Privacy Policy
9TH & CLINTON, LLC
Effective Date: August 31, 20269th & Clinton (“9th & Clinton,” “the Firm,” “we,” “us,” or “our”) is a national consulting firm that partners with financial institutions, developers, community-based organizations, impact investors, and municipalities to design and implement creative financial solutions that expand capital access and strengthen local economies, including New Markets Tax Credits, Social Impact Funds, and Community Development Financial Institution (CDFI) lending and investment support. This Privacy Policy explains how we collect, use, disclose, and safeguard information in connection with our website, our consulting engagements, and our other business activities.Please read this Policy carefully. By using our website or engaging our services, you acknowledge the practices described here. If you do not agree with this Policy, please do not use our website or share personal information with us.1. Information We CollectWe collect information in the following ways:1.1 Information You Provide DirectlyContact and inquiry information: name, title, organization, email address, phone number, mailing address, and the content of any message you send us through our website, email, or in person.Client and partner engagement information: information provided by financial institutions, developers, community-based organizations, impact investors, municipalities, developers and CDFIs in the course of an engagement, including organizational, financial, transactional project-related information or training materials necessary to structure or evaluate New Markets Tax Credit efforts, Social Impact Fund arrangements, CDFI lending or investment activity, and related community and economic development platforms.Professional and business information: resumes, professional biographies, business profiles, pitch decks and related information submitted by prospective employees, consultants, or subcontractors.Event and communications information: information you provide when registering for a webinar, subscribing to a newsletter, or requesting materials.1.2 Information Collected AutomaticallyWhen you visit our website, we and our service providers may automatically collect certain technical information, including:• IP address, browser type, device type, and operating system• Pages viewed, time spent on pages, referring/exit pages, and click patterns• Approximate geographic location derived from IP address• Information collected through cookies and similar tracking technologies (see Section 5)1.3 Information From Other SourcesWe may receive information about you or your organization from third parties, including business partners, publicly available sources, industry databases, referral sources, and government or regulatory filings relevant to community development finance, in each case consistent with applicable law.2. How We Use InformationWe use the information we collect for purposes that include:• Providing, managing, and improving our consulting services, including structuring and administering New Markets Tax Credit transactions, Social Impact Fund programs, and CDFI lending and investment arrangements• Communicating with clients, partners, and prospective clients about engagements, proposals, and business opportunities• Conducting due diligence, underwriting, compliance, and reporting activities required by our clients, funders, investors, or applicable regulators• Operating, maintaining, and improving our website and understanding how it is used• Recruiting and evaluating prospective employees, consultants, and subcontractors• Complying with legal, regulatory, contractual, and audit obligations, including anti-money-laundering, know-your-customer, and community development finance reporting requirements• Protecting the rights, property, and safety of 9th & Clinton, our clients, our partners, and others3. How We Share InformationWe do not sell personal information. We may share information as follows:With clients and partners: in connection with a specific engagement, we may share relevant information among the financial institutions, developers, community organizations, impact investors, municipalities, and CDFIs participating in that transaction, as necessary to structure, close, and administer it.With subcontractors and service providers: we engage third parties to perform professional services (e.g., project support, legal, accounting), who are authorized to use such information only as needed to provide those services.With regulators and government entities: where required for compliance, reporting, or oversight purposes related to New Markets Tax Credits, CDFI activity, or other regulated community development finance programs.For legal reasons: to comply with applicable law, regulation, legal process, or governmental request, or to protect the rights, property, or safety of 9th & Clinton, our clients, or others.4. Data SecurityWe maintain administrative, technical, and physical safeguards designed to protect the confidentiality, integrity, and availability of the information we handle, including information relating to sensitive financial transactions. These safeguards include access controls, encryption in transit where appropriate, and confidentiality obligations with employees and service providers. No system, however, can guarantee absolute security, and we cannot warrant that information will be free from unauthorized access, loss, misuse, or alteration.5. Cookies and Tracking TechnologiesOur website may use cookies, web beacons, and similar technologies to operate the site, remember preferences, and understand how visitors use our content. These may include:• Essential cookies necessary for the website to function• Analytics cookies that help us understand site usage and improve our content• Functional cookies that remember choices you make on the siteMost browsers allow you to block or delete cookies through their settings. Disabling cookies may affect the functionality of our website.6. Data RetentionWe retain personal and engagement information for as long as necessary to fulfill the purposes described in this Policy, including to satisfy contractual, legal, tax, accounting, audit, and community development finance regulatory requirements applicable to New Markets Tax Credit, CDFI, and Social Impact Fund engagements, after which we securely delete or de-identify it.7. Your Choices and RightsDepending on your location and relationship with us, you may have rights to access, correct, update, or request deletion of personal information we hold about you, to object to or restrict certain processing, or to receive a copy of your information in a portable format, subject to applicable law and any exceptions related to our recordkeeping and regulatory obligations.If you are located in the European Economic Area, United Kingdom, or a U.S. state with a comprehensive privacy law, you may have additional rights under applicable law. To exercise any of these rights, please contact us as described in Section 10.8. Third-Party LinksOur website may contain links to third-party websites or resources, such as those of client organizations, government agencies, or industry partners. We are not responsible for the privacy practices or content of those third parties, and we encourage you to review their privacy policies before providing information to them.9. Children's PrivacyOur website and services are directed to businesses, institutions, and professional audiences and are not intended for individuals under the age of 18. We do not knowingly collect personal information from children.10. Contact UsIf you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:9th & ClintonAttn: Privacy InquiriesEmail: gnisbeth@9thclinton.com3465 Rockway AvenueAnnapolis, MD 2140311. Changes to This PolicyWe may update this Privacy Policy from time to time to reflect changes in our practices, services, or applicable law. We will post the revised Policy on our website with an updated effective date. Your continued use of our website or services after any changes take effect constitutes acceptance of the revised Policy.