Wellrogo — Alternative Real Estate Funding, Investments & Lending Platform

[Effective Date: 07/28/2026]

 

1. Introduction

Wellrogo A business AlignChance Financial, LLC.  ("Wellrogo," "we," "us," or "our") respects your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard information about you when you visit wellrogo.com, create an account, apply for a loan, invest through the Platform, or otherwise interact with us (collectively, the "Platform"). It also describes your privacy rights and how to exercise them.

This Policy applies to visitors, prospective and current borrowers, and prospective and current investors. It does not apply to information we process solely as a processor/service provider on behalf of a third-party lender or issuer, which is governed by that party's own privacy notice.

 

2. Information We Collect

2.1 Information You Provide

• Identity information: name, date of birth, government ID number (e.g., SSN/Tax ID or passport number), address, and copies of identity documents.
• Contact information: email address, phone number, mailing address.
• Financial information: income, net worth, bank account and routing numbers, tax returns, credit history, employment information, and, for investors, accreditation status and supporting documentation (e.g., letters from a CPA, attorney, or broker-dealer, or brokerage statements).
• Transaction information: loan applications, investment subscriptions, amounts, payment history, and communications related to a transaction.
• Account credentials: username and password (stored in encrypted/hashed form).
• Communications: messages you send us via email, chat, or contact forms, and records of customer support interactions.

 

2.2 Information Collected Automatically

• Device and usage data: IP address, browser type, operating system, referring URLs, pages viewed, and timestamps.
• Cookies and similar technologies: as described in Section 6 below.
• Approximate location: derived from your IP address.

 

2.3 Information from Third Parties

• Identity-verification and KYC/AML providers.
• Credit bureaus and consumer reporting agencies (subject to the Fair Credit Reporting Act, where applicable).
• Bank and payment processors, for purposes of funding and disbursing transactions.
• Publicly available sources, such as property and county records relevant to real estate collateral.
• Co-investors, loan guarantors, or business partners you identify to us in connection with a transaction.

 

3. How We Use Information

We use the information we collect to:

• create and administer your account and verify your identity;
• evaluate loan applications and investment eligibility, including accreditation and investment-limit checks;
• process transactions, disbursements, repayments, and distributions;
• comply with legal and regulatory obligations, including AML/KYC, OFAC sanctions screening, tax reporting (e.g., Form 1099), and securities recordkeeping requirements;
• communicate with you about your account, transactions, and, where you have consented, marketing;
• detect, investigate, and prevent fraud, security incidents, and other unlawful activity;
• maintain and improve the Platform, including analytics and troubleshooting;
• enforce our Terms of Use and protect our legal rights.

 

4. Legal Bases for Processing (EU/UK Users)

If you are located in the European Economic Area (EEA) or United Kingdom, we process your personal data on the following legal bases under the GDPR/UK GDPR:

• Contract: processing necessary to perform a loan, investment, or account agreement with you.
• Legal obligation: processing necessary to comply with AML/KYC, tax, and securities laws.
• Legitimate interests: processing for fraud prevention, platform security, and service improvement, balanced against your rights and interests.
• Consent: for optional marketing communications and non-essential cookies, which you may withdraw at any time.

 

5. How We Share Information

We do not sell your personal information for money. We may disclose information to:

• Lending partners and issuers: third-party lenders, loan servicers, or investment issuers involved in a specific transaction you apply for or invest in;
• Service providers: identity-verification vendors, payment processors, cloud hosting providers, customer support tools, and analytics providers, under contractual confidentiality and data-protection obligations;
• Credit bureaus and consumer reporting agencies, in connection with loan applications;
• Professional advisors: our attorneys, accountants, auditors, and regulators, as needed;
• Regulators and law enforcement: where required by law, subpoena, court order, or to protect the rights, property, or safety of Wellrogo, our users, or others;
• Corporate transactions: an acquirer or successor in the event of a merger, acquisition, financing, or sale of assets;
• With your consent or direction, such as when you choose to share your information with a co-investor or partner.

 

6. Cookies and Tracking Technologies

We and our service providers use cookies, web beacons, and similar technologies to operate the Platform, remember your preferences, analyze usage, and, where permitted, support marketing. Categories include:

• Strictly necessary cookies, required for login and core functionality;
• Analytics cookies, to understand how users interact with the Platform;
• Marketing/advertising cookies, used only where you have provided consent (e.g., via a cookie banner for EU/UK visitors).

You can control cookies through your browser settings and, where offered, our cookie consent tool. Disabling certain cookies may limit Platform functionality.

 

7. Data Retention

We retain personal information for as long as necessary to provide the Platform, complete the purposes described in this Policy, and comply with legal, tax, accounting, and securities recordkeeping obligations (which, for financial and investment records, commonly require retention of five to seven years or longer after the end of a relationship, depending on applicable law). We may retain and use information as necessary to resolve disputes and enforce our agreements.

 

8. Data Security

We implement administrative, technical, and physical safeguards designed to protect personal information, including encryption in transit, access controls, and employee confidentiality obligations, consistent with the safeguards expected under the GLBA Safeguards Rule and comparable state requirements. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

 

9. Your Privacy Rights

9.1 U.S. State Privacy Rights (e.g., California, Colorado, Virginia, and similar states)

Subject to applicable exemptions (including exemptions commonly available for information already regulated under the GLBA or FCRA), you may have the right to:

• know/access the categories and specific pieces of personal information we hold about you;
• request correction of inaccurate personal information;
• request deletion of your personal information;
• opt out of the sale or sharing of personal information for cross-context behavioral advertising (Wellrogo does not sell personal information as defined by these laws);
• non-discrimination for exercising your privacy rights.

To exercise these rights, contact us using the information in Section 13. We will verify your identity before fulfilling your request.

 

9.2 EEA/UK Rights (GDPR/UK GDPR)

If you are located in the EEA or UK, you may have the right to access, rectify, erase, or restrict processing of your personal data; to data portability; to object to processing based on legitimate interests or for direct marketing; and to withdraw consent at any time without affecting the lawfulness of processing before withdrawal. You also have the right to lodge a complaint with your local data protection supervisory authority.

 

9.3 Marketing Preferences

You may opt out of marketing emails at any time using the unsubscribe link in those emails. You cannot opt out of transactional or legally required communications related to your account or transactions.

 

10. International Data Transfers

Wellrogo.com A business of AlignChance Financial, LLC is based in the United States, and personal information we collect may be transferred to, stored, and processed in the United States or other countries that may not have data protection laws equivalent to those in your home jurisdiction. Where we transfer personal data from the EEA or UK to the United States or another country, we rely on appropriate safeguards, such as the European Commission's Standard Contractual Clauses (and, where applicable, the UK International Data Transfer Addendum), or another lawful transfer mechanism.

 

11. Children's Privacy

The Platform is not directed to individuals under 18, and we do not knowingly collect personal information from children. If we learn we have collected personal information from a child under 18, we will take steps to delete it.

 

12. Third-Party Links and Services

The Platform may link to or integrate with third-party websites and services, including lending partners, issuers, and identity-verification providers. This Policy does not apply to those third parties' practices, and we encourage you to review their privacy notices.

 

13. Contact Us

For questions about this Privacy Policy or to exercise your privacy rights, contact:

Wellrogo

Attn: Privacy Officer

Email: info@wellrogo.com

 

14. Changes to This Policy

We may update this Privacy Policy from time to time. We will post the updated version on the Platform and revise the "Effective Date" above. For material changes, we will provide additional notice as required by applicable law (such as email notice or prominent notice on the Platform).