Correia Financial Privacy Policy

11. Who We Are and What This Policy Covers

Correia Solutions LLC, doing business as Correia Financial (“Correia Financial,” “we,” “us,” or “our”), provides commercial financing brokerage services. We help businesses explore financing options offered by independent lenders, funders, and financing providers. We do not make the final funding decisions of those providers.

This Privacy Policy describes how we collect, use, disclose, retain, and protect information through our website at https://correiafinancial.biz, applications, document submissions, customer and partner portals, telephone conversations, emails, text messages, and related online and offline interactions (collectively, the “Services”). It applies to applicants, business owners, guarantors, authorized representatives, referral partners, and website visitors.

Business records may contain personal information about owners or other individuals. We handle that personal information as described in this Policy and applicable law. This Policy does not replace separate financing agreements, credit authorizations, communication consents, or any additional legally required privacy notices. Reading this Policy or visiting our website does not, by itself, constitute consent to every processing activity or to automated marketing communications.

22. Information We Collect

The information we collect depends on your interaction with us and the financing requested. We collect information relevant to providing the Services, including the following categories when applicable:

Certain information, such as Social Security numbers, government identification numbers and some financial account information, may be sensitive personal information under applicable law. We request sensitive information only when relevant to an identified service, verification, security, or legal purpose. Do not submit information unrelated to your financing request.

Call recordings and transcripts. We may record or transcribe calls for customer service, accuracy, quality assurance, training, compliance and documentation. Recordings and transcripts may be processed by our communications, transcription and authorized AI service providers. We provide notice and obtain consent when required by applicable law. This Policy does not replace a required recording notice or consent. If you prefer not to be recorded, tell us at the beginning of the call so we can discuss an alternative way to communicate.

33. Where Information Comes From

We collect information directly from you and your authorized representatives, through your use of our Services, and from parties involved in your inquiry or financing request. These sources may include referral partners, other brokers, lead providers, financing providers, identity and fraud verification services, publicly available business records, and financial institutions or account connection services you authorize.

Information received from a referral or lead provider is not treated as automatic permission for every form of marketing contact. We use it subject to applicable law and any required permissions. If you provide information about another owner, guarantor, employee, or individual, you must have the authority to provide it and give that person any required notices.

44. How We Use Information

We use information to:

• Respond to inquiries, identify funding needs, schedule consultations and provide support.
• Receive, organize, review and verify applications and supporting documents.
• Identify potentially suitable financing products and submit requests to appropriate financing providers or intermediaries.
• Communicate about document requests, application progress, offers and funding outcomes.
• Discuss renewal, refinancing or additional financing opportunities where permitted and consistent with communication preferences and required consent.
• Operate customer and partner relationships, track eligible referrals, and administer commissions and business records.
• Maintain consent, unsubscribe and suppression records.
• Detect fraud, verify identity, investigate misuse, protect systems and resolve disputes.
• Maintain, troubleshoot and improve our Services and evaluate their performance.
• Measure advertising performance and promote our Services through analytics and advertising technologies, subject to the choices and restrictions described below.
• Meet legal, regulatory, contractual, accounting and recordkeeping obligations and establish, exercise or defend legal claims.

We do not use this Policy as unrestricted permission to use information for unrelated purposes. Where a new use requires additional notice or consent, we will provide that notice or obtain that consent before proceeding.

55. How We Disclose Information

We disclose information as reasonably necessary for the purposes described in this Policy, subject to applicable law and appropriate restrictions.

Financing providers and placement intermediaries. We may provide applications, business bank statements, identification, financial records and related information to multiple lenders, funders, underwriting partners, or other brokers assisting with a requested financing placement. A submission does not guarantee approval or funding. Providers may process information under their own privacy notices and applicable legal obligations. Ask us if you need help identifying a provider involved in your request.

Service providers. We use providers for hosting, storage, customer relationship management, electronic signatures, communications, document processing, analytics, security, verification and administrative support. We restrict their use of information through applicable agreements and instructions. We authorize access only for the services they perform for us, subject to applicable law.

Analytics and advertising providers. We disclose limited website identifiers, device and browser data, and usage or advertising interaction information to analytics and advertising providers as described in Sections 6 and 7. These disclosures are distinct from sharing application documents with financing providers.

Referral partners and representatives. Where authorized and appropriate, we may provide the referring partner or your representative with limited updates about referral status, funding results or commission eligibility. A referral does not automatically entitle the partner to your complete application, Social Security number, bank statements or tax returns.

Legal and protective disclosures. We may disclose information when required by law, valid legal process or a regulator, and as permitted to investigate fraud, protect rights and security, or establish, exercise or defend legal claims.

Business transactions. Information may be disclosed in connection with a proposed or completed merger, financing, acquisition, reorganization, bankruptcy or sale of business assets, subject to applicable confidentiality protections, legal requirements and any required notice or consent. This provision does not override the SMS restrictions below.

Your direction. We may disclose information to another recipient when you direct or authorize us to do so, subject to applicable law.

We may receive compensation for successfully arranging financing or for other disclosed brokerage services. Compensation does not eliminate applicable privacy requirements or automatically determine whether a disclosure is a sale or sharing under privacy law.

66. Sale, Sharing and Advertising Practices

We do not sell applicant contact lists or application documents to third parties for their independent marketing purposes. We do not permit financing submissions to serve as unrestricted permission for unrelated third-party marketing.

Some privacy laws define “sale” to include exchanges for valuable consideration other than money and “sharing” to include disclosures for cross-context behavioral advertising. Accordingly, the legal classification of a disclosure depends on its actual circumstances.

We use analytics and advertising technologies, including tools from Meta and Google, to understand website activity, measure advertising results and reach people who may be interested in our Services. These technologies may disclose online identifiers, IP addresses, device information, pages visited and advertising interactions to advertising providers. Those providers may associate the information with activity on other websites or services. Depending on the configuration and applicable law, these disclosures may constitute a sale, sharing or targeted advertising even though we do not sell leads for money.

Your advertising opt-out. To request that we stop covered sales, sharing or targeted advertising, email info@correiafinancial.biz with the subject Do Not Sell or Share My Personal Information, or call (619) 387-5891. A specific subject line is helpful but not required. We may ask for the minimum information needed to locate the relevant browser or records, without imposing prohibited verification requirements. You can also use the browser-based choices described below. Opting out does not prevent all advertising; you may still see general advertisements.

The restrictions on mobile information and SMS consent in Section 9 apply regardless of any general disclosure provisions elsewhere in this Policy.

77. Cookies, Analytics and Tracking Choices

Our Services use cookies and similar technologies for functionality, session management, security and measurement. Your browser may allow you to block or delete cookies. Blocking necessary cookies may affect certain features.

We use Meta and Google analytics or advertising technologies, which may include Meta Pixel, Google Analytics and Google Ads measurement tools. Their operation may involve cookies, pixels or similar identifiers. These providers may collect information over time and across websites and services for measurement and advertising purposes, subject to applicable settings, agreements and law.

You can manage available advertising preferences through Google My Ad Center (opens in a new tab) and your Meta account's advertising settings. Google also offers a Google Analytics opt-out browser add-on (opens in a new tab). These tools have different scopes and do not necessarily stop every type of collection. Browser settings that block third-party cookies or tracking can provide additional controls. Clearing cookies or changing browsers or devices may require you to set preferences again.

Browser signals. Traditional Do Not Track signals do not provide a standardized opt-out mechanism for our Services; use the advertising opt-out methods above or Global Privacy Control where applicable.

Where applicable law requires us to honor opt-out preference signals, we honor valid signals such as Global Privacy Control for covered sales, sharing or targeted advertising. A browser signal may apply only to the browser or device sending it unless we can associate it with your other information as required by law. Traditional Do Not Track settings and Global Privacy Control are different mechanisms.

We do not intentionally transmit Social Security numbers, bank account numbers, tax returns or application documents to advertising platforms for advertising purposes.

88. Credit Information and Financing Decisions

Correia Financial does not directly pull consumer credit reports. Independent financing providers may obtain consumer or business credit reports, verify financial information and make their own underwriting decisions, subject to a legally permissible purpose and any required authorization.

We may receive credit information you voluntarily provide and relevant eligibility or underwriting feedback from financing providers as permitted by law. This Policy is not, by itself, authorization for a credit inquiry. Required credit authorizations are obtained separately. Each party remains responsible for the legal obligations applicable to its own activities, including required notices. Contact us if you need assistance identifying the provider responsible for a financing decision.

99. Calls, Emails and Text Messages

Application and service communications. We may contact you about your inquiry, application, documentation, appointments and requested Services through legally permitted channels, consistent with your permissions and preferences.

Marketing communications. Where required, we obtain separate consent before sending marketing texts or using regulated automated calling technologies, prerecorded messages or artificial voices. Providing a telephone number or visiting our website does not, by itself, constitute written consent to automated marketing. Promotional financing and renewal messages are handled according to their actual content and applicable requirements.

SMS consent and terms. If you expressly opt in, Correia Solutions LLC dba Correia Financial may send texts within the scope of your consent, including application updates, consultation scheduling, document requests and related follow-ups. Promotional messages are sent only within the scope of any applicable marketing consent. Message frequency varies. Message and data rates may apply. Consent to receive SMS is not a condition of purchasing goods or services or obtaining financing assistance.

Reply STOP to unsubscribe from SMS. Reply HELP for assistance, or contact info@correiafinancial.biz. We honor applicable revocation requests and maintain suppression records to help prevent further unwanted messages. You may receive a permitted, nonpromotional confirmation of your opt-out. Message delivery is subject to carrier and network availability.

Protection of mobile information. We do not sell, rent or share mobile information with third parties or affiliates for their own marketing or promotional purposes. SMS opt-in data and consent are not shared with third parties for their marketing. We may disclose limited information to messaging and support providers solely to operate the messaging program on our behalf, subject to appropriate restrictions. A financing submission does not transfer your SMS marketing consent to the recipient.

Email and telephone choices. Use the unsubscribe link in a marketing email or contact us to request that marketing emails or calls stop. Opting out of marketing does not automatically erase records or cancel an application. Necessary service information may still be provided through a legally permitted channel, but an active application does not override a valid withdrawal of consent for a regulated communication method.

1010. Automated Tools and Artificial Intelligence

We use our Maverick customer relationship management system and other software, including artificial intelligence tools, to support our Services. These tools may process applications, business bank statements, customer conversations and related information to organize documents, summarize communications, assist with application review and product matching, schedule follow-ups and support fraud detection. Processing may occur through our systems and authorized technology providers.

Information processed through these tools remains subject to the purposes, disclosure restrictions, retention practices and privacy choices described in this Policy. We do not authorize AI service providers to use applicant information for their own independent marketing. This Policy does not provide blanket consent for unrelated AI uses.

Automated summaries and preliminary product matches are not financing approvals. Final provider decisions are made under the provider's own processes. Contact us to correct inaccurate information or request assistance with a preliminary assessment.

Where applicable law provides rights concerning automated decisions or profiling, you may contact us to exercise those rights, including any applicable right to information, review or opt-out. We will provide additional notices and choices when required for a particular use.

1111. How Long We Retain Information

We retain information for as long as reasonably necessary for the disclosed purposes and applicable obligations. Retention depends on the category, sensitivity, relationship, legal requirements and any pending dispute or investigation.

• Application, identity and financial records are retained as needed to process requests and meet applicable recordkeeping, audit, fraud prevention and legal obligations.
• Communications, consent and suppression records are retained as needed to document permissions, resolve disputes and honor communication preferences.
• Partner and commission records are retained as needed for administration, accounting, tax and legal purposes.
• Technical and security records are retained for appropriate operational, analytics, investigation and security periods.

When information is no longer needed, we take reasonable steps to delete or deidentify it. Backup copies may remain until their scheduled deletion and are restricted from ordinary use. Legal holds or other lawful exceptions may delay deletion. Deletion requests do not necessarily require removal of limited records needed to honor an opt-out.

1212. Information Security

We maintain reasonable administrative, technical and physical safeguards appropriate to the nature of the information we handle. Access is limited according to business need. No system or method of transmission is completely secure, and we cannot guarantee absolute security. We provide breach notifications when required by applicable law.

Please use the submission method we designate for sensitive documents. Do not send account passwords, full Social Security numbers or complete financial documents through ordinary SMS. Contact us if you suspect unauthorized access or disclosure. These precautions do not reduce our own security obligations.

1313. Your Privacy Rights and Requests

Depending on your residence, our activities and the law applicable to the information, you may have rights to:

• Know whether and how we process personal information and access it.
• Correct inaccurate information.
• Request deletion, subject to lawful exceptions.
• Obtain an eligible copy in a portable format.
• Opt out of covered sales, sharing, targeted advertising or certain profiling.
• Limit certain uses or disclosures of sensitive information, where that right applies.
• Withdraw consent where processing is based on consent.
• Appeal a denied request where required by law.

Send requests to info@correiafinancial.biz with the subject Privacy Request, call (619) 387-5891, or use the mailing address below. You do not need to use a particular subject line to exercise your rights. Explain the request and provide enough information to locate your records. Do not email a full Social Security number, account password or complete bank account number.

For access, correction and deletion requests, we may verify identity and authority using information reasonably necessary for the request. Authorized agents may submit requests as permitted by law; we may request proof of authority and any permitted identity verification. We do not require identity verification for opt-out requests where prohibited.

We respond within applicable legal deadlines, explain permissible extensions where needed and provide reasons for a denial when required. Rights may be subject to exceptions, including security, legal recordkeeping, completion of requested transactions and protection of other individuals. If an appeal right applies, reply to our response with Privacy Appeal or email us using that subject. We will provide the applicable appeal process and regulator complaint information as required.

We do not unlawfully discriminate or retaliate against individuals for exercising privacy rights. Some Services may be unavailable if information necessary to provide them is deleted or withheld; we will explain the relevant limitation.

1414. Additional California Information

Where the California Consumer Privacy Act, as amended by the California Privacy Rights Act, applies to us and the information involved, California residents may exercise applicable rights described above, including rights to know, delete, correct, opt out of sale or sharing, and limit certain sensitive information uses.

Sections 2 through 7 identify the categories, sources, purposes and recipient categories relevant to our practices. Section 11 explains retention criteria. Sensitive information is used for requested Services, verification, security and legal obligations, rather than to infer unrelated personal characteristics.

The following category-to-recipient summary describes our disclosures for the purposes explained in this Policy. Legal authorities, professional advisers and transaction counterparties may also receive relevant categories under the limited circumstances described in Section 5.

We do not knowingly sell or share personal information of individuals under 16. Where the CCPA applies, we process requests to know, delete or correct within its applicable response periods, generally 45 calendar days, with a permitted extension and notice where appropriate. Opt-out requests follow their separate applicable deadlines. We do not require you to create an account to submit a privacy request.

Where California's Shine the Light law applies, California residents may contact us to request information about applicable disclosures for third-party direct marketing. Our stated policy is not to disclose personal information for independent third-party marketing as described above.

This section does not claim that every state privacy law applies to every business record. Exemptions and coverage depend on the relevant law and circumstances; they do not remove obligations that otherwise apply.

1515. Third-Party Services and Links

Our Services may link to financing providers, electronic signature services, account verification services or other third-party websites. Their own notices may govern information they collect directly. Review those notices before submitting information. We remain responsible for obligations applicable to our own disclosures and processing; a third-party policy does not waive those responsibilities.

1616. Location of Processing

Our Services are intended for businesses seeking financing in the United States. Information may be processed where we and our service providers operate, subject to applicable legal protections. If information is transferred internationally, we apply any safeguards required by applicable law. Merely using our website does not waive your privacy rights.

1717. Children

Our Services are intended for adults acting for business purposes and are not directed to individuals under 18. We do not knowingly collect personal information from minors. If you believe a minor has provided information, contact us so we can investigate and take appropriate deletion or other legally required action.

1818. Changes to This Policy

We may update this Policy to reflect changes in our practices, Services or legal requirements. We will post the revised Policy and update the dates above. For material changes, we will provide additional notice and obtain consent where required. Posting a new policy does not retroactively authorize incompatible uses of information collected under earlier promises.

1919. Contact Us