Carlyle Capital Inc. and its affiliates and subsidiaries (collectively referred to as “Company”, “we”, “us”, and “our”) respect your privacy and are committed to protecting it through our compliance with this privacy policy (“Privacy Policy”). This Privacy Policy describes the types of information we may collect from you or that you may provide when you visit our website www.carlyleloans.com (our “Website“) and our practices for collecting, using, maintaining, protecting, and disclosing that information. Our Website was created to provide information about the Company and our real estate lending services, mobile applications, and related services (the “Services”).

This Privacy Policy applies to information we collect through our Website, Services, and in email, text, and other electronic messages between you and this Website, and when you interact with our advertising and applications on third-party websites and services. It does not apply to information collected by any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.

By accessing or using the Website or Services, you consent to this Privacy Policy, which may change from time to time and without notice to you. If you do not agree with our policies and practices, your choice is not to use our Website. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.

Information We Collect About You and How We Collect It

When you interact with us this through our Website and related Services, we collect several types of information from and about users of our Website. We may collect such information directly from you when you provide it to us, automatically as you navigate through the Website, and from third parties (e.g., our business partners).

The information we collect includes information by which you may be personally identified, such as name, postal address, email address, telephone number, social security number or any other identifier by which you may be contacted online or offline (“Personal Information“). We also collect information about your internet connection, the equipment you use to access our Website, and usage details.

Information You Provide to Us

Information that you provide by filling in forms or applications or submitting inquiries on our Website. This includes information provided at the time of registering to use our Website, subscribing to any of our services, or requesting further services. The information we collect on or through our Website may include:

• - Information that you provide by filling in forms or applications or submitting inquiries on our Website. This includes information provided at the time of registering to use our Website, subscribing to any of our services, or requesting further services.

• - Records and copies of your correspondence (including email addresses), if you contact us.

• - Your responses to surveys that we might ask you to complete for research purposes.

• - Your search queries on the Website.

Information We Collect Through Automatic Data Collection Technologies

Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website. As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including\

• - Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is only statistical data and does not include Personal Information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• - Estimate our audience size and usage patterns.

• - Store information about your preferences, allowing us to customize our Website according to your individual interests.

• - Speed up your searches.

• - Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

• - Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

• - Web Beacons. Pages of the Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Minors

Neither our Website nor our servicers are intended for individuals under the age of 18. We do not knowingly collect personal information from minors. If we learn we have collected or received personal information from a minor, we will delete that information. If you believe we might have any information from or about a minor, please contact us at [email protected] to have the information deleted.

How We Use Your Information

To present our Website and its contents to you. We use information that we collect about you or that you provide to us, including any personal information:

• - To provide you with information, products, or services that you request from us.

• - To fulfill any other purpose for which you provide it.

• - To provide you with notices about your account.

• - To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

• - To notify you about changes to our Website or any products or services we offer or provide though it.

• - To allow you to participate in interactive features on our Website.

• - To contact you about products and services that may be of interest to you.

• - In any other way we may describe when you provide the information.

• - For any other purpose with your consent.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Disclosure of Your Information

We may share your Personal Information with our subsidiaries and affiliates for purposes consistent with our Privacy Policy. We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. In addition, we may disclose personal information that we collect or that you provide to various third parties without notice to you as set forth below:

• - We may also share your Personal Information with contractors, service providers, and other third parties that we use to support our business. For example, we may share your Personal Information with mortgage brokers, title companies, appraisers, insurance companies, purchasers of loans, inspectors, and property preservation providers, among others.

• - In the event of a merger, restructuring, reorganization, or other sale or transfer of some or all of Carlyle Capital Inc.’s assets, your Personal Information may be among the assets transferred.
  

  • Carlyle Capital Inc. may disclose your Personal Information if we believe that we are required to do so (i) to comply with any court order, law, or legal process, including to respond to any government or regulatory request, (ii) to enforce our rights under the Terms of Use and other agreements, including for billing and collection purposes, and (iii) to protect the rights, property or safety of Carlyle Capital Inc., our customers, or the public. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• - Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly. Promotional Offers from the Company: If you do not wish to have your contact information used by the Company to promote our products or services, you can opt-out by clicking on the “unsubscribe” link at the bottom of the e-mail or by emailing [email protected].

California residents may have additional personal information rights and choices. Please see below to check on Your California Privacy Rights and get more information.

E-mail, Phone and Text Messaging (SMS) Policy

Consent to email, phone and text messaging is obtained when customers (including prospective customers) opt-in to our programs by submitting a loan application or inquiry, subscribing to insights or newsletters, or requesting information about the Company’s products or services. Additionally, the Company may use e-mail, phone, and text messaging to contact active customers. The Company does not use SMS for mass-marketing or promotional messaging.

By providing us with a telephone number for a cellular phone or wireless device (including a number that you later convert to a wireless devise number), you expressly consent to receive informational, telemarketing, and advertising communications from us and our service providers. Such communications, include, but are not limited to prerecorded or artificial prerecorded voice message calls, text messages, and communications made by an automatic telephone dialing system. This express consent applies to all telephone numbers and e-mail addresses you provide now and all telephone numbers and e-mail address you provide to us in the future. You understand that you are not required to grant consent as a condition of purchasing any property, goods, or services from the Company. Should you wish to decline to provide such express consent or revoke your consent at any time, you may do so by (i) emailing [email protected], (ii) texting “STOP,” (iii) by following the opt-out instructions in any marketing communication you receive, or (iv) by any other method that reasonably ensures we receive your revocation. You understand that message and data rates may apply. If at any time you need help, you can email [email protected] or text “HELP” to 877-700-1914

We may collect certain information on or through SMS, including name, e-mail, address, and any other information you provide during SMS interactions. Such information gathered enables us to provide you with information about your loan(s) and other services, to verify your identity for security purposes, to respond to your inquiries, and to provide customer service support.

No mobile information will be shared with third parties for marketing or promotional purposes. Moreover, no information provided on or through SMS will be shared with any third parties outside of the terms of this Privacy Policy.

This Privacy Policy applies only to our Website and Services. It does not apply to third-party websites, services and applications ("Third-Party Services"). Please consult the policies and other terms and conditions of such Third-Party Services as they may differ from our Privacy Policy.

Third Parties

This Privacy Policy applies only to our Website and Services. It does not apply to third-party websites, services and applications (“Third-Party Services”). Please consult the policies and other terms and conditions of such Third-Party Services as they may differ from our Privacy Policy.

Accessing and Correcting Your Information

You can review and change your personal information by logging into the Website and visiting your account profile page.

Data Security

We have implemented reasonable measures designed to safeguard your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Changes to Our Privacy Policy

We may update or modify this Privacy Policy at any time without prior notice. The date the privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Website and this privacy policy to check for any changes. You understand that your continued use of our Website and Services after any update or modifications to this Privacy Policy constitutes your acceptance of the terms of such revised Privacy Policy. If we make material changes, as determined in our sole discretion, to how we treat our users’ personal information, we will notify you by email to the primary email address specified in your account and through a notice on the Website.

Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at [email protected] or 877-700-1914.

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, please see below for our Privacy Policy for California Residents.

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Privacy Policy for California Residents

This Privacy Policy for California Residents (this “Policy”) supplements the information contained in Carlyle Capital Inc.’s Privacy Policy above, and applies solely to residents of the State of California (“consumers” or “you”). Carlyle Capital Inc. and its affiliates and subsidiaries (collectively referred to as “Company”, “we”, “us”, and “our”) adopt this notice to comply with the California Consumer Privacy Act of 2018 (the “CCPA”), as may be amended, and any terms defined in the CCPA have the same meaning when used in this Policy.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“Personal Information”). Personal Information also includes “Sensitive Personal Information,” such as social security number, financial account information, driver’s license, passport number, or legally protected characteristics. Personal Information does not include:

• - Publicly available information from government records.

• - Deidentified or aggregated consumer information.

• - Information excluded from the CCPA’s scope, such as personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

In particular, we may have collected the following categories of Personal Information from consumers, including during the preceding 12 months, for business purposes:

Category - Identifiers.

Examples: Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.

Category - Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Examples: A name, signature, Social Security number, address, telephone number, identification numbers, insurance policy number, bank account number, credit card number, debit card number, or any other financial information. Some Personal Information included in this category may overlap with other categories.

Category - Protected Classification Characteristics under California or federal law.

Examples: Age, race, color, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status.

Category - Commercial information.

Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Category - Internet or other similar network activity.

Examples: Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

Category - Geolocation data.

Examples: Physical location or movements.

Category - Professional, educational or employment-related information.

Examples: Current or past job history, performance evaluations, education records.

We do not use or disclose Sensitive Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA.

The categories of sources from whom we collected the categories of Personal Information listed above include:

• - Directly from you. For example, from forms you complete.

• - Indirectly from you. For example, from observing your actions on our Website.

• - From third parties, such as technology vendors, marketing and advertiser providers, analytics providers, and consumer reporting agencies.

Use of Personal Information

In the past 12 months, we have collected and used the categories of Personal Information listed above for the following business purposes:

• - To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a quote or ask a question about our products or services, we will use that Personal Information to respond to your inquiry. If you provide your Personal Information in connection with a product or service, we will use that information to process your payment and facilitate delivery.

• - To provide, support, personalize, and develop our Website, products, and services.

• - To create, maintain, customize, and secure your account with us.

• - To process your requests, transactions, and payments and prevent transactional fraud.

• - To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

• - To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).

• - To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.

• - For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.

• - To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

• - As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.

• - To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our Website users is among the assets transferred.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Disclosure of Personal Information

We do not “sell” or “share” (as those terms are defined by the CCPA) Personal Information to third parties. We may disclose Personal Information for a business purpose to the following categories of third parties:

• - Service providers, vendors, or third parties that provide mortgage, real property, or credit or financial-related services (e.g., appraisers, closing agents, title agents, PMI companies, or consumer reporting agencies).

• - Service providers, vendors, or third parties that provide services related to compliance, website hosting, information technology, data security, or support services.

• - Investors or wholesale lenders.

• - Government agencies.

We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the Personal Information confidential, and prohibit using the disclosed information for any purpose except performing the contract.

Your Rights under the CCPA

The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know

You have the right to request that we disclose certain information to you about our collection, use, disclosure, and sale of your Personal Information over the past 12 months (the “right to know”), subject to certain exemptions specified in the CCPA. Once we receive and verify your request and confirm your identity (see “Exercising Your Rights to Know or Delete” herein), we will disclose to you:

• - The categories of Personal Information we collected about you.

• - The categories of sources from which your Personal Information was collected.

• - Our business or commercial purpose for collecting or sharing that Personal Information.

• - The categories of Personal Information about you that we shared for a business purpose.

• - The categories of third parties with whom we shared that Personal Information.

• - The specific pieces of Personal Information we collected about you.

Right to Correct

You have the right to request that we correct any inaccurate Personal Information that we have on you.

Right to Delete

You have the right to request that we delete any of your Personal Information that we collected from you, subject to certain exceptions (the “right to delete”). Once we receive and verify your request and confirm your identity (see “Exercising Your Rights to Know or Delete” herein), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• - Complete the transaction for which we collected the Personal Information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

• - Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

• - Debug to identify and repaid errors that impair existing intended functionality.

• - Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.) or any other legal obligation.

• - Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.

• - Comply with a legal obligation.

• - Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify Personal Information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Right to Opt Out

You have the right to request that we not sell or share your Personal Information to third parties.

Right to Nondiscrimination

We will not discriminate against you for exercising any of your rights under the CCPA.

Exercising Your Rights to Know, Correct, or Delete

To exercise your rights to know, correct, or delete described above, please submit a verifiable consumer request using one of the following methods:

• - Calling us at 1-877-700-1914

• - Completing our online form at https://carlyleloans.com/

• - Emailing us at [email protected]

A verifiable consumer request must provide sufficient (i) information that allows us to reasonably verify that you are the person about whom we collected Personal Information or an authorized representative, and (ii) detail that allows us to properly understand, evaluate, and respond to it.

Only you, or an authorized agent may make a verifiable consumer request related to your Personal Information. If you wish to have an authorized agent make a verifiable consumer requests on your behalf, they will need to provide us with sufficient written proof that you have designated them as your authorized agent and we will still require you to provide sufficient information to allow us to reasonably verify that you are the person about whom we collected Personal Information.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. You do not need to create an account with us to submit a request to know or delete. We will only use Personal Information provided in the verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

Upon receiving a consumer request, we will promptly confirm receipt of the request and provide information on how we will process the request. We endeavor to respond to a verifiable consumer request within 45 calendar days of its receipt.

Retention and Deletion of Personal Information

We retain your Personal Information for as long as is necessary for the purposes for which it was collected, or as may be required by law. We utilize the following criteria to determine the length of time for which we retain information:

• - the business purposes for which the information is used, and the length of time for which the information is required to achieve those purposes;

• - whether we are required to retain the information to fulfill reasonable business needs, legal obligations, and compliance requirements;

• - the privacy impact on the consumer of ongoing retention;

• - whether we should retain the information to protect against fraud and other security vulnerabilities; and

• - the manner in which information is maintained in our systems, including the complexity of systems.

Changes to This Policy

We reserve the right to amend this Policy at our discretion and at any time. When we make changes to this Policy, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website and/or services following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about our Privacy Policies, the ways in which we collect and use your information described in these Privacy Policies, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact us by doing one of the following:

• - Calling us at 1-877-700-1914

• - Completing our online form at https://carlyleloans.com/

• - Emailing us at [email protected]

• - Mailing us at:

Carlyle Capital Inc.

5 Park Plaza

Suite 1800

Irvine, CA 92614