Privacy Policy

Our company name is RPA Commercial Loans, a division of Intouch Dynamics, with a registered corporate address of 30 N Gould Street, Suite R, Sheridan, WY 82801.

Our primary website addresses include:

• https://rpacommercialloans.com
• https://rpa-us.com
• https://app.rpacommercialloans.com (Application Portal)

Personal Data: While using our services, we may collect personally identifiable information including:

• Full name, email address, and phone number
• Mailing address, city, state, and ZIP code
• Social Security Number (for credit authorization only, encrypted)
• Date of birth and marital status (for loan applications)
• Financial information: income, assets, liabilities, credit scores
• Property information: address, value, type, and ownership details
• Uploaded documents: tax returns, financial statements, IDs, credit reports
• Business entity information: EIN, entity type, formation details

Usage Data: We automatically collect usage information when you visit our websites or use our platform, including your IP address, browser type, pages visited, time spent on pages, and device identifiers. This data helps us improve our services and diagnose technical issues.

We use the information we collect for the following purposes:

• Loan Processing: To evaluate and process commercial loan applications, including matching you with appropriate funders.
• Account Management: To manage your account, authenticate your identity, and provide access to the application portal.
• Communication: To contact you about your application, provide status updates, and respond to inquiries via email, phone, or SMS (with your consent).
• Service Improvement: To analyze how our platform is used and to improve its functionality and user experience.
• Legal Compliance: To comply with applicable laws, regulations, and legal processes, including anti-money laundering (AML) and Know Your Customer (KYC) requirements.
• Marketing: With your consent, to send newsletters, market insights, and promotional materials. You may opt out at any time.

We use cookies and similar tracking technologies to track activity on our websites and store certain information. The types of cookies we use include:

• Essential Cookies (Session): Required for basic site functionality, authentication, and security. Cannot be disabled.
• Cookie Consent Cookies (Persistent): Records your acceptance of our cookie policy.
• Functionality Cookies (Persistent): Remember your preferences and login details for a better experience.
• Analytics Cookies (Persistent, Third-Party): Track usage patterns to help us understand how visitors use our site. Information collected is pseudonymized.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, some parts of our service may not function properly. Our website displays a cookie consent banner allowing you to manage your preferences.

We do not sell your personal information to third parties. We may share your information in the following limited circumstances:

• Funding Partners: With your explicit consent, we share relevant loan application data with potential funders as part of the loan placement process.
• Service Providers: With vetted third-party vendors who assist in operating our platform (e.g., document processing, e-signature, credit reporting), subject to confidentiality agreements.
• Legal Requirements: When required by law, subpoena, court order, or governmental authority.
• Business Transfers: In the event of a merger, acquisition, or asset sale, your information may be transferred as part of that transaction.

If you are a California resident, you have the following rights under the CCPA:

• Right to Know: You may request disclosure of the categories and specific pieces of personal information we have collected about you.
• Right to Delete: You may request deletion of your personal information, subject to certain exceptions (e.g., where the information is required to complete a transaction or comply with legal obligations).
• Right to Opt-Out of Sale: We do not sell your personal information. Therefore, this right is not applicable, but you may submit a request confirming this.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights.

To exercise any of these rights, please contact us here. We will respond within 45 days of receiving a verifiable consumer request.

For GDPR inquiries (European residents), please use the same contact form. We will respond in accordance with applicable EU data protection laws.

We retain personal information for as long as necessary to fulfill the purposes outlined in this policy, or as required by law. Loan application data is retained for a minimum of seven years to comply with financial record-keeping regulations.

We employ industry-standard security measures to protect your information, including:

• SSL/TLS encryption for all data transmitted between your browser and our servers
• Encrypted storage for sensitive fields including SSNs and financial data
• Role-based access controls limiting data access to authorized personnel only
• Regular security audits and system monitoring

No method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee absolute security.

Data Collected Within the Application Portal:

• Loan application details: property information, loan amounts, transaction type, and project specifics
• Borrower and co-borrower personal and financial information as described above
• Uploaded documents: financial statements, tax returns, government-issued identification, credit reports, property records, and other supporting documentation
• Electronic signature records and consent logs
• Communication records between borrowers, brokers, loan officers, and funders within the platform
• Session data, login history, and audit logs

How Application Data Is Processed:

• Document data may be processed by artificial intelligence (AI) tools to assist with data extraction, underwriting analysis, and document verification. AI-assisted analysis is always reviewed by a human loan officer before any decision is made.
• Property data may be cross-referenced with third-party data providers (such as Property Radar) to validate information provided in the application.
• Credit authorization documents are processed through secure e-signature platforms (Adobe Sign or DocuSign).

Data Storage and Access:

• All application data is stored on Base44's secure, encrypted cloud infrastructure hosted in the United States.
• Access to your application data within our portal is restricted to: you (the applicant), your assigned loan officer, your referring broker or originator (if applicable), and authorized RPA Commercial Loans administrators.
• Funders only receive your information after you have selected a funder and consented to sharing your application package.

Third-Party Services Used in the Application:

• Base44: Application platform, database hosting, authentication, and file storage
• Google reCAPTCHA: Bot prevention on public forms (subject to Google's Privacy Policy)
• Adobe Sign / DocuSign: Electronic signature processing for agreements and authorizations
• Property Radar: Property data and valuation information
• Resend: Transactional email delivery
• Square: Payment processing for applicable fees (subject to Square's Privacy Policy)
• OpenAI / Anthropic Claude: AI-assisted document analysis and content processing (data is not used to train AI models)

Your Rights Regarding Application Data: You may request access to, correction of, or deletion of your application data by contacting your assigned loan officer or using our online contact form. Please note that certain records may be required to be retained for regulatory compliance purposes even following a deletion request.

RPA Commercial Loans operates a built-in Customer Relationship Management (CRM) system accessible to registered partners (loan originators, brokers, referral agents) and internal staff. This section describes how data within the CRM is collected, stored, accessed, and protected.

Data Collected in the CRM:

• Lead contact information: name, email address, phone number, company, and title
• Loan inquiry details: estimated loan amount, loan type of interest, property type, and state
• Lead source, status, and priority level
• Assignment records: which RPA partner or officer a lead is assigned to, and by whom
• Activity logs: records of calls, emails, texts, meetings, and internal notes, including timestamps, outcomes, and scheduled follow-up dates
• Communication notes entered by partners or staff summarizing interactions

Access Controls and Contact Masking:

• Full contact information (complete email addresses, direct phone numbers) is visible only to users with privileged roles: administrators, executives, and loan officers.
• Partners at the broker, loan originator, and referral agent level see masked email addresses (e.g., j***@e***.com) in place of actual email addresses for leads, borrowers, and funders. This is a deliberate privacy and non-circumvention control.
• Activity note bodies are automatically scanned before saving, and any email addresses or URLs embedded in notes are replaced with [email removed] or [link removed] to prevent circumvention of the platform.

How CRM Data Is Used:

• To manage and track the sales pipeline for commercial loan origination
• To facilitate timely follow-up and communication between RPA partners and prospective borrowers
• To maintain a complete and auditable record of all interactions for compliance and dispute resolution purposes
• To allow administrators and executives to assign, monitor, and supervise partner activity

CRM Data Retention: CRM lead and activity records are retained for a minimum of three years from the date of last activity, or for the duration of any associated loan transaction plus seven years, whichever is longer, to satisfy financial services record-keeping obligations.

Partner Obligations: Partners accessing the CRM agree that all lead data and contact information within the platform is the property of RPA Commercial Loans. Partners may not export, copy, or use CRM contact data outside the platform, including for the purpose of directing transactions to competing entities. Full details are outlined in the Partner Agreement and Terms of Use.

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

We reserve the right to update this Privacy Policy at any time. Changes will be posted on this page with an updated "Last Updated" date. Continued use of our services following any changes constitutes your acceptance of the revised policy. We encourage you to review this page periodically.