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Effective Date: 3 September 2026

Privacy Policy

How Rhofin collects, uses, shares, protects and retains personal information in connection with our website, preliminary enquiries, onboarding, underwriting, transaction administration, servicing and receivables-purchase activities.

01 / Introduction

Who we are and what this covers

Rhofin Inc. ("Rhofin," "we," "us," or "our") operates a technology and commercial-finance platform for eligible business customers, logistics providers and other transaction participants. This Privacy Policy explains how Rhofin collects, uses, shares, protects and retains personal information in connection with its website, preliminary enquiries, onboarding, underwriting, transaction administration, servicing and receivables-purchase activities.

This policy applies to individuals who interact with our website or platform, including business owners, officers, directors, beneficial owners, authorised users and guarantors of our business customers, as well as contacts at logistics providers, suppliers and account debtors. Our services are directed to businesses and the individuals who act for them, not to consumers acting in a personal, family or household capacity.

We do not sell your personal information, and we do not share it for cross-context behavioural advertising. We collect and use personal information for the business and commercial purposes described in this policy.

02 / Who Is Responsible

Who is responsible for your information

Rhofin Inc., a Delaware corporation, is responsible for the personal information processed in connection with its website and platform. Rhofin acts as an independent controller of personal information it processes in its capacity as lender, purchaser, servicer, collateral agent and financing-program operator. We have designated a point of contact for data protection matters.

For any privacy enquiry, to exercise a right described in Section 12, or to raise a concern, contact us at compliance@rhofin.com. We may ask you to verify your identity before acting on a request.

03 / Information We Collect

What we collect

The categories of personal information we collect depend on how you interact with us. A website enquiry involves far less than onboarding as a customer. Depending on the relationship, we may collect:

Identity and Contact
Names and business contact information, including for company officers, directors, beneficial owners, authorised users and guarantors.
Personal Identifiers
Dates of birth and residential addresses where required, government-issued identification, and taxpayer-identification information, including employer identification numbers (EIN) and other organisational identifiers.
Verification and Screening
Business-verification, identity-verification, sanctions-screening and forced-labour (including UFLPA) screening information used to confirm who we are dealing with and to meet our legal obligations.
Credit Information
Personal and commercial credit information used to assess eligibility and make credit decisions. See Section 6 (Consumer Reports and Credit Information).
Financial and Banking
Bank-account and financial information, including account and routing numbers, supplier invoices, supplier and supplier-contact information, and payment instructions used to fund and settle transactions.
Shipment and Cargo
Cargo, shipment, container and bill-of-lading information relating to a financed shipment.
Collateral
Collateral information relating to financed goods and their proceeds, including documents of title, UCC filing details and insurance information.
Wallet Addresses
Where enabled for a transaction, blockchain wallet addresses used to send or receive settlement.
Receivables
Invoices, account-debtor information and proof-of-delivery information relating to receivables we may purchase or administer.
Communications
Communications and support records, including correspondence and the content of your messages, so we can respond and keep accurate records.
Platform and Device
Login, platform, device, browser, IP-address and security information collected when you use our website or portal, used to operate and protect the platform.

We ask that you provide only the information we request, and that you do not send us special categories of information (such as health data) unless we specifically ask for it in connection with a transaction.

03A / Shipment Planner Data

How we use planner scenarios

When you change the shipment planner, Rhofin records a stable scenario after you pause. A scenario may include hypothetical shipment values, costs and timing; HTS classification and origin and destination route codes; financing selections; calculated results; the planner-model and Important Information versions; an ephemeral browser-session identifier; and, if you are signed in, the email address associated with your Rhofin account.

We use planner scenarios only as first-party data to operate and test the planner, understand demand and improve the planner and Rhofin's products. We do not sell or share planner scenarios. We do not send planner financial values or signed-in email addresses to PostHog. We do not use planner scenarios for CRM enrichment, eligibility, underwriting, pricing, automated profiling or credit decisions.

We retain the link to a signed-in email address and the browser-session identifier for three years after a scenario is captured. We then remove both identifiers. We may retain the remaining de-identified scenario for longer for longitudinal product and demand analysis, and we will not attempt to re-identify it.

You may request access to, correction of or deletion of personal information in a planner scenario through the channels described in Your Privacy Rights and Contact Us.

04 / Where We Obtain Information

Where the information comes from

We obtain personal information from the following sources:

  • Applicants and customers, and the business owners, officers and guarantors who act for them;
  • Logistics providers involved in a shipment;
  • Suppliers and account debtors;
  • Credit bureaus and commercial-data providers;
  • Identity, fraud, sanctions and verification providers;
  • Banks, payment providers and funding partners;
  • Website-visitor identification providers;
  • Public records and government sources; and
  • Our website and platform, and your interactions with them.
05 / How We Use Your Information

How we use it

We use personal information for the following business and commercial purposes:

  • Conducting preliminary eligibility reviews;
  • Onboarding and business verification;
  • Underwriting and making credit decisions;
  • Fraud prevention and sanctions screening;
  • Verifying shipments, invoices and proof of delivery;
  • Originating and administering commercial loans;
  • Purchasing and administering receivables;
  • Perfecting and enforcing security interests;
  • Managing cargo release;
  • Servicing, payment processing and collections;
  • Resolving complaints and disputes;
  • Complying with laws, audits, litigation and regulatory requests; and
  • Protecting the platform and preventing unauthorised access.

No sale; no advertising. We do not sell your personal information, and we do not share it for cross-context behavioural advertising. We do not use your personal information to make decisions producing legal or similarly significant effects about you by solely automated means without human involvement.

06 / Consumer Reports and Credit Information

Credit reports and your authorisation

To assess eligibility and make credit decisions, Rhofin may obtain personal and commercial credit reports and other consumer reports about a business and the individuals associated with it, including owners, officers and guarantors, from credit bureaus and other consumer-reporting agencies.

This Privacy Policy is not your authorisation to obtain a consumer report about you. Where an individual's consumer report may be obtained, a separate, affirmative authorisation is requested from that individual during onboarding, before the report is obtained. Where required by applicable law, if we take adverse action based in whole or in part on information in a consumer report, we will provide the notices that law requires.

07 / How We Share Information

Who we share information with

We share personal information with the following categories of recipients where relevant to a transaction or to operating our platform:

  • Current or future partner banks;
  • Special-purpose vehicles and other funding or purchasing entities;
  • Current and prospective financing sources assessing a transaction or portfolio;
  • Servicers, agents, collateral agents and collection providers;
  • Logistics providers involved in the transaction;
  • Credit bureaus;
  • Identity, sanctions, fraud and verification providers;
  • Payment and banking-service providers;
  • Cloud, communications, analytics and security vendors;
  • Website-visitor identification and sales-engagement vendors; and
  • Insurers, auditors, legal advisers, regulators and government authorities.

Rhofin shares information with these parties only where relevant to evaluating, originating, funding, acquiring, administering, servicing or enforcing a transaction, operating the platform, protecting against fraud or complying with applicable law.

We require our service providers to process personal information only for the purposes for which we engage them. We may also disclose personal information as required by law, regulation, subpoena, court order or governmental authority, or to protect the rights, property or safety of Rhofin, our customers or others. If Rhofin is involved in a merger, acquisition, financing or sale of assets, personal information may be transferred as part of that transaction.

We process personal information primarily in the United States. Where information is transferred from another country, we take steps to provide appropriate protection consistent with applicable law.

08 / SMS Communications

Our text-message programme

Where you have voluntarily provided a mobile phone number and given explicit consent, we may send you SMS (text) messages relating to your use of the Rhofin platform. This section sets out what we send, how to opt in and out, and how we handle your number.

Programme Description
We send transactional and customer-care SMS only. Examples include application status updates, onboarding milestones, funding event notifications, and replies to support enquiries you have raised. We do not send marketing or promotional SMS under any circumstances.
How to Opt In
You may opt in to SMS in two places: (a) on our public Contact Us page, by entering a mobile number and ticking the explicit SMS consent checkbox next to the phone field; or (b) inside the authenticated Rhofin portal at app.rhofin.com, by adding a mobile number and checking the consent box on your account or notification settings page. Phone numbers are never required, and consent is never bundled with sign-up or with acceptance of these or any other terms.
Message Frequency
Frequency varies and is driven by your account activity, typically a small number of messages per month per active account. There is no fixed cadence.
Cost
Message and data rates may apply. Carriers may charge you for receiving SMS based on your mobile plan; Rhofin does not control those charges.
How to Opt Out
Reply STOP to any Rhofin SMS to immediately revoke your consent and stop all future messages. Reply HELP for assistance. You may also disable SMS at any time in your portal account settings, or email us at support@rhofin.com.
Sub-Processors
We use Twilio Inc. ("Twilio") as our SMS sub-processor. Twilio processes your mobile phone number and message content solely to deliver the messages on our behalf, under a written data processing agreement. We do not share your mobile number with any other third party for SMS purposes, and we never receive your number from a third party.
Carrier Disclaimer
Mobile carriers are not liable for delayed or undelivered SMS. We deliver messages to Twilio for onward transmission to your carrier on a best-efforts basis but cannot guarantee delivery, latency, or carrier behaviour.

Consent is always explicit. The only places Rhofin collects mobile phone numbers for SMS are our public Contact Us page (with an explicit, unchecked-by-default SMS consent checkbox next to the phone field) and the authenticated portal at app.rhofin.com. We never opt you in by default.

09 / Data Retention

How long we keep information

We retain personal information for as long as necessary to fulfil the purposes described in this policy, to administer and service transactions, and to comply with our legal, regulatory, tax, audit and recordkeeping obligations, after which it is deleted or anonymised. Because we originate and administer financing and purchase receivables, we generally retain financing, receivables-purchase, shipment, cargo-release, verification, credit-decision, consent, adverse-action, sanctions-screening and audit records for at least seven years after the later of transaction completion or termination of the relevant relationship, unless a longer period is required by law, litigation hold or contract.

Website enquiry and general contact records are retained for a shorter period sufficient to respond and maintain business continuity. You may request deletion of your personal information (see Section 12), subject to any overriding legal or legitimate business need to retain it.

10 / Cookies and Tracking Technologies

How we use cookies

Our website and authenticated portal use cookies and similar technologies to operate correctly, keep the services secure, and understand how visitors move through them. Strictly necessary cookies are required for the services to function. Our configured analytics tools begin on first visit without a separate cookie prompt and use a persistent pseudonymous browser identifier across Rhofin subdomains. You can block or delete these cookies through your browser settings.

We use PostHog as our product-analytics provider. It records page and route visits, selected actions, and privacy-masked session replays so we can understand journeys from the public website into the portal and improve those journeys. After portal authentication, the journey may be associated with an internal profile and organisation identifier and limited account categories such as portal and role; we do not send PostHog names, email addresses, phone numbers, organisation names, financial values or free-text form content. Public-site inputs and the displayed enquiry email are masked. In the portal, all visible text, input values and element attributes are masked; URL query strings, fragments and access tokens are removed, and network request or response headers and bodies are not recorded. A successful portal logout resets the analytics identity. Rhofin configures the PostHog project not to retain IP addresses and does not use this information for advertising.

We also use a business-visitor identification service, lemlist, on our public website. It records the pages you visit on our website, together with technical information such as your browser details and the IP address your visit comes from, and uses that information to identify the business a visit is likely to have come from; for visits from the United States it may also identify an individual business contact and their job role. We use this only to understand which businesses are interested in our services and to prioritise our own business-to-business outreach. The script itself does not store anything on your device or read your existing cookies, and it does not run in the authenticated Rhofin portal. If you would prefer not to be identified in this way, you can block the script in your browser or write to us at compliance@rhofin.com.

We do not use cookies or tracking technologies to build advertising profiles or to share your browsing behaviour with third-party advertisers. You can control cookies through your browser settings; disabling certain cookies may affect how the website works.

11 / Security Measures

How we protect information

We implement technical and organisational measures designed to protect personal information against loss, misuse, and unauthorised access, alteration or disclosure. Our measures include:

  • Encryption of data in transit using industry-standard TLS protocols;
  • Encryption of data at rest on our servers and cloud infrastructure;
  • Access controls limiting data access to authorised personnel on a need-to-know basis;
  • Regular review of our information-security policies and procedures;
  • Use of reputable, security-accredited cloud infrastructure and service providers; and
  • Contractual obligations on our service providers to maintain appropriate security.

Where a security incident affecting personal information occurs, we will notify affected individuals and authorities as and when required by applicable law.

No method of transmission over the internet or method of electronic storage is completely secure. While we use commercially reasonable measures to protect personal information, we cannot guarantee its absolute security.

12 / Your Privacy Rights

Your choices and rights

Depending on where you live and the nature of the information, you may have rights to request access to, a copy of, correction of, or deletion of certain personal information we hold about you, and to appeal a decision on your request. To make a request, email us at compliance@rhofin.com. We will respond within the timeframe required by applicable law and may need to verify your identity first.

Some US state privacy laws contain exemptions for personal information collected in a business-to-business context, and for financial information and activities governed by the federal Gramm-Leach-Bliley Act (GLBA) and the Fair Credit Reporting Act (FCRA). Where such an exemption applies, a particular right may be limited or unavailable, and information handled under GLBA and FCRA is governed by those frameworks and their own notices.

Access and Portability
You may ask what personal information we hold about you and, where applicable, request a copy in a portable format.
Correction
You may ask us to correct inaccurate or incomplete personal information.
Deletion
You may ask us to delete personal information, subject to legal and legitimate-business retention needs.
Opt Out of Sale or Sharing
We do not sell personal information or share it for cross-context behavioural advertising, so there is nothing to opt out of; you may still contact us to confirm our practices.
Withdraw SMS Consent
Where you have consented to SMS, you may withdraw consent at any time by replying STOP or as described in Section 8.
Non-Discrimination
We will not deny you services, or provide a different level or quality of service, because you exercised a privacy right.

If you believe we have not handled your personal information consistently with this policy or applicable law, you may contact your state attorney general or applicable regulator. If you are located outside the United States, you may have rights under the laws of your jurisdiction and may contact us to exercise them. We encourage you to contact us first so we can address your concern directly.

13 / Contact Us

Get in touch about your information

For any privacy-related enquiry, to exercise a right, or if you have a concern about how we handle personal information, please reach out to us directly.

EntityRhofin Inc.
Address221 W 9th St #180, Wilmington, DE 19801, USA

Important information

13 clauses. Version 2026-09-01.1, effective 1 September 2026.

  1. 1. Who we are. Rhofin Inc. is a nonbank commercial finance company, not a bank. Rhofin does not accept deposits or hold customer funds.
  2. 2. Business use only. All financing described is commercial financing extended to business entities for business purposes. It is not available for personal, family or household purposes, and is not available to sole proprietorships, general partnerships or individuals.
  3. 3. Nothing here is an offer. Nothing on this website is an offer or commitment to extend financing. Submitting the form is a preliminary enquiry, not an application, and no credit check is run at that stage. Any transaction is subject to eligibility, verification, credit approval, required disclosures, definitive documentation and applicable law. Those documents govern. Nothing on this website varies them.
  4. 4. Who provides the financing. During Rhofin's current limited-release phase, inventory financing may be provided directly by Rhofin, Inc. from its own balance sheet. Rhofin, Inc. is a nonbank commercial finance company and is not a bank. Rhofin does not accept deposits. The legal lender applicable to each transaction is identified in the definitive financing documents. Rhofin, Inc. may also provide the technology platform and act as servicer, administrator, agent or collateral agent, as specified in those documents. Financing is offered only where permitted by applicable law. Rhofin finances US incorporated businesses only. Availability varies by state. Financing requires the shipment to move through a participating logistics provider.
  5. 5. Figures are examples. Figures shown are illustrative examples, not quotations. Your amount financed, annual percentage rate, total cost and repayment date are set at approval and disclosed to you in full before you commit.
  6. 6. Pricing. Financing is priced per transaction. Rates start at 1.45% per 30 days on the supplier balance advance, and your rate depends on your credit profile, the shipment, the route, the supplier and the jurisdiction. Your amount financed, annual percentage rate, total financing cost and repayment date are set at approval and disclosed to you in full before you commit. There are no origination, arrangement, documentation, wire, platform or monthly fees. Eligible ocean freight is advanced at no financing charge and repaid at face value. A default margin applies to amounts unpaid from the sixth day after the maturity date, at the rate stated in your documents before you sign. Pricing may vary by state where required by applicable law.
  7. 7. What the financing is. Rhofin extends a secured commercial loan against a specific shipment. Rhofin holds the bill of lading and takes a purchase money security interest in the specific financed goods and their identifiable proceeds, as described in the definitive transaction documents and applicable UCC filings. Rhofin holds a negotiable to-order bill of lading with telex and express release disabled. The cargo is released only against Rhofin's release instruction, under a procedure agreed in advance with the responsible logistics provider. The financing is full recourse, so if realising the cargo does not cover the amount owed you remain liable for the shortfall. If an amount stays unpaid Rhofin may sell the financed cargo, and has committed to use commercially reasonable efforts to complete a disposition within 90 days after maturity, subject to the exceptions in your documents, including legal process, customs or regulatory holds, casualty, general average, salvage, the absence of a commercially reasonable market, and your own acts or omissions. Repayment falls due on arrival of the cargo at the destination CFS, or on availability for collection where the shipment moves as a full container load, or on the earlier date on which the goods are sold or released to you. Where Rhofin approves a warehouse sell-down period for an enrolled importer at an approved facility, maturity and release mechanics for that shipment are instead governed by the definitive warehouse financing terms, and the goods remain held at the approved facility and are released only against Rhofin's authorization. If you sell the goods you must prepay from the proceeds. Where cargo is released to you before payment, you hold the goods and their sale proceeds in trust for Rhofin, must keep the proceeds identifiable, and may be required to route them through an account Rhofin designates. Where your documents do not require cargo insurance, you bear the risk of loss, damage or destruction from any cause, and no such event reduces or suspends what you owe. Any additional credit support is set per facility and stated in your documents before signing.
  8. 8. What is not financed. Duties, taxes and other government charges, demurrage, detention and storage charges are not financed and remain your responsibility, as they would be without financing. Where Rhofin approves a warehouse sell-down period, Rhofin may continue financing the goods while they remain at the approved facility, as described in clause 7; the storage charges themselves remain your responsibility. Where Rhofin pays a logistics charge to obtain release of your cargo, that amount is added to what you owe and bears interest at the rate applicable to advances. A customs detention, seizure or withhold release order does not suspend your obligation to repay.
  9. 9. Out of scope. Commodities, seasonal goods and fungible bulk, goods not identifiable by container and lot marks, perishables, hazmat, pharma, alcohol, tobacco, weapons, sanctioned or high UFLPA risk supply chains, overland cargo from Canada or Mexico, businesses in serious financial distress, and importers shipping fewer than about four times a year. Approved lanes and approved suppliers only.
  10. 10. Settling at arrival. An inventory-finance transaction is settled in cash on the maturity date. You may fund that payment from your own cash or from availability under your factoring or asset-based facility, at your request and with your lender's approval. A payoff made by your factor or asset-based lender directly to Rhofin before release requires an agreement between Rhofin and that lender and remains that lender's decision. Once the amount due is settled, Rhofin issues its release instruction and the cargo is released. Rhofin does not finance the same goods after they are released to you.
  11. 11. Your existing lenders. Rhofin is designed to sit alongside an existing bank facility. Where another lender holds a security interest in your inventory, funding is conditional on a lien search showing no competing interest, or on a subordination, release or estoppel acceptable to Rhofin. You must identify that lender so Rhofin can send the UCC notice the law requires before you take possession of the goods. Most bank facilities also restrict additional indebtedness and additional liens. Whether Rhofin financing is permitted under your own facility documents is for you and your lender to confirm.
  12. 12. Law and forum. Your transaction documents are governed by New York law. The state and federal courts in Manhattan have jurisdiction. You and Rhofin waive trial by jury. Payments are made in full without set-off or counterclaim.
  13. 13. No advice. Nothing on this website is legal, tax, accounting or financial advice.

End of Important information, version 2026-09-01.1, effective 1 September 2026.

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