Privacy policy

1. Overview

RoseCove Ventures Corp. (“Company,” “we,” “us,” or “our”) operates Rose Cove. Our mission is to help you make sense of your financial options and find the right path forward. We connect you with lenders, banks, credit unions, and other financial service providers, and give you tools and information you can trust along the way. We do not directly originate loans or make credit decisions. Your trust matters to us, and we take the privacy and security of your personal information seriously. This Privacy Policy explains the practices you agree to when you visit our website, located at https://www.rosecove.com/ (“Site”), and use our services, submit information, or interact with us.

Please note that this Privacy Policy does not address our practices with respect to nonpublic personal information (“NPI”) governed under the Gramm-Leach-Bliley Act (“GLBA”), which is instead governed by our GLBA Privacy Notice, located at www.rosecove.com/legal/glba.

PLEASE REVIEW THIS PRIVACY POLICY CAREFULLY. When you access or use the Site or submit information to or through the Site, you accept the terms of this Privacy Policy and our Terms of Service, and you consent to the collection, use, disclosure, retention and processing of your information as described in this Privacy Policy, except where applicable law, such as Vermont law, requires your separate affirmative consent.

2. Information We Collect

A. Personal and Financial Information

We may collect:

• Full name, address, email, phone number
• Date of birth
• Employment status, employer, and income
• Housing status and monthly payment obligations
• Loan request details (amount, purpose, preferences)
• Credit profile information you provide
• Identity verification data
• Records of your consents and authorizations

B. Automatically Collected Information

We collect:

• IP address, device identifiers, browser data
• Session activity, clickstream data, timestamps
• Advertising engagement data
• Geolocation (approximate via IP)
• Behavioral and interaction data

We may use session replay, heat mapping, and AI-driven analytics tools where permitted.

C. Cookies and Tracking Technologies

A cookie is a small file containing a string of characters that is sent to your computer when you visit a website or use an online service. When you visit the website use the service again, the cookie allows that website or online service to recognize your browser or device. Cookies may store unique identifiers, user preferences and other information.

We may use “session cookies” or “persistent cookies.” Session cookies are temporary and expire once you close your browser or once your session ends. Persistent cookies remain on your device for much longer or until you or your browser erase them. Persistent cookies have varying durations that are dependent on their expiration date.

We may also use third-party cookies, like Google Analytics, which sets cookies on the Site to help analyze how visitors use the Site. Please note that information collected via third-party cookies may be shared with our website analytics and digital advertising vendors. You can visit https://www.google.com/settings/ads to learn more about Google’s use of cookies. If you would like to opt-out from the use of your information by Google Analytics, you may use Google Analytics’ opt-out browser add-on designed for this purpose.

We use cookies and similar tools for:

• Site operation
• Analytics and performance measurement
• Behavioral advertising
• Lead attribution and conversion tracking

We may participate in:

• Cross-device tracking
• Retargeting campaigns
• Third-party ad networks

Please see “Interest Based Advertising” below for more information.

Web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to manage and delete cookies, visit www.allaboutcookies.org. Some web browsers provide settings that allow a user to reject cookies or to alert a user when a cookie is placed on the user’s computer, tablet or mobile device. Most mobile devices also offer settings to reject mobile device identifiers. Although users are not required to accept cookies or mobile device identifiers, blocking or rejecting them may prevent access to some features available through the Site.

D. Interest Based Advertising

We may collect information about your online activities on our Sites to provide you with advertising about products tailored to your individual interests. We also may obtain information for this purpose from third-party websites on which our advertisements are served.

You may see certain advertisements on other websites because we work with advertising partners (including advertising networks) to engage in remarketing and retargeting activities. Our advertising partners allow us to target our messaging to users through demographic, interest-based and contextual means. These partners track your online activities over time and across websites, including our Site, by collecting information through automated means, including through the use of third-party cookies and pixels/web beacons, including the pixels/web beacons that we may utilize on the Sites and in our HTML-formatted email messages to you. They use this information to show you advertisements that may be tailored to your individual interests. The information our advertising partners may collect includes data about your visits to websites that participate in the relevant advertising networks, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our Sites and on third-party websites that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts. For example, we utilize certain of our advertising partners’ targeted advertising services to show you our advertisements on other websites based on your prior visits to our Sites and other online activity.

Provided that a company participates in industry-developed programs designed to provide consumers choices about whether to receive targeted advertising, you may opt out of interest-based advertising generally through the Network Advertising Initiative website or by visiting http://www.aboutads.info/choices/ (web-based advertising) or http://www.aboutads.info/appchoices (for mobile advertising). To learn more, please visit the websites operated by the Network Advertising Initiative and Digital Advertising Alliance at www.networkadvertising.org/choices. Opting-out does not mean that you will stop receiving advertisements from us. It means that you still stop receiving advertisements from us that have been targeted to you based on your visits and browsing activity across websites over time.

E. Information From Third Parties

We may receive data from:

• Lead sources and affiliates
• Marketing partners and data aggregators
• Identity verification and fraud vendors
• Consumer reporting agencies (where permitted)
• Advertising networks and analytics providers

3. How We Use Information

We use your information :

• To provide and improve our Site
• To personalize offers and our advertising and marketing communications, including by using data analytics and AI tools
• To communicate with you (including marketing and transactional communications)
• To improve marketplace performance, match rates, and targeting
• To match you with one or more lenders or financial providers
• To generate and sell consumer leads and loan inquiries
• To facilitate prequalification and eligibility screening
• To train proprietary large language models
• To conduct identity verification and fraud prevention
• For our other business purposes, such as customer service, data analytics, accounting, auditing and reporting, developing new or improving our products and services, identifying Site usage trends and determining the effectiveness of our promotional campaigns;
• As we believe to be necessary or appropriate: (i) under applicable law; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities; (iv) to enforce this Privacy Policy and our Terms of Service; (v) to protect our operations; (vi) to protect our rights, privacy, safety or property, and/or that of you or others; and (vii) to allow us to pursue available remedies or limit the damages that we may sustain.

4. How We Share Information

A. Lenders and Financial Providers (Primary Use Case)

We share your information with a lender or financial provider only when you choose to connect with that provider by clicking through to it on our Site, or as described in Section 4.B. When you click through, we share the information needed to process your request with that provider.

We may share your information with:

• Banks
• Credit unions
• Finance companies
• Marketplace lending platforms
• Loan brokers and aggregators
• Other financial service providers

Important: Each provider you choose to connect with may independently:

• Evaluate your eligibility
• Access your credit report
• Contact you directly
• Retain and reuse your information subject to their policies

B. Lead Buyers and Marketing Partners

We may share your information with:

• Lead purchasers
• Marketing partners
• Affiliate networks

These entities may contact you regarding financial products. We sell or share personal information with these entities only about consumers who have interacted directly with Rose Cove. If you are a Vermont resident, we share your information with these entities only if you opt in, as described in Section 12 (Vermont Residents).

C. Service Providers

We may share your information with vendors providing:

• Hosting and infrastructure
• Analytics and AI tools
• Adtech and tracking
• Identity verification
• Fraud prevention
• Communications (email, SMS, voice)
• Compliance and audit support

D. Legal Purposes

We may share your information as needed to:

• Enforce our rights
• Protect our property or protect the rights, property or safety of others
• Support external auditing, compliance and corporate governance functions
• Pursue available remedies or limit damages we may sustain
• Respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental or law enforcement request or other legal or regulatory process

E. Changes of Control

We reserve the right to transfer or assign the information that we have collected from users in connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

5. Consent to Contact and Communications

We and participating lenders, financial providers, lead buyers and marketing partners may contact you via:

• Email
• SMS/text messages
• Phone calls (including autodialed/prerecorded calls)

You understand:

• You may receive communications from multiple parties;
• For SMS/text messages and phone calls, you must provide your opt-in consent to be contacted. Consent is not a condition of obtaining credit;
• You may opt out at any time by following the unsubscribe instructions included in such messages or by contacting us at privacy@rosecove.com.

6. Information Security

We maintain safeguards including:

• Encryption and secure transmission
• Access controls and authentication
• Vendor risk management
• Monitoring and incident response
• Data minimization practices

However, please note that no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. It is your responsibility to protect the security of your login information.

7. Data Retention

We retain data as needed to:

• Facilitate matching and lead transactions
• Maintain compliance records (including consent logs)
• Meet regulatory and audit obligations
• Prevent fraud and enforce agreements

Retention periods vary by data category and legal requirements.

8. Children’s Privacy

We do not knowingly collect data from individuals under 13.

9. Do Not Track

Our Site does not currently take any action when it receives a Do Not Track request. Do Not Track is a privacy preference that you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For details, including how to turn on Do Not Track, visit www.donottrack.us.

10. Nevada Residents

If you are a Nevada resident, you may submit a request that we not sell any personal information we have collected about you by contacting us at privacy@rosecove.com.

11. California Shine the Light

Under California Civil Code Section 1798.83, also known as California’s “Shine the Light” law, if you are a California resident, you have a right to prevent your personal information from being disclosed to third parties for those third parties’ direct marketing purposes. If you would like to exercise this right, please contact us at privacy@rosecove.com.

12. Vermont Residents

If you are a Vermont resident, we will not share nonpublic personal financial information about you, including credit report information, with nonaffiliated third parties, other than as permitted by Vermont law, unless you authorize us to do so. Sharing that Vermont law permits without your authorization includes: (i) sharing needed to process a request you make, such as when you choose to connect with a lender or financial provider by clicking through to that provider on our Site; (ii) sharing with service providers that perform services for us under contracts that restrict their use of your information; (iii) sharing under joint marketing agreements with other financial institutions, as permitted by Vermont law; and (iv) sharing required or permitted by law, including to prevent fraud, respond to legal process, or comply with regulatory requirements.

 We will not share your information with the lead purchasers, marketing partners, or affiliate networks described in Section 4.B unless you opt in. You may opt in by checking the authorization box shown to Vermont residents when you submit information through the Site. Opting in is optional and is not required to use the Site or to receive our tools or recommendations. You may limit or withdraw your authorization at any time by contacting us at privacy@rosecove.com, and we will stop sharing your information under that authorization going forward.

 We will not share information about your creditworthiness with our affiliates without your authorization. We will obtain your consent before we obtain your credit report. Lenders and financial providers you choose to connect with are responsible for obtaining your consent before they obtain your credit report.

 Rose Cove is not a lender and does not make loans. Information you provide to us will be shared with third parties in connection with your loan inquiry, as described in this Privacy Policy. Lenders we connect you with may be subject to federal lending laws and may not be subject to all Vermont lending laws.

 We sell personal information only about consumers who have interacted directly with Rose Cove. For more information about how we handle nonpublic personal information, including your rights under Vermont law, please see our GLBA Privacy Notice at www.rosecove.com/legal/glba.

13. Third-Party Links and Online Services

Our Site may contain links to third- party websites and online services. We are not responsible for such third-parties’ privacy practices. Any access to and use of such third-party websites and online services is not governed by this Privacy Policy or our Terms of Service, but instead is governed by the privacy policies and terms of those third- party websites and online services.

14. Changes to This Policy

We may update this Privacy Policy periodically. Updates will be reflected by the “Last Updated” date.

15. Contact Information

RoseCove Ventures Corp. Attn: Privacy Office 1001 Post Road, Darien, CT 06820 Email: privacy@rosecove.com Phone: 315-566-8399