Privacy Policy

1. Overview & Scope

Union Capital Lending LLC ("Union Capital," "we," "us," or "our") is committed to protecting the privacy and security of your personal and financial information. This Privacy Policy ("Policy") describes how we collect, use, disclose, and safeguard information in connection with your use of our website at unioncapitallending.com (the "Site"), our mobile applications, our loan products, and all related services (collectively, the "Services").

This Policy applies to all individuals who visit our Site, submit a loan inquiry or application, or enter into a loan agreement with us, including prospective borrowers, current borrowers, and former borrowers. It does not apply to information collected offline (other than loan application data) or to third-party websites linked from our Site.

This Policy is incorporated into and subject to our Terms of Service. By using our Services, you consent to the practices described in this Policy. If you do not agree with this Policy, please do not use our Services.

2. Information We Collect

We collect several categories of information in connection with your use of our Services:

2.1 Personal Identification Information

• Full legal name, date of birth, and Social Security Number (SSN) or Individual Taxpayer Identification Number (ITIN)
• Government-issued photo identification (driver's license, passport, state ID)
• Email address, mailing address, phone numbers
• Marital status and number of dependents (optional; used for income calculation)

2.2 Financial Information

• Income information (gross monthly income, income sources, employer information)
• Bank account and routing numbers (for disbursement and AutoPay enrollment)
• Assets and liabilities, including existing debts and monthly obligations
• Property information and estimated value (for mortgage and home equity products)
• Business financial statements, tax returns, and bank statements (for business loan products)

2.3 Credit Information

• Credit reports obtained from Equifax, Experian, TransUnion, and/or other consumer reporting agencies
• Credit scores and related factors
• Payment history on existing accounts
• Public records (bankruptcies, judgments, liens)

2.4 Transaction & Account Information

• Loan application data, approval decisions, and loan terms
• Payment history on your Union Capital loan(s)
• Customer service interactions and correspondence
• Complaints and disputes

2.5 Technical & Usage Information

• IP address, browser type, device type, and operating system
• Pages visited, time spent, links clicked, and referral URLs
• Cookie and tracking pixel data (see Section 7)
• Location data (city/state level, derived from IP address)

2.6 Communications

• Emails, chat messages, and other communications you send us
• Recorded phone calls (we record calls for quality assurance and compliance purposes; you will be notified at the start of any recorded call)

3. How We Collect Information

3.1 Directly From You

We collect information you voluntarily provide when you: complete a pre-qualification or loan application; create or log into a borrower account; contact our customer service team; submit a contact form on our Site; or enroll in newsletters or promotional communications.

3.2 Automatically

When you visit our Site, we automatically collect certain technical information through cookies, web beacons, pixel tags, log files, and similar technologies. This data helps us understand how visitors use our Site, improve our services, and personalize your experience.

3.3 From Third Parties

We may receive information about you from:

• Consumer Reporting Agencies: Credit reports, scores, and related data from Equifax, Experian, and TransUnion;
• Identity Verification Services: Data to verify your identity and prevent fraud;
• Employment & Income Verification: Payroll data providers (e.g., The Work Number by Equifax) to verify employment and income;
• Public Records Databases: Property records, lien information, and court records;
• Lead Generation Partners: If you submitted a loan inquiry through a partner site, we may receive your contact information from that partner;
• Social Media Platforms: If you interact with our social media profiles or connect an account, we may receive limited profile information.

4. How We Use Your Information

We use your information for the following purposes:

4.1 Loan Processing & Servicing

• Evaluate and process your loan application;
• Verify your identity, income, employment, and creditworthiness;
• Underwrite, approve, or decline your application;
• Disburse loan funds and process repayments;
• Service your account, including managing payment schedules and handling inquiries;
• Report your payment history to consumer reporting agencies.

4.2 Legal & Regulatory Compliance

• Comply with applicable federal and state laws and regulations;
• Respond to lawful requests from courts, government agencies, and law enforcement;
• Fulfill our obligations under anti-money laundering (AML) and Bank Secrecy Act (BSA) requirements, including identity verification;
• Detect, prevent, and investigate fraud, identity theft, and other illegal activity.

4.3 Business Operations

• Improve and develop our products, services, and website;
• Conduct data analysis and research to enhance our lending models;
• Manage risk across our loan portfolio;
• Facilitate corporate transactions (e.g., sale of loan portfolios, mergers, or acquisitions).

4.4 Marketing & Communications

• Send you information about products and services that may interest you, subject to your communication preferences;
• Send transactional communications (e.g., application status updates, payment reminders, account alerts) — these are not subject to opt-out as they are required for loan servicing;
• Display relevant advertisements on our Site and third-party platforms (see Section 7).

You may opt out of marketing communications at any time by clicking "Unsubscribe" in any marketing email or by contacting us at info@unioncapitallending.com.

5. Sharing Your Information

We do not sell your personal information to unaffiliated third parties for their own marketing purposes. We may share your information in the following circumstances:

5.1 Affiliates

We may share information with our affiliated companies for everyday business purposes and, to the extent permitted by law, for marketing of our financial products. You have the right to opt out of affiliate marketing sharing — see Section 10 for instructions.

5.2 Service Providers

We share information with trusted third-party vendors who perform services on our behalf, including:

• Identity verification and fraud prevention services;
• Credit reporting agencies and data analytics providers;
• Payment processors and ACH network providers;
• Cloud storage and IT infrastructure providers;
• Email and SMS communication platforms;
• Loan servicing platforms and document management systems;
• Legal, accounting, and audit firms.

All service providers are contractually obligated to use your information only for the services they provide to us and to maintain appropriate security standards.

5.3 Loan Investors & Purchasers

We may sell, assign, or transfer your loan to an investor, loan servicer, or secondary market purchaser (e.g., Fannie Mae, Freddie Mac, or private investors). In such cases, we will transfer your loan file, including personal and financial information, to the new holder. You will be notified if your loan servicer changes.

5.4 Legal Requirements

We will disclose your information when required by law, court order, subpoena, or governmental authority, or when we believe disclosure is necessary to: (a) comply with a legal obligation; (b) protect and defend our rights or property; (c) prevent fraud or illegal activity; or (d) protect the personal safety of our employees, customers, or the public.

5.5 Business Transfers

If Union Capital Lending is involved in a merger, acquisition, asset sale, or bankruptcy proceeding, your information may be transferred as part of that transaction. We will notify you via email or a prominent notice on our Site before your information becomes subject to a materially different privacy policy.

5.6 With Your Consent

We may share information with third parties when you have given your explicit consent to do so, such as when you authorize us to share data with a mortgage broker or financial planner of your choosing.

6. Credit Reporting

Union Capital Lending reports borrower payment information to the major consumer credit reporting agencies — Equifax, Experian, and TransUnion — on a monthly basis. This includes your account opening date, credit limit or loan amount, current balance, payment status, and any delinquencies.

Accurate positive reporting can help build your credit history. Late payments or defaults reported to consumer reporting agencies may significantly harm your credit score. You have the right to dispute inaccurate information on your credit report directly with the reporting agency or by contacting us.

We comply fully with the Fair Credit Reporting Act (FCRA) and its implementing regulations in all aspects of our credit reporting practices.

7. Cookies & Tracking Technologies

7.1 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the Site to function (e.g., session management, security). Cannot be disabled.
• Functional Cookies: Remember your preferences (e.g., language, region, saved calculator inputs) to personalize your experience.
• Analytics Cookies: Help us understand how visitors use our Site (e.g., Google Analytics, Hotjar). We use this data in aggregate to improve the Site.
• Advertising/Targeting Cookies: Track browsing activity to deliver relevant advertisements on third-party platforms (e.g., Google Ads, Meta Pixel). We use conversion tracking to measure the effectiveness of our advertising campaigns.

7.2 Managing Cookies

You can control cookies through your browser settings. Most browsers allow you to refuse all cookies, accept cookies from specific sites, or delete cookies. Disabling cookies may impact certain features of our Site, including your ability to log in to the borrower portal or use the loan calculator. You may also opt out of interest-based advertising by visiting:

• Network Advertising Initiative: optout.networkadvertising.org
• Digital Advertising Alliance: optout.aboutads.info
• Google Analytics Opt-Out: tools.google.com/dlpage/gaoptout

7.3 Do Not Track

Our Site does not currently respond to "Do Not Track" (DNT) browser signals. We will update this Policy if our practices change. California residents have the right to know whether we honor DNT signals — we currently do not.

8. Data Security

We take the security of your personal and financial information seriously. We implement and maintain a comprehensive information security program that includes:

• Encryption: All data transmitted between your browser and our servers is protected using TLS 1.2 or higher (HTTPS). Sensitive data at rest is encrypted using AES-256 encryption;
• Access Controls: Access to your data is restricted to authorized personnel with a legitimate business need. We use role-based access control (RBAC) and the principle of least privilege;
• Multi-Factor Authentication (MFA): Required for all employees accessing systems that contain customer data. Offered to customers for borrower portal access;
• Network Security: Firewalls, intrusion detection/prevention systems, and regular penetration testing;
• Vendor Management: All third-party service providers are assessed for security compliance and subject to data processing agreements;
• Incident Response: We maintain a documented data breach response plan. In the event of a breach affecting your personal information, we will notify you as required by applicable state law (typically within 72 hours to 30 days depending on jurisdiction).

While we employ industry-standard security measures, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you believe your account has been compromised, please contact us immediately at (217) 828-7205.

9. Data Retention

We retain your information for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. Specific retention periods include:

• Loan application data (approved loans): 7 years from loan payoff date, as required by federal and state banking regulations;
• Loan application data (declined applications): 25 months from adverse action date, as required under ECOA/Regulation B;
• Mortgage records: Minimum 7 years from loan closing, or longer as required by state law;
• Credit reports obtained: 25 months from date of receipt;
• Customer service records: 3 years from the date of last interaction;
• Website analytics data: 26 months (Google Analytics default);
• Recorded phone calls: 90 days unless subject to a legal hold.

Following the applicable retention period, we securely destroy or anonymize your information in accordance with our data destruction policy.

10. Your Privacy Rights

Depending on your state of residence, you may have the following rights regarding your personal information:

10.1 Right to Access

You have the right to request a copy of the personal information we hold about you. We will respond to verified access requests within 45 days (extendable by an additional 45 days with notice).

10.2 Right to Correct

You have the right to request correction of inaccurate or incomplete personal information. You can update certain information through your borrower portal or by contacting us directly.

10.3 Right to Delete

You may request deletion of your personal information. Note that we may be required to retain certain information to comply with legal obligations, complete transactions, detect fraud, or exercise our legal rights. Deletion requests will not affect information we are legally required to retain.

10.4 Right to Opt Out of Marketing

You may opt out of receiving marketing communications at any time. Transactional and servicing communications (e.g., payment reminders, account statements) cannot be opted out of while you have an active loan.

10.5 Right to Opt Out of Affiliate Sharing

You may instruct us not to share your information with our affiliates for their marketing purposes. To opt out, contact us at info@unioncapitallending.com or call (217) 828-7205.

10.6 Gramm-Leach-Bliley Act (GLBA) Rights

As a customer of a financial institution, you have rights under the GLBA regarding the sharing of your "nonpublic personal information" with nonaffiliated third parties. We provide you with the opportunity to opt out of certain such sharing, as described above.

10.7 How to Submit a Rights Request

To exercise any of the above rights, please submit a verifiable request by:

• Email: privacy@unioncapitallending.com
• Phone: (217) 828-7205 (select "Privacy Request" option)
• Mail: Union Capital Lending LLC, Attn: Privacy Officer, 1621 E. 17th St., Suite G, Santa Ana, CA 92705

We will need to verify your identity before processing any request. We will not discriminate against you for exercising your privacy rights.

11. California Privacy Rights (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), grants you additional rights. This section supplements the general rights in Section 10.

Categories of Personal Information Collected (Last 12 Months)

California-Specific Rights

• Right to Know: Categories and specific pieces of personal information collected, used, disclosed, and sold;
• Right to Delete: As described in Section 10.3, subject to exceptions;
• Right to Correct: Inaccurate personal information;
• Right to Opt Out of Sale/Sharing: See Section 13;
• Right to Limit Use of Sensitive Personal Information: You may limit our use of sensitive information to necessary purposes;
• Right to Non-Discrimination: We will not discriminate against you for exercising CCPA rights.

California residents may submit requests via email at privacy@unioncapitallending.com or by calling (217) 828-7205. We will respond within 45 days.

Note: The CCPA/CPRA contains an exemption for information subject to the Gramm-Leach-Bliley Act (GLBA). Much of the personal information we collect in connection with your loan is GLBA-covered and therefore may be exempt from certain CCPA rights. We will process all requests in good faith and inform you if an exemption applies.

12. Children's Privacy

Our Services are intended for adults aged 18 and older. We do not knowingly collect, use, or disclose personal information from individuals under the age of 18. If we discover that we have inadvertently collected information from a minor, we will promptly delete it. If you believe we have collected information from a child under 18, please contact us at privacy@unioncapitallending.com.

13. Do Not Sell or Share My Information

Union Capital Lending does not sell your personal information to unaffiliated third parties for monetary consideration. However, our use of advertising cookies and pixels may constitute "sharing" personal information for cross-context behavioral advertising under the CCPA/CPRA definition.

California residents and residents of other states with applicable opt-out rights may opt out of the "sharing" of personal information for targeted advertising purposes by:

• Emailing: privacy@unioncapitallending.com with subject "Do Not Sell/Share My Info";
• Calling: (217) 828-7205;
• Using an opt-out preference signal (GPC — Global Privacy Control) recognized by your browser — we honor GPC signals.

Opting out of sharing will disable advertising cookies on our Site for your browser. It will not affect your ability to apply for or manage a loan.

14. Updates to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will:

• Update the "Last Updated" date at the top of this Policy;
• Post the revised Policy prominently on our Site;
• For material changes affecting existing customers, send email notification to the address on your account.

We encourage you to review this Policy periodically. Your continued use of our Services following any update constitutes acceptance of the revised Policy.

15. Contact & Complaints

If you have questions or concerns about this Privacy Policy or our data practices, please contact our Privacy Officer:

If you are a California resident and are not satisfied with our response to a privacy rights request, you may file a complaint with the California Privacy Protection Agency (CPPA) at cppa.ca.gov.