Client Privacy Notice

FACTS: What does Top Shelf Capital do with your personal information?

Top Shelf Fundability LLC, doing business as Top Shelf Capital. This notice is for our clients. For how this website and our consult form handle information, see our Privacy Policy.

Why we’re giving you this notice

Credit repair, business fundability, business plans, loan packaging, and grant-readiness services are financial services. Federal law (the Gramm-Leach-Bliley Act and its Privacy Rule, Regulation P) gives you the right to know how we collect, use, share, and protect your personal financial information. Please read this notice carefully.

What information we collect

To do the work you hire us for, we may collect the following nonpublic personal information:

• Identity and contact details: your name, address, phone number, email, date of birth, Social Security number, and a copy of your government ID (to verify your identity and send credit bureau disputes).
• Credit information: your credit reports and scores, account and payment history, collections, inquiries, and dispute results.
• Income and employment: income, pay stubs, tax returns, W-2s/1099s, and employment history.
• Bank and asset information: bank statements, account balances, and assets and debts.
• Business information: business financials (profit and loss statements, balance sheets, business bank statements, business tax returns, debt schedules), EIN, formation and ownership documents, and business credit reports.
• Grant and nonprofit information: organization documents, budgets, and financial statements. These may include personal details about owners, officers, or board members.
• Payment information: how and when you pay us.

We get this information from you; from credit bureaus and credit monitoring services that you authorize us to use; and from lenders, funders, agencies, and creditors that respond to applications or disputes we submit for you.

How we use it

Only to:

• provide the services in your written agreement (for example, reviewing your credit, preparing disputes you approve, building a business plan, packaging a loan file, or preparing a grant application);
• communicate with you about your file;
• meet our legal duties (federal Credit Repair Organizations Act, Texas Finance Code chapter 393, tax, and record-keeping laws); and
• protect against fraud and keep our records secure.

How we share it

We do not sell your personal information. We do not rent it, and we do not share it with anyone for their own marketing.

We share information with companies we are not affiliated with only as needed to provide the service you asked for, or as the law allows or requires:

Your opt-out rights

We do not share your information in any way that requires an opt-out under federal law. We share only to provide your service, with your consent, or as the law allows or requires. If that ever changes, we will send you a new notice and a chance to opt out before we share.

Former clients

If you stop being a client, we continue to protect your information as described in this notice.

How we protect it

We will protect your information with these safeguards:

• A written security program. We will keep a written information security program under the FTC Safeguards Rule (16 C.F.R. Part 314). The person responsible for it is Derick Coleman, Owner.
• Limited access. We will limit access to your information to staff who need it to work on your file.
• Strong logins. We use strong passwords and two-step login (multi-factor authentication) on the accounts that hold client information.
• Encrypted files. We will encrypt the client files we store.
• Secure sharing. Please do not send SSNs, account numbers, or full credit reports by regular email or through our website form. Instead, use a secure, encrypted method we provide (never regular email).
• Careful choice of vendors. We will choose service providers that can protect your information, share only what they need, and require them to keep it confidential and secure.
• Secure disposal. We will shred paper and permanently delete files we no longer need.
• If something goes wrong. If unencrypted customer information about 500 or more people is acquired without authorization, we will notify the FTC within 30 days of discovery, as the Safeguards Rule requires. We will also notify you as Texas law requires (see Texas notes below).

How long we keep it

• Signed agreements, disclosures, and cancellation records: at least 2 years (the CROA minimum). We will keep them for 5 years after your engagement ends.
• Sensitive documents (SSN or ID copies, full credit reports, bank statements, tax returns): kept only while we are working on your file. We securely delete or shred them within 90 days after the work ends, and never later than 2 years after we last used them, unless the law requires us to keep them longer or you ask us in writing to keep them.

Questions or requests

Questions, or want to see, correct, or ask us to delete your information (when we are allowed to)? Contact us:

• Email: info@topshelffundability.com
• Phone: 910-978-1173

Texas notes

• Texas Credit Services Organization. Top Shelf Fundability LLC is registered as a Credit Services Organization with the Texas Secretary of State under Texas Finance Code chapter 393: Registration No. 20260142 (approved; expires 9/25/2027). As Texas requires, a surety bond (#352105, issued by NGM Insurance Company and obtained through BondAbility) is on file. Our Texas disclosure statement explains your bond rights. See our Texas CSO notice.
• Data security (Tex. Bus. & Com. Code ch. 521). We will use reasonable procedures to protect sensitive personal information, and we will destroy or erase records containing it when we no longer need to keep them.
• Breach notice (Tex. Bus. & Com. Code § 521.053). If a breach of system security affects your sensitive personal information, we will notify you without unreasonable delay and no later than 60 days after we determine the breach happened. If the breach affects 250 or more Texans, we will also notify the Texas Attorney General within 30 days.
• Social Security numbers (Tex. Bus. & Com. Code ch. 501). We will never print your SSN on anything mailed to you unless the law requires it, and we will never ask you to send it over the internet unless the connection is secure or the information is encrypted.
• Texas Data Privacy and Security Act. In general, this law does not apply to financial institutions covered by the GLBA or to small businesses. Even so, we do not sell personal data, including sensitive data.
• Calls and texts. We follow Texas telemarketing and texting laws (Bus. & Com. Code ch. 301, 304, and 305) and honor Texas no-call requests.
• Complaints. You may contact us first at 910-978-1173 or info@topshelffundability.com. You can also contact the Texas Secretary of State (Credit Services Organizations) or the Texas Attorney General, Consumer Protection Division.

Changes

If we change this notice, we will update this page and the effective date, and we will send clients a new notice when the law requires it.