Privacy Policy &
Data Protection Protocol

Fitzgerald Debt Exchange, LLC Last Updated: November 25, 2025

1. Introduction

Fitzgerald Debt Exchange, LLC (dba "Fitzgerald Advisors") is committed to maintaining the confidentiality and security of the sensitive financial data entrusted to us. This Privacy Policy outlines the protocols we employ to collect, utilize, and safeguard personal and commercial information in the execution of debt portfolio valuations and divestitures.

2. Information Collection

We collect information necessary to execute our advisory mandates and ensure regulatory compliance. This includes:

• Client Data: Name, corporate entity details, contact information, and verification documents required for Know Your Customer (KYC) and Anti-Money Laundering (AML) compliance.
• Portfolio Data: Loan tapes, chain-of-title documents, borrower payment histories, and other asset-level data submitted for valuation via our "Debt Catalyst" engine.
• Digital Data: IP addresses and browser data collected via cookies to optimize website performance and security.

3. Use of Information

We utilize your data strictly for the following purposes:

• To perform portfolio valuations, stratifications, and "Pre-Market" assessments.
• To execute Private Treaty transactions between verified Buyers and Sellers.
• To communicate strategic opportunities, market intelligence, and transaction updates.
• To comply with federal and state regulatory requirements (CFPB, SEC, etc.).

4. Sharing & Disclosure

Fitzgerald Advisors does not sell, rent, or trade client data to data brokers or marketing agencies. We disclose information only in specific scenarios:

• Transaction Counterparties: Asset-level data is shared with vetted institutional buyers or sellers strictly under a Non-Disclosure Agreement (NDA) for the purpose of a transaction.
• Service Providers: We may utilize trusted third-party vendors for secure data hosting, encryption, or CRM services.
• Legal Compliance: We may disclose information if required by law, subpoena, or to protect the rights and safety of our firm and its clients.

5. Data Security

We employ enterprise-grade security protocols to protect your information. This includes encryption of data in transit and at rest, strict access controls, and firewalls. While we utilize industry-standard safeguards, no digital transmission is entirely impenetrable; clients transmit data at their own risk.

6. Cookies & Tracking

Our website utilizes cookies to enhance user experience and analyze traffic patterns. You may disable cookies through your browser settings; however, this may limit your access to certain secure areas of our platform.

7. Policy Updates

We reserve the right to amend this Privacy Policy to reflect changes in regulatory landscapes or business operations. Updates will be posted immediately to this page.

8. Contact & Compliance