This Privacy Policy explains how ELEN HOLDINGS LLC ("Truss-t," "we," "us," or "our") collects, uses, shares, and protects information about you when you use our online lending portal, websites, and related services (the "Services"). As a provider of financial services, we are also subject to the federal Gramm-Leach-Bliley Act (GLBA) and applicable state privacy laws.
1. Scope
This Policy applies to information we process about applicants, borrowers, guarantors, authorized signers, entity representatives, and visitors who use the Services. It does not apply to information handled by third parties we don't control (for example, title companies, attorneys, insurance carriers, or credit bureaus), which have their own privacy practices.
2. Information We Collect
Depending on how you use the Services, we may collect:
| Category | Examples |
|---|---|
| Identity & contact | Name, email, phone number, mailing address, date of birth, government ID, Social Security or tax ID number. |
| Entity & business | Borrowing entity name, formation documents, EIN, ownership, members, authorized signers. |
| Financial | Income, assets, bank and account information, credit history, transaction and payment details, loan and draw activity. |
| Property & loan | Property address, valuation, purchase and renovation details, title, insurance, and closing documents. |
| Documents you upload | Photos, invoices, statements, IDs, lien waivers, and other supporting files. |
| Device & usage | IP address, browser and device type, pages viewed, and interactions with the portal. |
3. How We Collect It
- Directly from you — when you create an account, apply for a loan, upload documents, or communicate with us.
- Automatically — through cookies and similar technologies as you use the Services.
- From third parties — such as credit bureaus, banks, title and escrow companies, insurance carriers, appraisers, public records, and identity-verification and fraud-prevention providers.
4. How We Use Your Information
- Create and manage your account and verify your identity.
- Evaluate, underwrite, approve, fund, and service loans, and process draws and payments.
- Communicate with you about your account, applications, and loans (transactional/service messages).
- Detect, prevent, and investigate fraud and security incidents.
- Comply with legal, regulatory, licensing, tax, and anti-money-laundering obligations.
- Operate, maintain, analyze, and improve the Services.
- Send marketing, service, and new-offer communications where permitted (see Marketing Communications).
5. GLBA Financial Privacy Notice
As a financial institution, we collect nonpublic personal information ("NPI") about you as described above. We may share NPI to provide our Services, process and service your loan, and as otherwise permitted or required by law. Federal law gives you the right to limit certain sharing; we describe our sharing practices below and will provide any legally required GLBA privacy notice and opt-out mechanism. We restrict access to NPI to those who need it to do their jobs and maintain physical, electronic, and procedural safeguards to protect it.
6. How We Share Information
We do not sell your personal information. We may share it with:
- Service providers / processors — cloud hosting, authentication, email delivery, document storage, and analytics vendors who process data on our behalf under contract.
- Transaction partners — title, escrow, and closing agents, attorneys, insurance carriers, appraisers, and recording services needed to originate and close your loan.
- Credit and verification agencies — credit bureaus and identity/fraud-prevention services.
- Lending affiliates, investors, and successors — including in connection with funding, sale, servicing transfer, financing, merger, or acquisition of loans or the business.
- Legal and regulatory — when required by law, subpoena, or regulator, or to protect our rights, safety, or property.
- With your consent — for any other purpose you authorize.
7. Marketing Communications
With your permission, we may send you service updates, marketing, and new-offer emails. You can opt out of marketing emails at any time by using the "unsubscribe" link in those emails or by contacting us at elen.investors@gmail.com. Even if you opt out of marketing, we will still send you transactional and service messages about your account and loans, which are necessary to provide the Services.
8. Cookies & Tracking
We use cookies and similar technologies to keep you signed in, remember preferences, secure the Services, and understand usage. You can control cookies through your browser settings, though disabling some cookies may affect how the Services work.
9. Data Retention
We keep your information for as long as your account is active and as needed to provide the Services, and thereafter as required to comply with legal, regulatory, tax, audit, and recordkeeping obligations, resolve disputes, and enforce our agreements. Loan and financial records are typically retained for periods set by applicable law.
10. Data Security
We use administrative, technical, and physical safeguards designed to protect your information, including encryption in transit, access controls, and authentication. No method of transmission or storage is completely secure, however, and we cannot guarantee absolute security. Please protect your login credentials and notify us at elen.investors@gmail.com if you suspect a problem.
11. Your Privacy Rights
Depending on where you live, you may have rights to access, correct, delete, or receive a copy of your personal information, and to opt out of certain uses. To exercise a right, contact us at elen.investors@gmail.com. We will verify your request and respond as required by law. Note that some information must be retained to service your loan or meet legal obligations and may not be deletable on request.
12. California Privacy Rights
If you are a California resident, the California Consumer Privacy Act (as amended by the CPRA) may give you rights to know, access, correct, delete, and limit certain uses of your personal information, and not to be discriminated against for exercising those rights. Much of the financial information we handle is covered by the GLBA and may be exempt from certain CCPA provisions. We do not sell or share personal information for cross-context behavioral advertising. To make a request, contact elen.investors@gmail.com.
13. Third-Party Links
The Services may link to third-party websites or tools. We are not responsible for their privacy practices. Review their policies before providing information.
14. Children's Privacy
The Services are intended for adults engaged in real-estate finance and are not directed to anyone under 18. We do not knowingly collect information from children. If you believe a child has provided us information, contact us and we will delete it.
15. Where Data Is Processed
We use reputable cloud infrastructure and service providers (for example, for hosting, authentication, and email delivery) to operate the Services, primarily in the United States. Where information is transferred across borders, we take steps to protect it consistent with this Policy and applicable law.
16. Changes to this Policy
We may update this Policy from time to time. We will revise the "Last updated" date above and, for material changes, provide additional notice. Your continued use of the Services after changes take effect constitutes acceptance of the updated Policy.
17. Contact Us
Questions or requests about your privacy? Contact us at:
ELEN HOLDINGS LLC (operating as Truss-t) — Privacy
9131 Kilbourn Ave, Skokie, IL 60076
Email: elen.investors@gmail.com
Web: www.truss-t.com