Privacy Policy

Declare Capital, LLC("Company," "we," "us," or "our"), a Georgia limited liability company doing business as MyBLOC™, operates the MyBLOC™ website and member portal at mybloc.cc. This Privacy Policy explains how we collect, use, disclose, store, and safeguard your information when you visit our website, create an account, or use our services.

BY ACCESSING OR USING THE MYBLOC™ PLATFORM, YOU CONSENT TO THE COLLECTION, USE, AND DISCLOSURE OF YOUR INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THIS POLICY, DO NOT USE THE SITE OR SERVICES.

This Privacy Policy is incorporated into and subject to our Terms of Service.

1. Information We Collect

1.1 Information You Provide Directly

When you create an account, complete your profile, or use our services, we collect:

• Full name, email address, and phone number
• Account login credentials (email and password)
• Business name, EIN (Employer Identification Number), and business address
• Business entity type, state of formation, and registration status
• Credit profile information you enter, including credit scores (TransUnion, Equifax, Experian), inquiry count, and credit utilization percentage
• Business credibility checklist completion status
• Application status, approvals, credit limits, and credit-building progress data
• Uploaded documents (e.g., credit reports)

1.2 Third-Party Credentials You Store

The portal offers an optional feature allowing you to store login credentials for third-party services (e.g., MyFreeScoreNow, Nav, Experian). By using this feature, you acknowledge that:

• You are voluntarily providing these credentials for your own convenience
• These credentials are stored in our database and encrypted at rest
• The Company does not use your third-party credentials to log into any service on your behalf
• The Company is not responsible for any unauthorized access to stored credentials
• You may delete stored credentials at any time through the portal

1.3 Information Collected Automatically

When you access our website, we automatically collect:

• IP address, browser type, and browser version
• Device type, operating system, and screen resolution
• Pages visited, time spent on pages, and navigation paths
• Referring website, search terms, and traffic source
• Date and time of access
• Click behavior and interaction data within the portal

1.4 Cookies & Tracking Technologies

We use the following tracking technologies:

• Essential Cookies: Required for authentication, session management, and portal functionality. These cannot be disabled while using the platform.
• Analytics Cookies: Used to understand how Members use the platform, which pages are most visited, and where improvements are needed. We may use third-party analytics tools (e.g., Google Analytics, Vercel Analytics).
• Affiliate Tracking: When you click "Apply Now" or similar links, cookies may be set by affiliate networks or lender partners to track referrals. These cookies are governed by the respective third party's privacy policy.

You can instruct your browser to refuse cookies or alert you when cookies are being sent. However, disabling essential cookies may prevent you from using certain features of the portal.

2. How We Use Your Information

We use the information we collect for the following purposes:

• Provide, operate, and maintain the MyBLOC™ member portal and services
• Create and manage your account
• Display personalized credit card recommendations and estimated approval odds
• Generate your Credit Snapshot and personalized recommendations
• Track your credit-building progress across application cycles
• Communicate with you about your account, program updates, cycle reminders, and support requests
• Send promotional materials and educational content (with opt-out available)
• Monitor for fraudulent activity and enforce our Terms of Service
• Improve our website, portal, algorithms, and services
• Comply with legal obligations and respond to lawful requests
• Generate anonymized, aggregated analytics that do not identify individual Members

3. How We Share Your Information

We may share your information in the following circumstances:

3.1 Affiliate & Lender Partners

When you click "Apply Now" or similar links on the platform, you are directed to a third-party lender or affiliate partner's website. At that point, any information you provide on the lender's website is governed by that lender's privacy policy, not ours. The Company does not transmit your personal information (credit scores, SSN, etc.) directly to lenders through the portal — you apply directly on their sites.

Affiliate networks may receive referral data (e.g., that a click originated from mybloc.cc) for the purpose of tracking and compensating referrals.

3.2 Service Providers

We use third-party service providers to help operate our platform, including:

• Supabase: Database hosting, authentication, and file storage
• Vercel: Website hosting and deployment
• Email Services: Transactional and marketing email delivery
• Analytics: Website usage analytics and performance monitoring

These providers are contractually obligated to use your information only as necessary to provide services to us and are required to maintain the confidentiality and security of your data.

3.3 Legal Requirements

We may disclose your information if required to do so by law or in response to:

• A subpoena, court order, or other legal process
• A request from law enforcement or government authority
• To protect the rights, property, or safety of the Company, our Members, or the public
• To investigate or prevent suspected fraud, security breaches, or violations of our Terms

3.4 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will notify you via email and/or prominent notice on the platform of any change in ownership or use of your personal information.

We do not sell, rent, or trade your personal information to unaffiliated third parties for their own marketing purposes.

4. Data Security

We implement industry-standard technical and organizational security measures to protect your personal information, including:

• Encryption of data in transit (TLS/SSL) and at rest
• Secure authentication through Supabase Auth with Row Level Security (RLS) policies
• Access controls limiting employee and contractor access to personal data on a need-to-know basis
• Regular monitoring for security vulnerabilities

However, no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. In the event of a data breach that affects your personal information, we will notify affected Members in accordance with applicable law.

5. Data Retention

We retain your personal information as follows:

• Active Accounts: We retain your data for as long as your account is active and as needed to provide you services.
• After Termination: Upon account termination or deletion, we will delete or anonymize your personal information within 90 days, except where retention is required by law or necessary to resolve disputes, enforce our agreements, or comply with legal obligations.
• Stored Credentials: Third-party login credentials stored in the portal are deleted immediately upon account termination or upon your request.
• Anonymized Data: We may retain anonymized, aggregated data indefinitely for analytics and improvement purposes. This data cannot be used to identify you.

6. Your Rights & Choices

Depending on your location, you may have the following rights regarding your personal information:

6.1 All Members

• Access: Request a copy of the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of your personal information and account
• Opt-Out: Unsubscribe from promotional and marketing communications at any time
• Credential Removal: Delete any stored third-party credentials through the portal at any time
• Data Portability: Request your data in a structured, commonly used format

6.2 California Residents (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA):

• The right to know what personal information we collect, use, disclose, and sell
• The right to delete personal information we have collected from you
• The right to opt out of the sale of personal information (we do not sell your data)
• The right to non-discrimination for exercising your privacy rights
• The right to correct inaccurate personal information
• The right to limit use and disclosure of sensitive personal information

To exercise any of these rights, contact us at info@mybloc.cc with the subject line "Privacy Rights Request." We will respond to verified requests within 45 days as required by law.

7. Third-Party Links & Services

Our platform contains links to third-party websites, including lender partner sites, credit monitoring services, and affiliate links. When you click on these links, you leave the MyBLOC™ platform and are subject to the third party's privacy policy and terms of service.

We are not responsible for the privacy practices, content, security, or data handling of any third-party website. We strongly encourage you to review the privacy policy of every third-party site you visit, especially before submitting personal or financial information.

The inclusion of a link on our platform does not imply endorsement of the third party's privacy practices.

8. Children's Privacy

The MyBLOC™ platform is not directed to individuals under the age of 18. We do not knowingly collect, solicit, or maintain personal information from anyone under 18 years of age. If we become aware that we have collected personal information from a child under 18, we will promptly delete that information. If you believe we have inadvertently collected information from a minor, please contact us immediately at info@mybloc.cc.

9. Do Not Track Signals

Some browsers offer a "Do Not Track" ("DNT") setting. There is currently no industry standard for how companies should respond to DNT signals. At this time, we do not respond to DNT signals. However, you may opt out of certain tracking through your browser's cookie settings.

10. International Users

The MyBLOC™ platform is operated in the United States and intended for use by U.S. residents. If you access the platform from outside the United States, you understand and consent to the transfer of your personal information to the United States, where data protection laws may differ from those in your country of residence.

11. Data Breach Notification

In the event of a data breach that compromises your personal information, we will:

• Notify affected Members via email within 72 hours of discovering the breach (or as required by applicable law)
• Provide details about what information was affected
• Describe the steps we are taking to address the breach and prevent future occurrences
• Provide guidance on steps you can take to protect yourself
• Report the breach to relevant authorities as required by law

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make changes:

• We will update the "Last updated" date at the top of this page
• For material changes, we will notify Members via email or prominent portal notification
• Continued use of the platform after changes are posted constitutes acceptance of the updated policy

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

BY USING MYBLOC™, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND CONSENT TO THE COLLECTION, USE, AND DISCLOSURE OF YOUR INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY.