Privacy Policy

Your Privacy Matters. Carlyle Financial is committed to protecting your privacy. This Privacy Policy explains what information we collect, how we use and share it, and your rights and choices regarding your personal data. We take the privacy and security of your personal information very seriously, whether you are a prospective borrower, a current client, or just visiting our Site. Carlyle Financial will not sell or rent your personal information to third parties for their own marketing purposes. We use your data only as outlined in this Policy, primarily to provide our mortgage brokerage services and improve your experience on our Site. This Policy has been updated to comply with relevant privacy laws, including the California Consumer Privacy Act (CCPA) (as amended by the California Privacy Rights Act, CPRA) and the federal Gramm-Leach-Bliley Act (GLBA), along with other applicable regulations.

If you do not agree with this Privacy Policy, please refrain from using the Site or providing us with personal information. By using our Site or services, or by otherwise providing your personal information to us, you acknowledge that you have read and agree to the practices described in this Privacy Policy.

1. Information We Collect

Quick Summary: We collect information you provide (like your name, contact info, and loan application details), information about your transactions with us (like loan details), and technical information from your use of our Site (like IP address, cookies, etc.). We may also receive information from third parties (like credit bureaus) with your authorization.

We collect several types of information from or about our users and clients, which may include:

Personal Identifiers: Information that identifies you personally, such as your name, email address, postal address, phone number, or other contact details. For example, when you fill out a contact form or request a rate quote on our Site, we will ask for your name, email, phone number, and details about the loan you are interested in. If you engage in a live chat or use an AI assistant on our Site, we will collect the information you provide during that chat session. These identifiers are used to respond to your inquiries and provide our services to you.
Financial and Application Information: If you apply for a mortgage or pre-qualification through Carlyle Financial, we will collect more detailed personal data necessary for the loan process. This can include information such as your income, employment status, assets, credit history, Social Security number, and other details needed for a loan application. We may also collect documents you provide, like pay stubs, bank statements, tax returns, or pull your credit report (with your authorization). This non-public personal financial information is necessary for us to assist in finding you a suitable loan and for lenders to make informed credit decisions.
Loan Transaction Information: If you obtain a loan with our assistance, we maintain records of that transaction. This includes details about the loan terms, loan amount, interest rate, closing documents, and correspondence or notes related to your loan process. We keep this information to service your needs, comply with regulatory requirements, and for our internal records.
Website Usage Data: Like many websites, we automatically collect certain information about your visit to our Site. This includes data such as your IP address, browser type, device type, the pages you viewed, the dates/times of access, and the webpage you came from (referring page). We may use cookies and similar tracking technologies to collect this usage data (see Section 4. Cookies and Online Tracking below for more details). Usage data helps us analyze how visitors use our Site and improve its performance and design. For instance, knowing which pages are most popular or if certain pages are causing errors allows us to enhance our content and user experience.
Cookies and Similar Technologies: When you visit our Site, we may place “cookies” (small text files) on your browser, and use related technologies like pixel tags or web beacons. Cookies help us remember your preferences and recognize you on return visits. For example, a cookie might store your preferred loan officer or that you have visited our Site before, so we can customize content for you. Cookies cannot run programs or install viruses; they are just text files that our server or authorized third parties can read. We may also use pixel tags or web beacons in emails to know if you open them or click on links. (See Section 4. Cookies and Online Tracking for how we use cookies and your choices regarding them.)
Geolocation Data: We do not actively track your precise geolocation via GPS or other direct means. However, we might infer your general location (such as city or state) from your IP address or from information you enter (for example, the property address you are interested in). We use this general location data to ensure we are serving clients in areas where we operate (e.g., to confirm you’re in California) and to tailor content (for example, showing information relevant to California borrowers).
Professional or Employment Information: If you use our services for a loan related to a business, investment property, or if you provide us with work-related information (like your employer’s name, your title, or a work email), we may collect data about your employment or business (e.g., company name, position, years in role). This often happens during a loan application when employment and income need to be verified. (Note: If you apply for a job with Carlyle Financial via our Site, that application information is used for recruiting and not covered by this customer Privacy Policy).
Third-Party Information: In some cases, we receive information about you from third parties. For example, with your authorization, we may receive your credit report from credit bureaus, or verification of employment from a third-party service, or we might receive referral information if another professional (like a real estate agent) referred you to us. Any information we collect from third-party sources is treated in line with this Privacy Policy and applicable law.

Sensitive Personal Information: Some of the information we collect is considered sensitive under certain laws (for example, Social Security numbers, or data revealing racial or ethnic origin as part of loan applications for government monitoring purposes). We only use and disclose sensitive information as necessary to provide our services or as required by law (for example, to process your loan and comply with anti-discrimination laws). We do not use sensitive personal information to infer characteristics about you or for purposes unrelated to your mortgage transaction, except as permitted by law.

2. How We Use Your Information

Quick Summary: We use your information to operate our business and serve you: primarily to process your loan inquiries and applications, to communicate with you, to provide customer service, and to improve and market our services (including personalizing your experience and showing you relevant ads, with proper consent). We also use data to comply with laws (e.g., verification, record-keeping) and to protect our rights.

Carlyle Financial uses the collected information for a variety of legitimate business purposes, including:

To Provide Services and Process Loans: The primary reason we collect information is to help you obtain a mortgage or related financial service through us. We use your personal and financial information to evaluate your eligibility for loan programs, assist you in completing applications, submit your information to lenders, and guide you through to closing. For example, we use your income, credit score, and asset information to match you with loan options and allow lenders to make informed credit decisions. We also use your information to provide pre-qualification or pre-approval letters, if applicable, and to facilitate rate locks, appraisals, and other steps in the loan process.
To Communicate with You: We use your contact information (email, phone number, mailing address) to communicate with you about your requests and our services. For instance, if you ask a question through our website or begin an application, we will respond via email or phone to assist you. We send updates on your application status, notify you of any additional information needed, and deliver information you request. If you provide your phone number, we may call or text you about your loan inquiry or application (with your consent where required by law). We may also use email or phone to inform you of other products or services that might interest you – but only if you have not opted out of marketing communications. (You can opt out of marketing emails or texts at any time, as described in Section 7, Your Rights and Choices.)
For Customer Service and Support: Information you share with us helps us provide better support. For example, if you mention a specific goal or concern (like a tight timeline to close on a home purchase), we use that information to tailor our guidance and prioritize steps to meet your needs. We may keep records of communications you send us (such as emails, chat transcripts, or voicemails) so we can refer to them when helping you and to train our team to improve service in the future.
Personalization and User Experience: We want your experience on our Site to be useful and relevant. We may use data we collect through cookies and analytics to personalize your experience. For instance, cookies help us remember your preferences or past interactions – such as recalling if you’ve visited our Site before or if you have a preferred loan officer – so we can greet you by name or pre-fill certain forms. Usage data (like which pages you visited) helps us understand what content is most helpful to users, so we can improve our website layout and content. We might also use location or preferences to show you content or promotions tailored to you (for example, highlighting California jumbo loan options if you are visiting from California). All these uses aim to make the Site more user-friendly and relevant to your needs.
Advertising and Remarketing: We may partner with online advertising networks (such as Google or Facebook) to show advertisements for our services on other websites you visit. For example, we might use a Facebook pixel or Google cookie on our Site that notes you visited our mortgage page, and then later show you a Carlyle Financial ad when you’re on another site. The data collected for these advertising purposes is typically de-identified or pseudonymous – meaning we’re not sharing your name or direct contact info, but rather a unique cookie identifier or device ID. These tools help us serve targeted ads to you about Carlyle Financial that align with your interests (for instance, an ad about refinancing if you explored refinancing content). You can opt out of many targeted advertising practices (see Section 4 on Cookies and the “Do Not Sell/Share” options in Section 7). Please note that we do not allow third-party advertisers to collect your personal information for their own independent use; any such advertising-related data collection is used only to display Carlyle Financial’s ads and is done in compliance with privacy laws. We do not sell your personal information to third parties for their own marketing.
Use of AI Tools: We continually explore new technologies to enhance customer service. We may use automated systems or artificial intelligence (AI) tools to assist in processing information or interacting with you. For example, we might have an AI-powered chatbot on our Site that can answer common questions or help collect preliminary information for a loan application outside of business hours. We might also use AI-driven analytics to help match customers with loan products or detect potential fraud. Any use of AI is conducted under strict oversight – we do not delegate final loan decisions to AI without human review, and we configure our AI tools to comply with applicable privacy, consumer protection, and fair lending laws. If an AI tool on our Site collects personal information from you (for instance, if a chatbot asks for your email to have a human loan officer follow up), that information is treated like any other personal information under this Privacy Policy.
Compliance and Legal Obligations: We use and retain your information as necessary to fulfill our legal and regulatory obligations. As a mortgage brokerage, we are subject to various federal and state laws that require record-keeping and reporting. For example, we must maintain loan files and communications for a certain period to comply with the California Department of Real Estate regulations and federal laws like the Equal Credit Opportunity Act. We may use your personal information to verify your identity as required by the USA PATRIOT Act (for anti-money laundering and anti-fraud purposes), or to report certain data under the Home Mortgage Disclosure Act (HMDA). If we receive a lawful subpoena or court order, or a request from regulators or law enforcement, we may use and disclose your information as needed to comply. Additionally, we use your data to ensure we follow all applicable financial, privacy, and consumer protection laws (for instance, using certain demographic information for fair lending self-audits, in a manner allowed by law).
Protecting Our Rights and Interests: We may process and use personal data as necessary to enforce our contracts (such as our Site’s Terms of Use), to resolve disputes, and to protect the security and integrity of our website and business. For example, we might log IP addresses and monitor login attempts to detect malicious activity and protect against unauthorized access to accounts. If you threaten legal action against us or there is a dispute between you and Carlyle Financial, we may use relevant information (such as communications records or transaction history) in our defense or to pursue available remedies. We also may use information to investigate and prevent fraud or other unlawful activities, and to protect the rights, property, and safety of Carlyle Financial, our customers, our employees, or others.
Corporate Transactions: In the unlikely event that Carlyle Financial is involved in a corporate transaction such as a merger, acquisition, sale of assets, restructuring, bankruptcy, or the financing/diligence related to such transactions, customer information may be disclosed or transferred as part of that process. For instance, if another company acquires us or substantially all of our assets, your information would likely be one of the assets transferred. In such cases, we would ensure the successor company is contractually bound to handle your personal information in a manner consistent with this Privacy Policy (or we will obtain your consent if required by law). You would also be notified of any ownership change or changes to the use of your personal information as a result of a transaction, and we would give you any choices your law provides.

Finally, we will only use your personal information for the purposes we collected it for, or for compatible purposes. If we need to use your information for a materially different or unrelated purpose, we will update this Privacy Policy and/or notify you and, if legally required, obtain your consent.

3. How We Share Your Information

Quick Summary: We do not sell your personal information to third parties for their own profit or marketing. However, we do share your information in certain necessary contexts: with lenders (to process your loans), with service providers (who help us run our business), with certain marketing partners acting on our behalf, and with regulators or others as required by law. Any sharing is done with appropriate safeguards.

Carlyle Financial understands the importance of your privacy. We do not sell your personal information to third parties for their independent marketing or commercial use. However, in the normal course of business, we do share certain information with others, strictly for the purposes of providing our services or as required by law, as detailed below:

Lenders and Financial Partners: As a mortgage broker, our primary function is to connect you with mortgage lenders who can offer you a loan. When you decide to proceed with a loan application through us, we will share your application data with the lender(s) or financial institutions that we think are a good match for your needs. This can include personal and financial information such as your credit report, income, assets, employment information, and other details you provided in your application. We share this information with your knowledge and consent (i.e., when you choose to apply and submit information for the purpose of finding a loan). The lenders are only supposed to use your data for evaluating your loan application and not for other purposes. They may in turn share information back with us (for example, the status of the application, loan terms, or credit decision) so that we can assist you through the process. All lenders we work with are regulated financial entities that have their own privacy obligations to protect your data.
Service Providers (Processors): We employ and partner with various third-party service providers to support our operations and deliver our services to you. These include, for example: credit bureaus (to obtain your credit report when you authorize it during a loan pre-qualification), appraisal management companies (to coordinate property appraisals), title and escrow companies (to facilitate closing of your loan), verification services (to verify your employment, income or assets), technology providers (for hosting our website, data storage, customer relationship management software, or our online loan application portal), email and marketing service providers (to send out newsletters or other communications), and analytics providers (like Google Analytics, which help us understand Site traffic). We only share the information necessary for these providers to perform their functions. For instance, if we use an online loan application platform, the data you input is stored on their servers for our use; if we use an email marketing platform, your email address and name will be in their system to send you our communications. Our service providers are contractually obligated to keep your information confidential, to use it only for the services they provide to us, and to implement appropriate security measures to protect it.
Third-Party Marketing Partners: Carlyle Financial does not share your nonpublic personal information with outside companies for them to market their own products or services to you. We do, however, at times work with partners to help market our services to you. For example, we might share limited contact information with a vendor who sends out a promotional mailing or email on our behalf (e.g., a postcard printing/mailing service that gets your name and address to send our newsletter, or an email marketing firm that gets a list of client emails to deploy a campaign). In another case, we might upload a list of customer email addresses (in a hashed, privacy-protected format) to an online platform like Facebook or Google to create a “custom audience” for Carlyle Financial advertisements – meaning those platforms use the list to try to show our ads specifically to our customers or similar audiences. In all such cases, the third parties are not allowed to use your info for themselves beyond providing the agreed service for us. They cannot, for example, retain your data to sell to others or market their own products to you; the information is provided under duty of confidentiality and only for the restricted purpose of marketing Carlyle Financial’s services.
Affiliates: At this time, Carlyle Financial, Inc. does not have any affiliated companies in other lines of business (such as insurance, real estate, or banking) with whom we share personal information. If that changes in the future (for instance, if we were to have an affiliate title insurance company or a parent company with related financial services), we will update this Privacy Policy accordingly and provide any required notices or opt-out opportunities. Generally, under GLBA and other laws, you would have the right to opt out if we planned to share your information with affiliates for their marketing, and we would honor such requirements.
Legal and Regulatory Disclosures: We may disclose information about you if we are required to do so by law or legal process, or as part of compliance examinations and obligations. Examples include responding to a subpoena, court order, or other legal demand; providing information to regulators or auditors (such as the California Department of Real Estate) during an audit or examination of our company; or reporting information to law enforcement or government agencies if we believe it is related to potentially illegal activities (for example, if we suspect mortgage fraud or identity theft, we may report details to the appropriate authorities). We may also share information as necessary to enforce our Terms of Use or other agreements, or to protect our rights and the rights and safety of our customers or others. This kind of sharing will only be done to the extent permitted or required by applicable law.
Business Transfers: If Carlyle Financial is involved in a merger, acquisition, asset sale, financing, or other transaction in which customer information would be transferred or reviewed as part of due diligence, your personal information may be disclosed to potential transaction partners (under appropriate confidentiality agreements) or transferred to the successor or acquiring entity. In such events, we will ensure that your information remains protected by this Privacy Policy (the successor will be bound to use it in the same manner we do now, unless you consent otherwise or they provide notice of changes).

In all sharing scenarios, we aim to share only the minimum information necessary for the purpose and to ensure appropriate safeguards are in place. We do not sell your personal information for money, and we do not share your personal information with third parties for their own independent marketing use. If our practices change in the future, we will update this policy and provide you with any required notice or choice.

4. Cookies and Online Tracking

Quick Summary: We use cookies and similar tech to make our Site work better and to support analytics and advertising. Cookies help with things like remembering preferences and showing relevant content. We also work with third-party analytics and advertising partners (like Google Analytics, Facebook, etc.) that may set cookies. You have choices – you can disable cookies or opt out of certain tracking, but it might affect your experience.

Cookies and Why We Use Them: Our Site uses cookies and similar tracking technologies to enhance your experience and gather data about how visitors use our Site. When you visit carlylefinancial.com, our server may place a cookie file on your web browser. Cookies help in several ways, such as:

Remembering Your Preferences: Cookies can recall if you’ve visited us before and any preferences you set, so the Site can greet you and tailor content. For example, a cookie might remember that you prefer a certain loan officer or that you already submitted a contact form, preventing duplicate prompts. If we have a client login portal in the future, cookies might keep you logged in during your session or pre-fill your username on return visits.
Analytics: Cookies allow us to collect aggregate data about Site usage – like which pages are most visited, how long users stay on each page, and if any errors occurred. This helps us understand what parts of our Site are working well and what might need improvement. We use third-party analytics tools (such as Google Analytics) that set their own cookies to provide insights. These analytics cookies don’t identify you by name; they may collect your IP address or device ID, but typically this information is used in aggregate form (e.g., overall website traffic statistics). Google Analytics, for instance, helps us see general website trends without telling us exactly who each visitor is.
Advertising: We may use cookies (and allow certain third-party cookies) to assist with our advertising efforts. As described earlier, if you visit our Site, a cookie may note that fact, and we could later show you Carlyle Financial ads on other websites – a practice known as retargeting. For example, if you visited our “Refinance Loans” page, you might later see an advertisement from us about refinancing while browsing another site. Cookies might also cap how many times you see our ad (so you don’t see the same ad too many times). Additionally, cookies help us measure the effectiveness of our ads – for example, to know if someone who saw our Google ad eventually clicked it or came to our site and filled out a form. The data we access for advertising is typically not directly identifying you (we don’t see your name or profile info from these cookies), but it does help us reach people who are likely interested in our services.

Your Choices for Cookies: When you first visit our Site, you may see a banner or notice about cookies. You can choose to accept or decline non-essential cookies. Most web browsers automatically accept cookies by default, but you can usually modify your browser settings to decline or delete cookies if you prefer. Keep in mind, if you disable cookies entirely, some features of our Site may not function properly. For example, parts of the Site that rely on remembering your information (like forms that save your progress, or preference settings) might not work or might forget your preferences between visits. Even without cookies, you will still see basic content and potentially some generic marketing material, but it may be less personalized or relevant to you.

Third-Party Tracking and “Do Not Track”: Our Site may not respond to “Do Not Track” (DNT) signals from browsers, because there is currently no industry consensus on how to interpret them. However, we limit tracking to what is described in this Policy. Third parties, such as analytics providers or ad networks, may collect information about your online activities over time and across different websites when you use our Site. Importantly, we do not allow third-party companies to collect your personal identifiers (like your name or email) through our cookies for their own independent use. The information collected via cookies on our Site for analytics or ads is used for Carlyle Financial’s purposes as described.

Opt-Out of Targeted Advertising: If you prefer not to receive targeted advertising based on your Site usage data, you have options. You can opt out of many third-party advertiser tracking cookies by using tools provided by organizations like the Network Advertising Initiative (NAI) or the Digital Advertising Alliance (DAA) in the U.S. (we provide links to these on our Site or you can find them via a web search). These allow you to opt out of behaviorally targeted ads from participating companies. Additionally, many advertising cookies can be controlled via your browser settings or via browser extensions that enhance privacy.

Furthermore, if you are a California resident, you have the right to opt out of the “sale” or “sharing” of your personal information for targeted advertising purposes. As described in Section 7 below, we provide a “Do Not Sell or Share My Personal Information” link on our website footer, which you can use to opt out of the use of cookies for targeted advertising (i.e., to opt out of us sharing data with third-party advertising networks for cross-context behavioral advertising). When you exercise that opt-out, we will, to the extent feasible, stop the use of advertising cookies and similar tracking tools on our Site that result in such sharing of your information.

Please note that even if you opt out of targeted advertising, you may still see our ads; they just won’t be tailored to you based on cookies or tracking from our Site. Also, opting out via the methods above relies on cookies as well (to remember your choice), so if you clear your cookies, you might need to opt out again.

5. Data Security

Quick Summary: We take security seriously and use various measures (encryption, firewalls, access controls, etc.) to protect your personal information. We follow the GLBA Safeguards Rule for financial data. However, no system is completely infallible, so there’s always some risk. We also tell you steps you can take, like protecting your password and being cautious of suspicious communications.

How We Protect Your Data: Carlyle Financial employs a combination of technical, administrative, and physical security measures to protect your personal information from unauthorized access or misuse. For instance:

Our Site and online application forms use encryption (HTTPS/SSL) for data in transit, which means information you submit is encrypted when sent over the internet to our servers.
We maintain firewalls and network monitoring to guard against external attacks, and we regularly update our systems with security patches.
Within our organization, we restrict access to personal data. Only employees who need to know your information to perform their duties (for example, your loan officer, a processor, or compliance personnel) are granted access to your full loan file or personal details. We use access controls and multi-factor authentication for internal systems to ensure that even within our company, sensitive data is accessed only by authorized individuals.
Physical copies of any sensitive documents are stored in secure areas, and we employ physical security (like locked cabinets or secure office facilities) to prevent unauthorized viewing.
We provide privacy and security training to our staff to make sure they understand the importance of protecting your information and follow best practices.

Safeguards for Financial Information: As a financial institution under federal law, we abide by the Gramm-Leach-Bliley Act (GLBA) and its Safeguards Rule. This means we have a written information security program in place and take specific steps to protect your nonpublic personal information (like your loan application details) as required by law. We also commit to providing any required notifications in the event of certain security breaches, consistent with state and federal laws.

Despite all these measures, it’s important to understand that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to protect your personal data using commercially reasonable means and we regularly update our security protocols, we cannot guarantee absolute security of your information. By using our Site and services, you acknowledge and accept this residual risk.

Your Role in Security: We also encourage you to take precautions. Create a strong, unique password if you register an account, and do not share your login credentials. Be cautious of “phishing” attempts – Carlyle Financial will never ask you to provide sensitive information like passwords via email. If you receive communication that looks suspicious or asks for personal information in an odd way, contact us through our official channels to verify it. Always log out of your account and close your browser when finished if you are on a shared device.

If You Suspect a Security Issue: If you feel that your interaction with us is no longer secure – for example, if you suspect your account has been compromised or you receive a suspicious email that appears to come from us – please notify us immediately. You can find our contact details in Section 11 (Contact Information). We take such reports seriously and will work with you to investigate and address the issue.

6. Data Retention

Quick Summary: We keep your personal information only as long as necessary for the purposes it was collected, including fulfilling transactions and meeting legal requirements. For mortgages, that often means we retain files for several years (since the law requires it). We’ll dispose of or anonymize data when it’s no longer needed. Web analytics and cookies have their own retention (often controlled by third-party settings).

We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for business and legal purposes. In practice, the retention period will vary depending on the type of data and the context of its collection:

Loan Application and Transaction Data: For mortgage transactions and applications, we are often required by law and regulators to keep records for a certain number of years. For example, we may retain loan files, communications, and related documents for at least 3 to 5 years (or more) after a loan closes or an application is withdrawn, as mandated by regulations (such as state real estate laws or federal lending laws). We keep these records to comply with audit requirements, to address any post-closing questions or issues, and for legal record-keeping.
Prospect and Inquiry Information: If you reached out but did not complete a transaction with us, we may keep the information of your inquiry for a reasonable period. This is to follow up with you and see if we can assist you later, and also to have a record of our communications. For instance, if you inquire about rates but don’t apply, we might retain your contact info and notes for a year or two in case you come back or to send a courtesy follow-up (unless you request deletion sooner).
Marketing Data: If you’ve signed up for our newsletter or agreed to receive marketing communications, we will retain your contact details until you unsubscribe or ask us to delete them. We maintain suppression lists (of people who opted out) indefinitely as required to honor those opt-outs.
Web Analytics Data: Data collected via cookies and similar tools has retention periods that are often determined by the provider (e.g., Google Analytics might retain data for 14 months or as configured). We do not keep identifiable web server logs indefinitely; any raw web logs linking back to individuals are typically kept only for a short period (to ensure security and investigate any issues), after which they may be deleted or anonymized.

When personal information is no longer necessary for the purposes we collected it, and we are not legally required to retain it, we will securely delete or anonymize the data. For example, physical documents containing personal data that are no longer needed are shredded or incinerated. Electronic data is securely erased or rendered anonymous (meaning it can no longer be associated with you).

Keep in mind that even after you close an account or request deletion, we might retain certain information for the reasons above – but we’ll keep it no longer than necessary and access to it will be restricted.

7. Your Rights and Choices

Quick Summary: You have choices about your personal information. You can opt out of marketing emails/texts. You can update or correct your data. California residents have specific privacy rights (to know, delete, correct, opt-out of sale/sharing, etc.), which we outline below. We will not discriminate against you for exercising these rights. (Also, we don’t sell your info to begin with, and we only share for our own advertising as described, but we provide an opt-out link just in case.)

Opting Out of Marketing: If at any time you prefer not to receive promotional emails or newsletters from us, you can unsubscribe using the link provided at the bottom of our marketing emails or by contacting us directly to request removal. We will process your unsubscribe request as soon as possible, and in any event within the time required by law. Please note that even if you opt out of marketing emails (or calls or texts), we may still need to send you important transactional or service-related communications. For example, we may email or call you about your active loan application, send payment reminders, or notify you of changes to terms or policies affecting you. If you opt out of one communication channel (say, telemarketing calls), we may still contact you through other channels for non-marketing reasons (for instance, we might still call you to discuss an ongoing transaction you have with us).

Updating Your Information: It’s important that we have accurate, up-to-date information. If you need to update or correct any personal information you have provided to us, please let us know. For example, if you move or change phone numbers during the loan process, or if you realize we misspelled your name, inform your loan officer or contact our office and we will make the correction (after verifying your identity for security). If you have an online account with us, you may also be able to edit certain profile information directly. We will update your records as requested, or if we cannot (say, if the information is part of a submitted loan to a lender or part of a closed loan file that we must keep unchanged for regulatory reasons), we will let you know why we cannot make the change.

California Privacy Rights: If you are a resident of California, you have specific rights under the CCPA (California Consumer Privacy Act), as amended by the CPRA, regarding your personal information. These include:

Right to Know: You have the right to request that we disclose what personal information we have collected about you in the past 12 months. This includes the categories of personal information, the sources from which we collected it, the business or commercial purposes for collecting (or sharing) it, and the categories of third parties with whom we share it. You also have the right to request a copy of the specific pieces of personal information we collected about you. Once we receive and verify your request, we will provide the requested information (provided it is allowed by law – certain data may be exempt from disclosure for security or legal reasons).
Right to Delete: You have the right to request that we delete personal information we have collected from you (and direct our service providers to do the same), subject to certain exceptions. After we verify your identity and confirm your request, we will delete (and instruct any service providers or contractors to delete) your personal information from our records, unless an exception applies. For example, we may need to retain certain information to complete a transaction you initiated, to detect security incidents or protect against illegal activity, to comply with a legal obligation (such as maintaining records of a closed mortgage as required by law), or for other internal purposes that are reasonably aligned with expectations based on your relationship with us (like preserving evidence of a business transaction). If we deny a deletion request in whole or in part due to a valid exception, we will inform you of the reason.
Right to Opt-Out of Sale/Sharing: California law gives you the right to direct a business to stop “selling” your personal information or “sharing” it for cross-context behavioral advertising. Carlyle Financial does not sell personal information for monetary consideration. We also do not disclose personal information to third parties for their own targeted advertising in a way that we believe constitutes “sharing” under the CPRA, except in the context of showing you ads about our services as described (which we consider part of our service to you). In other words, we do not exchange your data with unrelated third parties for them to profile you and advertise their products to you. Our use of advertising cookies is solely to promote Carlyle Financial’s services to you. Nonetheless, out of an abundance of caution and in compliance with California law, we provide a “Do Not Sell or Share My Personal Information” link on our website. If you click that link (or use an authorized agent to submit an opt-out request, or send us a valid opt-out via the designated methods), we will honor it and refrain from any sale or sharing of your personal information as defined by CCPA/CPRA. If in the future we ever consider monetizing data in a way that qualifies as a “sale” or “share” under California law, we will provide clear notice and the opportunity to opt out before such activity occurs.
Right to Correct: Starting January 1, 2023 (under CPRA), California consumers have the right to request the correction of inaccurate personal information that a business maintains about them. If you become aware that we hold information about you that is incorrect or out of date (for example, an incorrect address or an outdated income figure), you can request that we correct it. Upon verifying the validity of your request, we will correct the inaccurate information in our records (taking into account the nature of the information and purpose for which it’s processed). If we cannot honor a correction request (say, if we believe the information is accurate, or we are legally prevented from altering it), we will explain why.
Right to Limit Use of Sensitive Personal Information: CPRA also gives California residents the right to limit a business’s use and disclosure of “sensitive personal information” (SPI) if that SPI is used for purposes beyond what is necessary to provide goods or services. In our case, any sensitive information (like Social Security numbers or account logins) we collect is used only for necessary purposes (e.g., processing your loan, verifying identity, or as required by law). We do not use or disclose sensitive information for purposes like inferring characteristics about you or showing personalized ads. Therefore, we do not currently need to offer a “Limit Use of My Sensitive Personal Information” link, because we are already limiting our use of sensitive data to what is permissible. If that ever changes, we will provide the appropriate opt-out mechanism.
Right to Non-Discrimination: We will not discriminate against you for exercising any of your California privacy rights. This means if you choose to exercise your rights to access, delete, opt-out, or correct, we will not deny you our services, charge you a different price, provide a different level of service, or suggest any of these will occur because you exercised your rights. However, please note that if the exercise of your rights limits our ability to process your data (for instance, if you request that we delete certain information), we may not be able to provide certain services that rely on that data. For example, if you request deletion of your data while in the middle of a loan process, we would not be able to continue processing that loan since we no longer have the information. We will inform you if such a situation arises.

How to Exercise Your Rights: If you are a California resident and would like to exercise any of the rights described above, you or your authorized agent can submit a request to us through the following methods: (1) call us at the phone number listed in the Contact Information section, or (2) email us at privacy@carlylefinancial.com (or info@carlylefinancial.com, with the subject line “CCPA Request”), or (3) submit a request via any online form or portal we may provide on our website for CCPA requests. Please specify which right you intend to exercise and provide us enough information to verify your identity (we want to ensure we’re providing data to the right person). For an access or deletion request, we will need to verify your identity to a reasonable degree of certainty, which might involve matching information you provide with information we have on file (we may ask for two or three pieces of personal info to confirm). For highly sensitive requests (like specific pieces of info), we may require a greater degree of verification (such as a signed declaration under penalty of perjury that you are who you claim).

If you designate an authorized agent to make a request on your behalf, we will take steps to verify the agent’s authority (for example, we may ask for a signed permission from you or proof of power of attorney, and also verify your identity directly).

We aim to respond to your request within 45 days of receiving it. If we need more time (up to an additional 45 days, for a total of 90 days), we will inform you of the reason and extension in writing. If we decline any part of your request, we will explain our reasoning (for instance, if we cannot delete data that we are legally required to keep, or we cannot provide certain information due to legal exemptions).

Shine the Light Law: Under California’s “Shine the Light” law (Civil Code § 1798.83), California residents who have an established business relationship with us may request information once a year about certain types of personal information we have shared with third parties for their direct marketing purposes, and with whom. However, Carlyle Financial does not share personal information with third parties for their own direct marketing purposes (without your consent). Thus, we believe we have no disclosures to make under that law. If you are a California resident and have questions about our compliance with Shine the Light, you may send a request to our contact address in Section 11. Any such inquiry must include “California Shine the Light Request” in the subject or body of the message, and you must include your name and contact information for us to respond.

Opt-Out of SMS Communications: As noted, if at any point you consented to receive SMS/text messages from us (for example, alerts or updates on your loan process), you can opt out of further texts. Typically, you can text “STOP” in reply to any message we send, and we will remove you from SMS communications (note that you may receive one final confirmation text). You can also contact us directly (phone or email) and request to be taken off text messaging, and we will handle that promptly. We do not charge any fee for you to opt out, though standard message rates from your carrier may apply to any messages sent or received.

8. Children’s Privacy

Quick Summary: Our services aren’t for kids under 13. We don’t knowingly collect data from young children. If somehow a child under 13 has given us data, parents can contact us to delete it.

Our website and services are not directed to children under the age of 13, nor do we knowingly collect personal information from anyone under 13 years old. Carlyle Financial’s services (such as mortgage loans) are adult-oriented by their nature (you must be of legal age to enter into financial contracts). We do not target or market to children.

If you are under 13, please do not use this Site or send us any personal information. If we discover that we have inadvertently collected personal information from a child under 13 (for instance, through a misguided contact form submission), we will promptly delete that information from our records.

If you are a parent or guardian and believe that your child under 13 may have provided personal information to us, please contact us immediately (see Section 11 for how to reach us). We will take steps to remove any such information and terminate any account that the child may have created, in accordance with the Children’s Online Privacy Protection Act (COPPA) and other applicable laws.

9. Third-Party Websites and Social Media

Quick Summary: Our Site may link to other websites (like our partners or social media pages). Once you leave our Site or interact with those pages, their privacy policies apply, not ours. We aren’t responsible for external sites.

Our Site may include links to third-party websites, such as realtor or broker partner websites, credit education resources, or social media platforms where we have an official presence (for example, Facebook, LinkedIn, or Instagram). If you click on those links or interact with those platforms, be aware that you are leaving Carlyle Financial’s website and that this Privacy Policy no longer applies.

For example, if you click a link to an article on an external site or go to a mortgage calculator provided by a partner, any information you provide on that third-party site (even if you reached it through our Site) will be governed by that site’s privacy policy and terms. We do not control, and are not responsible for, the content, security, or privacy practices of any third-party websites. We encourage you to review the privacy policies of every website you visit.

Similarly, if you choose to engage with Carlyle Financial on social media (such as by commenting on our Facebook page or sending us a message via Twitter/Instagram), your interactions are also governed by the privacy policy of the social media platform. We might collect information from our official social media pages (e.g., we can see your public profile or the information you voluntarily send to us in a message), but any data the social platform collects as you interact (like usage data or additional profile info) is subject to their rules.

In short, once you leave our Site or submit information to a third-party, we are not responsible for how that third party handles your data. Nonetheless, if you have concerns about a site we linked to, we appreciate feedback. We aim to link only to reputable sources that value privacy.

10. Changes to this Privacy Policy

Quick Summary: If we change our Privacy Policy, we will post the updated version with a new effective date. If changes are significant, we may notify you through additional means. Your continued use of the Site after changes means you accept the new policy.

We may update or change this Privacy Policy from time to time to reflect changes in our practices, to keep up with new legal requirements, or for other operational reasons. When we make changes, we will post the updated Privacy Policy on this page and update the “Effective Date” at the top. Any changes will become effective when the revised Privacy Policy is posted.

If we make material changes that significantly affect how we handle personal information (for example, expanding how we use or share data in a way that you might not expect), we will take additional steps to notify you. This might include posting a prominent notice on our Site’s homepage, or if appropriate, notifying you via the contact information you have provided (such as sending an email notification). We may also highlight the key changes for clarity.

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information. Your continued use of the Site or our services after any modifications to this Policy will signify your acceptance of the changes. If you do not agree to any updated terms, you should stop using our Site and services and may exercise your rights (such as requesting we delete your data, if applicable).

11. Contact Information (Privacy)

Quick Summary: If you have questions or requests regarding your privacy or this policy, here’s how to contact us.

If you have any questions, concerns, or comments about this Privacy Policy or our privacy practices, or if you wish to exercise any of your privacy rights as described in this Policy, please contact us as follows:

Carlyle Financial, Inc. – Privacy Office
10880 Wilshire Blvd., Suite 2100
Los Angeles, CA 90024, USA
Phone: 310-276-7400
Email: privacy@carlylefinancial.com (or you may use info@carlylefinancial.com and include “Privacy Inquiry” in the subject line)

When you contact us, please provide your name and contact information, and clearly describe your question or request. If you are making a request to exercise privacy rights (such as a data access or deletion request), please be prepared to provide information for us to verify your identity for security purposes.

We will respond to legitimate inquiries as promptly as possible, and at least within the timeframe required by law. Your privacy is important to us, and we welcome your feedback. Thank you for reading our Privacy Policy – we appreciate your trust in Carlyle Financial and are committed to safeguarding your personal information.

Carlyle Financial, Inc. (NMLS ID #1680556) is licensed by the California Department of Real Estate (Broker License #01941702) and is an Equal Housing Lender. We comply with the Gramm-Leach-Bliley Act and California privacy laws to protect your information. This Privacy Policy is for general consumer information and does not create a contractual obligation beyond what the law requires.

Privacy Policy (CPRA & GLBA Compliant)