Privacy Policy

Last Updated: September 7, 2026

1. Information We Collect

Information You Provide

When your account is created, or when you use platform features, we may collect:

• Name and email address
• Role (member or admin)
• Self-reported income and production figures you enter into Pathfinder
• Loan comparison data you upload through Vessel, which may include a client's name, property address, purchase price, loan amount, lender name, and loan terms
• Any other information you choose to share with us

Information Collected Automatically

When you use the platform, we automatically collect basic technical information such as browser type, device information, and general usage activity, to operate and maintain the Services.

Information We Do Not Collect

BrokerFuel does not collect, store, or process any of the following:

• Social Security numbers
• Full financial account numbers or credit/debit card numbers (any direct-subscription payment processing is handled entirely by our third-party payment processor)
• Credit reports or credit scores
• Health or medical information

2. How We Use Your Information

We use the information we collect to:

• Provide and maintain the platform and its features
• Generate the tools you request, such as Pathfinder tracking views and Vessel comparison links
• Send you account-related communications and support messages
• Respond to your requests
• Comply with legal obligations and protect our rights

We do not use your data to train AI models. We do not sell your personal information.

3. Cookies & Tracking

We use basic cookies and similar technologies to keep you signed in and remember your preferences. Disabling cookies may affect some features of the site.

4. Third-Party Services & Subprocessors

Our platform integrates with and relies on the following third-party services to deliver functionality:

• Supabase (via our Lovable Cloud hosting provider) — our database, authentication, file storage, and backend infrastructure. Supabase is SOC 2 Type 2 and ISO 27001 certified, and runs on Amazon Web Services and Google Cloud Platform infrastructure.
• GoHighLevel — our CRM and marketing automation platform. When you're identified as an eligible member in our CRM, GoHighLevel triggers your BrokerFuel account creation. GoHighLevel's own privacy practices govern any data you interact with directly within their platform.
• Zoom — used for our live weekly coaching calls.
• YouTube, Loom, and Descript — used to host and embed coaching video content within lessons. Watching an embedded video may be subject to that platform's own privacy practices.
• A PCI-compliant third-party payment processor, for members on a direct BrokerFuel subscription.

Each of these services maintains its own privacy policy and security practices, which we encourage you to review. We do not engage additional third-party subprocessors for member data beyond those listed above.

5. Data Sharing

We do not sell your personal information. We may share your information in the following situations:

• Service providers: with the trusted third parties listed in Section 4, who help us operate the platform
• Legal requirements: when required by law, regulation, or legal process
• Business transfers: in connection with a merger, acquisition, or sale of assets
• With your consent: when you explicitly agree to share your information

Vessel comparison links are, by design, publicly accessible to anyone who has the link, without requiring a login. This is intentional, so you can share the comparison with your client, but it means the information on that page (your client's name, address, purchase price, loan amount, and quoted terms) is not access-restricted while the link is live. See Section 9 for more on this.

6. Data Security

We take reasonable measures to protect your information, including encryption in transit and at rest, role-based access controls, and secure hosting through Supabase's SOC 2 Type 2 and ISO 27001 certified infrastructure. However, no method of transmission over the internet is 100% secure, and we cannot guarantee absolute security.

7. Data Hosting & Location

All platform data is hosted within the United States through our infrastructure providers. Data does not leave the United States.

8. Data Retention

We retain your account information for as long as your account is active, or as needed to provide you the Services. If your account is closed, we will delete or anonymize your data within 90 days, unless we're required to retain it for legal or legitimate business purposes.

Vessel comparisons are handled differently. Any comparison you generate, including the client information it contains, is automatically and permanently deleted 14 days after creation, regardless of whether your account remains active. Once deleted, this data cannot be recovered. If you need a permanent copy, use the comparison page's print/save option before it expires.

9. A Note on Client Information in Vessel

Vessel lets you upload a spreadsheet containing information about your own client (such as their name, property address, purchase price, and loan terms) to generate a shareable comparison page for that client. A few things are important to understand about how this works:

• You are the one uploading this information, not us collecting it directly from your client. You are responsible for having the appropriate basis and, where applicable, your client's consent to share their information this way.
• The resulting comparison page is public and unauthenticated, meaning anyone with the link can view it, for as long as it remains active.
• The comparison, and all client information within it, is permanently deleted 14 days after creation.
• DIFRNT Coaching is not a financial institution and does not use this data for any purpose beyond generating and temporarily hosting the comparison you requested.

10. Your Rights

You may have the right to:

• Access the personal information we hold about you
• Request correction of inaccurate data
• Request deletion of your data
• Request a copy of your data in a portable format

To exercise any of these rights, contact us at frazier@brokercmo.com. We will respond within 30 days.

11. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), including the right to know what personal information we collect and disclose, the right to request deletion, the right to opt out of the sale or sharing of personal information (we do not sell or share personal information), and the right to non-discrimination for exercising these rights.

To submit a request, contact us at frazier@brokercmo.com. We will verify your identity and respond within 45 days as required by law.

12. Breach Notification

In the event of a confirmed data breach affecting your personal information, we will notify impacted parties within 72 hours of confirmation, and communicate transparently about the nature of the breach and the steps being taken to address it.

13. Children's Privacy

Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us and we will promptly delete it.

14. Changes to This Policy

We may update this Privacy Policy from time to time. When we make changes, we will update the "Last Updated" date at the top of this page. Continued use of the Services after changes are posted constitutes your acceptance of the updated policy.

15. Contact Us

If you have questions about this Privacy Policy or how we handle your data, reach out:

DIFRNT Coaching

Georgia

Email: frazier@brokercmo.com