Privacy and Cookies Policy and Declarations of Consent

1. Who We Are and What this Policy Is
Welcome to ICON Commercial Lending Inc, (“ICON,” “we,” “us” and “our” etc.). ICON is
a leading commercial  financing company assisting companies improve their cash-flow
and overall business profitability. ICON is a trusted adviser to many of the country’s
most respected business organizations. ICON operates nationwide, providing expert
financing solutions for small, medium and large commercial entities. 
We provide a variety of services to these clients and other parties, including, but not
limited to: (i) Commercial Lines-of-Credit; (ii) Debt consolidation Financing; (iii)
Merchant Cash Advances; (iv) Equipment Financing; (v) Invoice A/R Financing; (vi)
Vendor Financing; (vii) Franchise Financing; (viii) SBA Lending Programs and (ix) Other
Commercial Real Estate Financing (collectively, and among others, our “Services”). For
additional information on our Services please visit https://www.ICONcl.com
 
We respect the privacy of our clients and other users of our services (“you”, “your”) and
are committed to protecting your personal data and information according to all
applicable laws. This privacy policy (“Policy”) explains how, to what extent and for what
purposes we are collecting and subsequently processing personal data and information.
 
ICON takes its responsibility for the processing of your personal data and information
very seriously, whether provided to us on our website, via email, via social networking
sites, telephone interviews, in person or otherwise. For the purpose of this Policy, the
controller of personal data is ICON Commercial Lending Inc and our contact details are
set out in the 'How to Contact Us' section at the end of this Policy.

 

2. Definitions
In addition to terms defined elsewhere in this Policy, the following terms shall have the
following meaning throughout this Policy:
 
“Personal Information” means any information that either (a) personally identifies a
natural person; or (b) pertains to an identifiable natural person, i.e. someone who can
be identified, directly or indirectly, in particular, by reference to an identifier such as a
name, an identification number, location data, an online identifier or to one or more
factors specific to his or her physical, physiological, genetic, mental, economic, cultural
or social identity, or (c) constitutes individually identifiable information about an
individual consumer collected by us online through our website and that we maintain in
an accessible form, or that (d) we are otherwise required to protect under applicable
data privacy laws (including, but not limited to, national, international and supranational
data protection and privacy laws, directives, regulations and comparable legal acts). 
 
Examples of Personal Information include your contact details such as your name,
email address, birthday or phone number as well as information about your professional
education and experience, skills, preferences, membership in professional
organizations, etc.;

“Processing” (and variations such as “Process”) means any operation or set of
operations which is performed on Personal Information or on sets of Personal
Information, whether or not by automated means, such as the collection, recording,
organization, structuring, storage, adaptation or alteration, retrieval, consultation, use,
disclosure by transmission, dissemination or otherwise making available, alignment or
combination, blocking, restriction, erasure or destruction;
 
“Sensitive Personal Information” means Personal Information revealing racial or
ethnic origin, political opinions, religious or philosophical beliefs, or trade union
membership, and the Processing of genetic data, biometric data for the purpose of
uniquely identifying a natural person, data concerning health or data concerning a
natural person's sex life or sexual orientation;
 
“Site” means http://www.ICONcl.com/ and all web pages hosted at that domain (such as
the “career” page at http://www.ICONcl.com/careers.html).
 
3. Processing of Your Personal Information
Depending on your interaction with us, your Personal Information may be Processed as
follows:
 
(i) Your Information – Declaration of Consent
As part of our Services, we specialize in the structuring of business and Commercial
Real Estate (CRE) financial solutions on behalf of our clients, including by using
machine learning and/or artificial intelligence tools to produce insights and financing
solutions based on data held by (or available to) ICON (“Client Services”).
In the event you are interested in working with ICON as a client or a career with ICON,
you can provide us with information on your personal and professional background
(“Information”) that we will, subject to our sole discretion, take into consideration as part
of the Client Services. For example, you may provide this information directly to one of
our consultants or upload your Info through our Site.
 
Providing any Information is purely voluntary on your part. Although it is generally true
that, the more information you share with us, the better we are able to assess your
potential qualification and suitability for various financing solutions or open career
positions, we urge you not to disclose to us any Information that is likely of little or no
relevance or may not even be legally considered as part of common loan underwriting
or hiring processes. This applies, in particular, to Sensitive Personal Information.
 
Your Information will mainly be Processed by and on behalf of ICON. However,
depending on how and where the Client Services need to be performed in your
individual case, your Information might, in addition, be Processed by and on behalf of
our affiliated companies (the “ICON Network”) or by selected partners with whom we
may work with. Your Information Processed by ICON and/or other companies of the
ICON Network might contain (a) your contact details (name, address, phone number,

email address, etc.), (b) your business data, (c) information on your business activities
and/or customers, and (d) your business licensing, professional certificates, etc. 
 
Your Information may be shared with third parties as follows:
· Your Information will be stored in databases located the United States. The servers
hosting the databases are operated by and accessible to members of the ICON
Network or third-party service providers, acting on their behalf and as per their
instruction in order to operate the servers. Physical support of the servers is provided by
GoDaddy Operating Company LLC;
· Via the databases, your Information will be available to the consultants and
administrative staff of the different companies in the ICON Network for the purposes of
providing the Client Services;
· Subject to our discretion, we might disclose excerpts of your Information such as your
professional education and employment history with particular clients in order to confirm
whether they might be interested in you as a Client with respect to an opening for an
executive or similar management position they have informed us of. The information
disclosed will be limited to what is necessary for this purpose. We will not disclose the
entirety of your Information or otherwise introduce you to any client in detail without first
obtaining separate and specific consent from you.
 
By declaring your consent as set forth below you therefore explicitly and
unambiguously (a) agree that your Information, or parts thereof, may be
disclosed or otherwise transferred, as described above, to recipients in countries
that may provide different, less or even inadequate protection of personal data as
compared to the standards applicable in the jurisdiction you reside or work in or
you contact us from, and (b) waive protection according to such standards with
respect to the information so disclosed or transferred.
 
As part of the Client Services, your Information may be Processed for the purposes of: 
(a) evaluating and underwriting your company and its principals for potential financing,
(b) assessing your company’s suitability for various financing opportunities,
(c) informing you of available financing solutions potentially suitable for you,
(d) sending you information or materials that we believe you may find interesting, such
as reports, research, invitations to networking events, or information regarding our
Services, publications and surveys,
(f) introducing you to our capital partners/investors/funders,
(f) verifying your business Information, personal credentials, professional diplomas and
certificates,
(h) performing searches for information on your personal and professional life publicly
available via social media services (e.g. Facebook, Google, LinkedIn, Twitter, etc.), on
the Internet or within data you have previously disclosed to us, provided that such
information might be of importance to your qualification for particular financing,
(i) operating the databases your Information is stored in, or

 

At no point will your Information be used for purposes other than providing Client
Services. Your Client Data will be Processed until you revoke your declaration of
consent given when sharing Client Data with us. Upon the revocation of your
declaration of consent, we will delete your Client Data from all databases.
 
We will retain your Personal Information where we have an ongoing consent or
legitimate business need to do so (for example, to provide you with our services or to
show we are compliant with applicable laws).
 
By sharing your Information with us, you explicitly consent to the Processing of
your Information, including any Sensitive Personal Information you might choose
to disclose to us, as described above. This may include, without limitation, the
transfer of your Information, or parts thereof, to countries not providing an
adequate level of protection of personal data. You acknowledge that you are
under no obligation to provide your consent and that, if you choose to do so
nonetheless, you may revoke your declaration of consent (including to specific
aspects of our processing) at any time with future effect by using the following
contact details: ICONprojects@protonmail.com.
 
Sections (ii) to (iv) (inclusive) apply to the extent you are using our Site:
 
(ii) Cookies
Our Site makes use of cookies. Cookies are small text files downloaded by your Internet
browser and stored on the device you use to access the Site (e.g., your desktop
computer, tablet or smartphone). Depending on their purpose, cookies log specific user-
related information such as your user preferences, authentication information, security
parameters, data concerning the device you access the Site with and statistical
information regarding your use of the Site. 
 
Where necessary during your visit of the Site or when revisiting the Site, your Internet
browser transmits the cookies including the contained information back to the servers
they were initially downloaded from. The analysis and Processing of such information
allows us to ensure the functionality of the Site, improve your online experience and
optimize the structure and content of the Site.
 
The cookies we use can be categorized as follows:
· Session Cookies: These are cookies that allow our Site to collect information about
what you do during a browsing session each time you visit the Site. When connecting to
our server, your device will be allocated a session ID, which enables our server to
identify your device during the session and facilitates Site usability. These cookies are
temporary and are set to be deleted when you leave the Site;
· Persistent Cookies: These are cookies that are stored by your Internet browser for
more than a session and are set to expire within a defined time period. Persistent
cookies enable us to remember your settings and information, so you do not have to
keep re-entering them whenever you visit our Site. They also measure how you use and

interact with the Site and enable us to personalize the Site. For example, they may
allow us to alter the rotation of images on the Site so that different images will be
displayed on your next visit;
· First-Party Cookies: These are cookies that we store and access on your device in
our capacity as controller of your Personal Information when you visit our Site. They
might include cookies related to third-party service providers, provided that we control
and determine the purposes and means of the Processing of your Personal Information
logged by such cookies. As a result, first-party cookies might log user-related Personal
Information accessible to and Processed by third parties on our behalf and subject to
our instructions.
· Third-Party Cookies: These are cookies that are stored and accessed on your device
by third parties determining the purposes and means of the Processing of your Personal
Information logged by such cookies.
You may influence the scope and extent to which we use cookies when you visit our
Site. In particular, you may prevent cookies from being stored on your device by
adjusting the respective settings on your Internet browser. For more information on how
to do so in the settings of your particular Internet browser, please see the following
information:
· Internet Explorer: https://privacy.microsoft.com/en-us/internet-explorer-ie11-
preview-privacy-statement
· Chrome: https://www.google.com/intl/en/chrome/browser/privacy/
· Firefox: https://support.mozilla.org/en-US/products/firefox/protect-your-privacy
· Safari: http://www.apple.com/privacy/manage-your-privacy/
 
Please be aware that this might render certain functions of our Site inoperable or more
difficult to use. Depending on the Internet browser you use, you might also be able to
specifically reject third-party cookies. In this context, please note, however, that third
parties might still have access to your Personal Information to the extent that such
information is logged by first-party cookies.
 
For additional information on first-party and third-party cookies used on our Site in the
context of third-party services and for information on how you might stop such cookies
from being stored on your device, please see “Third-Party Services” below.
 
(iii) Third-Party Services
On our Site, we use the following services provided by third parties:
· Google Analytics Our Site uses Google Analytics, a web analytics service provided
by Google, Inc., located at 1600 Amphitheatre Parkway, Mountain View, CA 94043,
USA (“Google”). Google Analytics uses “cookies”, which are text files placed on your
computer, to help analyze how users use the Site. The information generated by the
cookies about your use of the Site (including your IP address) will be transmitted to and
stored by Google on servers in the United States. On our behalf, Google will use the
information collected for the purpose of evaluating your use of the Site, compiling
reports on website activity for us and providing other services relating to website activity

and Internet usage to us. Google will not associate your IP address with any other data
held by Google. Neither will we match, link or otherwise connect any information
received from Google with Personal Information collected through other components of
the Site. You may refuse the use of cookies by selecting the appropriate settings on
your Internet browser. However, please note that if you do this, you may not be able to
use the full functionality of our Site. 
 
Furthermore, you can prevent Google’s collection and use of data (cookies and IP
address) by downloading and installing the browser plug-in available
under https://tools.google.com/dlpage/gaoptout?hl=en-US Further information
concerning the terms and conditions of use and data privacy can be found
at http://www.google.com/analytics/terms/gb.html or
at https://www.google.de/us/policies/ 
 
Additionally, we use the following Social Media Platform Cookies, all intended to
facilitate linking and following by or from the respective platforms:
· Facebook 1, Hacker Way, Menlo Park, CA 94025, USA
· LinkedIn 2029 Stierlin Ct. Ste. 200, Mountain View, CA 94043, USA
· Twitter 1355 Market Street, San Francisco, CA 94103, USA
 
In addition to the above, you can manage the cookies of various third-party service
providers by setting respective opt-out cookies
on http://www.aboutads.info/choices/ or http://www.youronlinechoices.com/uk/yo
ur-ad-choices.
 
(iv) Do-Not-Track Disclosure
Laws such as California Business and Professions Code § 22575 require us to disclose
how our Site responds to Internet browser “Do Not Track” signals and/or other
mechanisms that seek to provide consumers with the ability to control the collection of
their Personal Information through online tracking for certain purposes, such as targeted
or behavioral advertising.
 
Please note that we do not use Personal Information collected on our Site through
cookies or other technologies for targeted or behavioral advertising. If your Internet
browser gives our Site a “Do Not Track” signal, the Site may not honor it to the extent
that the Site uses cookies or other tracking technologies as described in “Cookies” or
“Third-Party Services” above. 
 
We do not make any promises or guarantees about the effects of any “Do Not Track”
signal we receive from your Internet browser because (a) the “Do Not Track” technology
is not necessarily effective for any or all Internet browsers, mechanisms or technologies,
(b) third parties we cooperate with may not honor your “Do Not Track” signal; and (c)
technologies, Internet browsers and access devices may change from time to time and
efforts to honor your “Do Not Track” signal might or might not be effective for each
technology or across all platforms.

 

However, in “Cookies” and “Third-Party Services” above, we describe how you may use
mechanisms similar to the “Do Not Track” technology of certain Internet browsers in
order to effectively prevent us or third parties from collecting your Personal Information
through online tracking. To the extent that you make use of these mechanisms, your
preference not to be tracked or to be tracked only to a limited extent will be honored by
us and the third parties providing services to us.
 
(v) Personal Information Pertaining to Children
Our Services are not intended to be used by minors and we do not want to collect
information from minors. If a child’s parent or a guardian believes their child may have
provided Personal Information to us, please write us using the contact details provided
in “How to Contact Us” below and we will delete that Personal Information, subject to
the applicable law and this Policy.
 
4. Data Security
Protecting your Personal Information is important to us. We use appropriate technical
and organizational measures and safeguards designed to help prevent unauthorized
access, unlawful Processing, and unauthorized or accidental loss of your Personal
Information. 
 
5. Your Right to Information
Subject to the applicable law, you have the right to: (a) obtain information about your
Personal Information we Process;(b) to request the correction or completion of incorrect
Personal Information we Process; (c) to request the deletion of Personal Information we
Process; (d) to object to our Processing of your Personal Information or to Restrict the
way we Process such Information; and (e) to request to receive Personal Information in
a structured, commonly used and machine-readable format and to ask us to transmit
that Information to you or directly to a third party. To make a respective request, please
use the contact details provided in “How to Contact Us” below.
 
6. Amendments to This Policy
From time to time we may change our business activities and/or our policies and
procedures with respect to the Processing of Personal Information. Where appropriate
in these cases, we will, subject to applicable law, revise, supplement, or replace this
Policy. When the Policy changes, we will post the substitute version and change the
effective date listed at the beginning of the Policy. When required by applicable law,
however, we may provide you with advance notice of any changes to this Policy and
with an opportunity to object to such changes. 
 
If you exercise your right to object, the changes will not become effective with respect to
your Personal Information, but your ability to use our Services may be terminated or
impaired. We will explicitly notify you of the consequences of the objection or non-
objection to the extent and in the manner required by law.
 
7. How to Contact Us

We encourage your questions and comments about this Policy and our privacy
practices. Please contact us using the information below, and we will respond to you as
soon as reasonably possible:
 
ICON Commercial Lending Inc
99 Wall Street #3350,
New York City, New York 10005  USA
Email: ICONprojects@protonmail.com

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ICON Commercial Lending Inc
www.ICONCL.com

International Headquarters:
99 Wall Street, Suite 3350,
New York, NY 10005

United States

Office Direct:
Toll Free: 1-888-850-ICON (4266)
iconcl@protonmail.com

Copyright © 2020 by ICON Commercial Lending Inc      All Rights Reserved