Portal Privacy Notice (EN)

Version 2026-10-v1. Effective date: October 25, 2026.

Coinfish Capital Advisors LLC ("CCA", "we") runs the Secure Client Portal at portal.coinfishcapital.com.

What we collect: your name, business name, phone number, sign-in email, information about your request, and the documents you upload (for example tax returns, bank statements and financial statements). The forms do not ask for Social Security, account or card numbers, and they block them if you type one into a form field. Documents you upload, like tax returns, bank statements and IDs, may contain Social Security, account or ID numbers. You may black out numbers we don't need. We protect everything you upload with encryption.
Why we collect it: only to provide the advisory services you engaged us for, such as financing-readiness analysis and lender-package preparation. We are not a lender or broker and do not make credit decisions.
Who can see it: only Mark O. Brazier, LL.B., EDFP, President and CEO. We do not sell your information or share it for marketing. We share documents with a lender only when you direct us to in writing. Documents we send to a lender at your direction are then covered by that lender's own privacy policy. Deleting them here does not delete the lender's copy.
Service providers: Cloudflare (hosting, sign-in, encrypted storage). We may use a secure AI tool to help organize your documents. The tool does not keep your data or learn from it. Mark reviews everything it drafts before it is used. The portal itself stores the draft memo with your client file, for Mark only, and deletes it together with your files under the retention policy. Email notices to us contain no file contents.
Security: one-time passcode sign-in, encrypted storage, no public links, download links that expire within minutes, a log of every upload, view and deletion, and access limited to one administrator.
Where the Gramm-Leach-Bliley Act and the FTC Safeguards Rule apply to our services, we protect client and guarantor information under a written information security program, and we do not sell or share nonpublic personal information with outside companies for their own marketing.
Retention: files are deleted automatically 90 days after your engagement closes, unless the law requires otherwise or you ask us to keep them. See the Data Retention and Deletion Policy.
Your choices: you can delete any file you uploaded at any time, or choose "Request deletion of all my data". We confirm the deletion within 30 days.
Cookies: The portal uses only the cookie needed for secure sign-in. No advertising or analytics cookies.
Legal requests: We may disclose information if the law requires it, such as a valid subpoena or court order, or to prevent fraud.
Breaches: if a breach affects your private information, we will notify you and the authorities as the law requires, including under New York's SHIELD Act.
Changes to this notice: If we make a material change, we will tell you before it applies to your files and ask again where required. We will ask for your consent again before using your information in a new way. Changes are announced by email and on the portal, with a new version number and date.
Contact: [email protected]