms of that agreement will govern the collection and use of information to the extent of any conflict with this Policy.

1. Collection of Personal Information

This section outlines the categories of personal information we collect and the categories of third parties with whom such information may be shared.

Prospective Customers: We may collect demographic and interest-based information for marketing purposes from third-party sources, including lead providers and data brokers.

All Site Users ("Users"): We may collect device, usage, activity, and approximate location data for purposes such as security, system administration, analytics, marketing, and improving the Sites. This information may be collected through analytics providers and other third-party tools that track user interaction with the Sites.

Users Interested in Our Products or Services: We may collect behavioral, demographic, and interest-based data derived from user activity on the Sites for marketing and analytical purposes. This information may be processed or stored by third-party analytics and advertising providers.

Applicants for Financial Products or Services (Including Mortgages): We may collect personal, financial, and business-related information, including contact details, account credentials, application data, guarantor information, residency details, financial statements, banking information, credit data, and identification documents. This information is used to evaluate eligibility, verify identity, and provide customer support and marketing. It may be collected directly from you, from authorized representatives, and from third parties such as credit bureaus, consumer reporting agencies, and other financial institutions, and may be shared with such entities for verification and credit-related purposes.

Users Paying Appraisal Deposits: We collect transaction and payment information through third-party payment processors to confirm and process deposit payments.

Users Submitting Feedback or Communications (Including Live Chat and Social Media): We may collect names, contact information, and message content to respond to inquiries, improve services, and for marketing purposes. This information may be shared with service providers such as live chat platforms and social media companies.

2. Disclosure of Personal Information

In addition to the disclosures described above, we may share your personal information with the following categories of recipients:  

• Employees and Professional Advisors. We may disclose personal information to our employees and professional advisors, including attorneys, accountants, financial advisors, and consultants, for purposes of providing services to the Company.

• Processors/service providers. We may share personal information with third-party service providers that perform business, technical, administrative, or operational services on our behalf, such as payment processing, data storage, billing, marketing support, and quality assurance. These providers are contractually required to use personal information only as necessary to perform services for us and as permitted by law. 

• Legal and Regulatory Disclosures. We may disclose personal information to courts, government authorities, regulators, law enforcement agencies, or other parties when required to do so by law or legal process. 

• Affiliates. We may share personal information with our affiliated entities for internal business purposes. 

• Successors. We may disclose personal information in connection with a merger, acquisition, sale of assets, financing, or other transfer of all or part of our business to a successor or potential successor entity.

We may also share personal information with third parties when you request or authorize such disclosure.

3. Children's Information

The Sites are not intended for individuals under the age of 18. We do not knowingly collect, use, or disclose personal information from anyone under 18 years of age. If a parent or legal guardian believes that a child under 18 has provided personal information without consent, they may contact us, and we will take reasonable steps to delete such information from our records.

4. Personal Information Security and Retention

We implement commercially reasonable technical and organizational safeguards designed to protect personal information against loss, misuse, and unauthorized access, disclosure, alteration, or destruction. In the event of a data breach involving your personal information, we will provide notice as required by applicable law.

No method of transmission over the internet or electronic storage system is completely secure, and we cannot guarantee absolute security of your information. Accordingly, you provide personal information at your own risk.

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, or as otherwise required by law. Retention periods are determined based on the following factors:

• Applicable legal and regulatory retention requirements

• Industry best practices

• Whether continued processing is reasonably necessary to achieve the intended purpose

• Potential risks to individual privacy from ongoing retention

• Applicable data protection or privacy impact assessments

• System design, operational, or technical limitations

• Costs associated with retention, storage, and deletion

5. Access from Outside the United States

If you access the Sites from outside the United States, please note that your personal information will be processed in the United States. Where applicable, any international transfers of personal information will be conducted in accordance with applicable law.

6. Use of Third-Party Analytics and Advertising Technologies

We use third-party tools to understand how users interact with the Sites, improve performance, and support marketing efforts.

6.1 Session Replay and User Experience. We use session replay and user experience analytics tools to record and analyze user interactions for purposes such as improving functionality and identifying technical issues.

• Sensitive fields are automatically masked or excluded from recordings, including Social Security numbers, passwords, bank account details, and government-issued identifiers

• Recordings are used for troubleshooting and product improvement purposes only

• Access to recordings is restricted to authorized personnel and service providers under confidentiality obligations.

6.2 Advertising and Marketing Analytics (Pixels and Server-to-Server Tools). We use tracking technologies, including pixels and server-to-server integrations, to measure advertising performance and improve marketing effectiveness.

• We may share hashed (de-identified) identifiers such as email address, phone number, name, or ZIP code with advertising partners

• Hashing is used to protect plain-text identifiers while enabling matching for advertising and conversion measurement

• Advertising partners are contractually required to maintain confidentiality and use data only for agreed purposes

• These tools may also support audience creation and retargeting based on site activity

Your Choices:
You may limit certain tracking and advertising activities through your third-party account settings. We may not respond to automated browser signals such as Global Privacy Control (GPC), but we provide opt-out options as described in Section 9.

6.3 Website Traffic Analytics. We use analytics providers to monitor site performance and usage trends.

• Data is generally aggregated or de-identified

• Information is used to understand usage patterns and improve the Sites

• It is not intended to individually profile users or borrowers

7. Third-Party Websites and Services

The Sites may contain links to or integrations with third-party websites and services that are not owned or controlled by the Company. This Policy does not apply to such third parties, and we are not responsible for their content or privacy practices. You should review the privacy policies of any third-party websites you visit.

Online Behavioral Advertising. We use third-party services to deliver interest-based advertising based on your activity across websites over time, including the Sites. These advertisements may appear on our Sites, other websites, or through email campaigns.

• We may use advertising platforms such as Google Ads to serve targeted advertisements

• These providers may collect or receive information about your visits to the Sites and other websites to personalize ads

• You may opt out of interest-based advertising through tools such as:

  • Google Ad Settings and Google Safety Center

  • National Advertising Initiative opt-out page

  • Digital Advertising Alliance opt-out tools

• Opting out will not eliminate all advertisements, only personalized or targeted ads

Google Analytics. We use Google Analytics and related tools to understand how users interact with the Sites and to improve performance. Google may collect and process information about your use of the Sites and provide aggregated reports and insights to us. We may also use additional Google Analytics features, including:

• Demographics and Interest Reporting (e.g., age range, gender, interests based on online behavior)

• Remarketing features to support advertising campaigns

• Google Display Network reporting on ad performance and impressions

For more information on how Google processes data, you may refer to Google’s Privacy Policy and related documentation. You may also install the Google Analytics Opt-out Browser Add-on, although this may not disable all analytics tools.

8. Corrections & Updates to Your Personal Information

You may request correction or updates to your personal information by contacting us using the contact details provided in the final section of this Policy. Certain information may also be updated directly through your account settings, where available.

9. E-mail and Text Messages

If you provide your email address, we may send you emails, including marketing communications. You may opt out of marketing emails by using the unsubscribe link included in the message or by contacting us at michael@mannacapitalgroup.com with “Unsubscribe” in the subject line. If you provide your mobile number, you agree to receive account-related text messages.

If you opt in to marketing text messages, you may also receive promotional communications. You may opt out of text messages at any time by replying “STOP.” Message and data rates may apply.

Opting out of marketing communications will not prevent you from receiving essential service-related communications, such as account notifications or transactional messages.