PRIVACY POLICY

INTRODUCTION

Who We Are

United Direct Lending operates the Elite Partner Program under the brand name "UDL Elite Partners."

Legal Entity: United Direct Lending

• NMLS #: 1749719
• Established: 2017
• Licensed in: FL, TX, CA, NJ, VA, CO

How We Operate

We are a direct lender, not a broker or referral service.

This means:

• All loan processing done internally by United Direct Lending
• We do NOT refer you to other lenders
• We do NOT sell your information to other mortgage companies
• You work directly with our licensed loan officers start to finish

What is UDL Elite Partners?

The consumer-facing program offering qualified homebuyers potential cash-back incentives (up to $15,000) when they finance their mortgage through United Direct Lending. Typical cash-back amounts range from $6,000 to $15,000 depending on loan amount and eligibility.

This Privacy Policy

Explains how we collect, use, share, and protect your information when you visit udlelitepartner.com or use our services.

We comply with:

• Gramm-Leach-Bliley Act (GLBA)
• California Consumer Privacy Act (CCPA)
• Fair Credit Reporting Act (FCRA)
• Telephone Consumer Protection Act (TCPA) - All applicable state and federal privacy laws

By using our services, you agree to this Privacy Policy.

INFORMATION WE COLLECT

You Provide to Us:

• Contact: Name, email, phone, address
• Financial: SSN, income, employment, assets, debts, credit history (for loans)
• Property: Address, purchase price, loan amount, timeline
• Communications: Messages, calls, chatbot conversations
• Professional (Agents): License info, brokerage

Collected Automatically:

• Website: IP address, browser type, pages viewed, time on site
• Cookies: Analytics, advertising pixels, tracking

From Others:

• Credit bureaus (credit reports)
• Employers (income verification - with your permission)
• Real estate agents who refer you
• Public records

HOW WE USE YOUR INFORMATION

To Provide Services:

• Process mortgage applications internally
• Determine eligibility for loans and cash-back
• Communicate about your application
• Schedule appointments
• Coordinate closing

For Marketing (with consent):

• Send educational content and updates
• Show relevant ads
• Conduct surveys

For Legal Compliance:

• Comply with GLBA, RESPA, TILA, ECOA, Fair Housing Act, HMDA
• Respond to legal requests
• Prevent fraud
• Maintain records (5-7 years)

For Analytics:

• Improve website
• Track marketing effectiveness
• Understand customer behavior

HOW WE SHARE YOUR INFORMATION

We do NOT sell your personal information.

Internal (United Direct Lending):

• Loan officers, underwriters, processors, support staff
• No referrals to external lenders

Service Providers:

• Credit bureaus, appraisers, title companies
• Technology: HighLevel (CRM), Google Analytics, Facebook Pixel, Cometly, LC Email (email service), LC Phone (SMS service), AI Employee (AI chatbot platform)

Your Real Estate Agent:

• To coordinate your purchase (if applicable)
• Agent may receive compensation (RESPA-compliant)

Legal Authorities:

• When required by law
• Government regulators, law enforcement

All service providers must protect your information and use it only for authorized purposes.

FINANCIAL PRIVACY NOTICE (GLBA)

Annual Privacy Notice under federal law

United Direct Lending
NMLS #: 1749719
Licensed in: FL, TX, CA, NJ, VA, CO
Verify: www.nmlsconsumeraccess.org

Address:
5550 Glades Rd Suite 500 Boca Raton, FL 33431

Information We Share:

We share information for everyday business purposes, such as processing and underwriting. This type of information sharing cannot be opted out of.

We also share information for our own marketing purposes. Customers have the option to opt out of this type of sharing.

For joint marketing, the details about whether we share information and whether you can opt out are currently to be determined.

We do NOT share information with nonaffiliates for marketing purposes. Therefore, there is no option to opt out since we do not share this information at all.

How We Protect Information:

• SSL/TLS encryption (256-bit)
• Firewalls and secure servers
• Access controls (employees access only what needed)
• Employee training
• Physical security (locked files, restricted access)

Your Rights:

• Opt out of marketing: [email protected] or (888) 249-7960
• Cannot opt out of: Information sharing necessary for loan processing or required by law

State-Specific Rights:

• California: Additional CCPA rights (Section 7)
• Vermont: Won't share with nonaffiliates except as permitted by law
• Nevada: Contact Bureau of Consumer Protection: (702) 486-3132

YOUR PRIVACY RIGHTS

Access:

Know what information we collected. Email [email protected] or call (888) 249-7960

Correct:

Request correction of inaccurate information

Delete:

Request deletion (with exceptions—we must keep loan records 5-7 years)

Opt Out:

• Email: Click "Unsubscribe" or email [email protected]
• SMS: Reply STOP
• Phone: Request Do Not Call list

Response time: 30-45 days

CALIFORNIA PRIVACY RIGHTS (CCPA)

Your Rights:

• Know what information we collect and how we use it
• Delete (with legal exceptions)
• Opt-out of "sale" or sharing for advertising
• Correct inaccurate information
• Non-discrimination for exercising rights

Do We "Sell" Information?

Not in traditional sense, but sharing for targeted ads may be considered "sale" under CCPA.

We do NOT sell: SSN, financial accounts, credit reports, loan details

We may share for ads: Contact info, demographics, website usage, device identifiers

To Opt-Out:

• Click "Do Not Sell My Personal Information" in footer (If link exists)
• Use Global Privacy Control (GPC)
• Email: [email protected]
• Call: (888) 249-7960

Sensitive Information:

We use sensitive data (SSN, financial accounts) only for:

• Processing loans
• Security/fraud prevention
• Legal compliance

Exercise Rights:

• Email: [email protected] (Subject: "California Privacy Request")
• Phone: (888) 249-7960
• Mail: United Direct Lending, Attn: CCPA, 5550 Glades Rd Suite 500 Boca Raton, FL 33431

Response: 45 days (may extend to 90 days)

COOKIES & TRACKING

Types:

• Necessary: Essential website functions (cannot disable)
• Analytics: Google Analytics tracks usage
• Marketing: Facebook Pixel, Cometly, Google Ads
• Functionality: Remember preferences

Manage Cookies:

• Browser settings (Chrome, Firefox, Safari, Edge)
• Opt-out: optout.networkadvertising.org, optout.aboutads.info

Do Not Track:

We don't don't respond to DNT, but honor Global Privacy Control (GPC) for California residents.

COMMUNICATIONS & CONSENT

Types:

• Transactional (cannot opt out): Loan updates, documents, closing notices
• Marketing (can opt out): Promotional emails, newsletters

Email:

Unsubscribe: Click link or email [email protected]

SMS:

By providing mobile number and consenting:

• Agree to texts from United Direct Lending via automated systems
• Frequency varies; message/data rates may apply
• Consent NOT required to apply for loan
• Opt out: Reply STOP
• Help: Reply HELP or call (888) 249-7960

Phone:

• May use automated dialing (with consent)
• Calls may be recorded
• Opt out: Request Do Not Call list

AI Chatbot:

• You're communicating with AI (Mariah Lee), not a human
• Conversations recorded
• AI can't provide advice or process loans
• Type "speak to a human" anytime
• Don't share SSN/passwords via chatbot

HOW WE PROTECT YOUR INFORMATION

Security Measures:

• Encryption: SSL/TLS (transmission), 256-bit (storage)
• Firewalls and intrusion detection
• Access controls: Multi-factor auth, role-based
• Monitoring: 24/7 security
• Employee training
• Physical security: Locked files, restricted access

Your Responsibility:

• Use strong passwords
• Don't share credentials
• Beware phishing
• Use secure connections
• Keep software updated
• Monitor accounts

Data Breach:

If breach occurs: Notify you within 30-60 days, notify authorities, provide protection steps

Data Retention:

• Loan files: 5-7 years
• Credit reports: 7 years
• Marketing: Until opt-out or 3 years inactivity
• Website analytics: 26 months

Secure Disposal: Secure deletion, shredding, physical destruction

THIRD-PARTY LINKS & SERVICES

Links to third-party sites (educational resources, social media). We're not responsible for their privacy practices. Review their policies before providing information.

Services We Use:

• CRM: HighLevel
• Analytics: Google Analytics
• Advertising: Facebook Pixel, Cometly
• Communications: LC Email (email service), LC Phone (SMS service), AI Employee (AI chatbot platform)

Each has own privacy policy and must protect your information.

CHILDREN'S PRIVACY

Services for 18+. We don't knowingly collect information from children under 13.

If we discover child's information: Delete immediately, notify parent

Parents: Contact [email protected] immediately if we have your child's info

INTERNATIONAL USERS

U.S.-Based:

United Direct Lending operates in U.S. Servers in U.S., licensed for U.S. services only.

If accessing from outside U.S.:

• Information transferred to U.S.
• U.S. laws apply
• By using services, you consent

EEA/UK (GDPR):

Not intended for EEA residents, but if visiting:

• Legal basis: Consent, contract, legitimate interests
• Your rights: Access, rectification, erasure, restriction, portability, object
• Contact: [email protected]

CHANGES TO PRIVACY POLICY

We may update this Policy anytime. For material changes, we'll provide notice via email or website banner.

Continued use = acceptance of updated Policy

CONTACT US

Privacy Questions:

Email: [email protected]

Phone: (888) 249-7960

Mail: United Direct Lending, Attn: Privacy Officer, 5550 Glades Rd Suite 500 Boca Raton, FL 33431

Customer Service:

Email: [email protected]

Phone: (888) 249-7960

Complaints:

CFPB: www.consumerfinance.gov/complaint or 1-855-411-2372

FTC: reportfraud.ftc.gov or 1-877-382-4357

Licensing:

NMLS #: 1749719

Verify: www.nmlsconsumeraccess.org

DISCLAIMERS

Equal Housing Lender: We don't discriminate based on race, color, religion, sex, handicap, familial status, or national origin.

Not Legal Advice: Consult attorney for specific legal concerns.

Acknowledgment: By using services, you've read and understood this Privacy Policy and consent to our practices.

END OF PRIVACY POLICY