Legal

Privacy Policy

Last updated: June 5, 2026

This Privacy Policy explains how Cohort Capital Management LLC and its affiliates ("Cohort Capital," "we," "us") collect, use, share, and protect information in connection with our website at cohortfunding.com, our application process, and our financing and platform services (the "Services"). By using the Services, you agree to this Policy.

1. Who we are

The Services are provided by Cohort Capital Management LLC, 777 Brickell Avenue, Miami, FL 33131, together with its affiliates, including Cohort Capital Fund LP, Cohort Capital GP LLC, and Cohort Capital Technology Corporation. For questions about this Policy or to exercise your rights, contact team@cohortfunding.com.

2. Information we collect

Information you provide

When you contact us, apply for financing, or become a partner, we collect business and contact details (such as business name, website, entity type, and revenue), the personal information of owners and authorized representatives (such as name, email, phone, and government identification used for identity verification and know-your-business/know-your-customer checks), and any information you submit in your application or communications.

Connected-account and platform data

With your authorization, we access data from third-party sources you connect on a read-only basis to support underwriting, servicing, and monitoring. These may include commerce platforms (e.g., Shopify), advertising accounts (e.g., Meta, Google), payment processors (e.g., Stripe), and bank-data providers (e.g., Plaid). This data includes order, revenue, cohort, advertising-spend, contribution-margin, and settlement information. We do not use these connections to initiate payments, transfers, or charges.

Information collected automatically

When you use the Site, we and our analytics providers may collect device and usage information (such as IP address, browser type, pages viewed, and referring URLs) through cookies and similar technologies.

Information from third parties

We may receive information from data-enrichment, identity-verification, fraud-prevention, credit, and referral-partner sources to evaluate and service financing.

3. How we use information

To evaluate applications, underwrite, price, fund, and service financing;
To verify identity and ownership and to detect, prevent, and investigate fraud and misreporting;
To monitor funded cohorts and portfolio performance on an ongoing basis;
To operate, maintain, secure, and improve the Site, Services, and our underwriting models and platform — including using aggregated and de-identified data to improve analytics and model accuracy;
To communicate with you, respond to inquiries, and provide reporting; and
To comply with legal, regulatory, tax, and contractual obligations and to enforce our agreements.

4. How we share information

We do not sell your personal information. We share information only as follows:

Affiliates — with Cohort Capital Fund LP, Cohort Capital GP LLC, Cohort Capital Technology Corporation, and related vehicles, for the purposes described above;
Service providers — vendors that perform services for us (hosting, analytics, identity/KYB verification, data connectivity, document management) under confidentiality obligations;
Financing and capital partners — warehouse lenders, co-investors, and special-purpose vehicles in connection with funding, servicing, audit, or financing of receivables, typically on a need-to-know or aggregated basis;
Professional advisors — legal, accounting, and audit advisors;
Legal and regulatory — where required by law, regulation, legal process, or to protect rights, safety, and the integrity of the Services; and
Business transfers — in connection with a merger, financing, acquisition, or sale of assets.

5. Financial information and the GLBA

To the extent we are a "financial institution" handling "nonpublic personal information" of individuals under the Gramm-Leach-Bliley Act (GLBA), we handle that information consistent with applicable financial-privacy laws. Information governed by the GLBA may be exempt from certain rights provided under state consumer-privacy laws. Bank-linked data accessed through providers such as Plaid is also subject to that provider's privacy practices.

6. Cookies and analytics

We use essential cookies to operate the Site and analytics cookies to understand usage. You can control cookies through your browser settings. Where applicable, we honor recognized opt-out preference signals (such as Global Privacy Control) for sales or sharing of personal information; note that we do not sell personal information.

7. Data retention

We retain information for as long as needed to provide the Services, to satisfy legal, regulatory, audit, tax, and recordkeeping obligations, to resolve disputes, and to enforce our agreements, after which we delete or de-identify it.

8. Security

We maintain administrative, technical, and physical safeguards designed to protect information, including encryption in transit and access controls. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

9. Your privacy rights

Depending on your state of residence and applicable law (which may include the California Consumer Privacy Act as amended, the Florida Digital Bill of Rights, and the privacy laws of Virginia, Colorado, Connecticut, Utah, and other states), you may have rights to access, correct, delete, or obtain a portable copy of your personal information, and to opt out of "sale," "sharing," or targeted advertising. We do not sell personal information or use it for cross-context behavioral advertising. To exercise any right available to you, contact team@cohortfunding.com; we will verify your request and respond as required by applicable law, and we will not discriminate against you for exercising your rights. You may appeal a decision by replying to our response.

10. Children's privacy

The Services are intended for businesses and adults. We do not knowingly collect personal information from children under 13 (or under 16 where applicable).

11. U.S. processing

The Services are operated from, and information is processed in, the United States. If you access the Services from outside the U.S., you understand your information will be processed in the U.S.

12. Changes to this Policy

We may update this Policy from time to time. Changes are effective when posted, as indicated by the "Last updated" date. Your continued use of the Services constitutes acceptance of the updated Policy.

13. Contact

Cohort Capital Management LLC
777 Brickell Avenue, Miami, FL 33131
team@cohortfunding.com

In short

We collect business and owner information and read-only platform data to underwrite, fund, service, and monitor financing, and to improve our platform using aggregated, de-identified data. We do not sell your information and we never use connected accounts to move money. Financial information may be governed by the GLBA. Contact us any time to exercise your privacy rights.

See also our Terms of Use and Disclosures.