Privacy Policy

Information We Collect

Palermo Financial Group, LLC ("Palermo," "we," "us," or "our") collects information from borrowers, borrowing entities, and authorized representatives who submit loan inquiries, construction draw requests, loan payoff requests, ACH authorizations, and other servicing requests through our website and forms. The information we collect includes:

• Names and full legal names
• Email addresses and phone numbers
• Borrower and borrowing entity names
• Loan numbers
• Property addresses
• Loan inquiry information
• Construction draw request details
• Loan payoff request details
• ACH authorization information
• Bank names and account types
• Last 4 digits of account and routing numbers
• Supporting documents (bank statements, photos, invoices, permits, title documents, closing documents, attorney requests, insurance documents, tax documents, and other borrower-submitted materials)

How We Use Information

We use the information you provide to process your loan inquiries, evaluate your loan applications, process construction draw requests, prepare payoff statements, set up ACH payments, manage your account, communicate with you, verify information, comply with legal obligations, prevent fraud, and improve our services. Information may be used by Palermo staff, authorized contractors, service providers, appraisers, inspectors, title companies, attorneys, loan servicers, payment processors, regulators, and other parties involved in processing your request.

Uploaded Documents and Private File Storage

Documents uploaded through Palermo's borrower forms are intended to be stored using private file storage. Authorized Palermo personnel and service providers may access these documents for business purposes. In some cases, internal access may be provided through time-limited signed links. Although Palermo uses reasonable safeguards designed to protect uploaded documents, no system can be guaranteed to be 100% secure.

Construction Draw Requests

When you submit a construction draw request, we may collect property information, borrower details, draw request amounts, work descriptions, supporting photos or documents, and the last 4 digits of the bank account on file for verification purposes. This information is used to review your draw request, conduct inspections if required, verify compliance with loan documents, and process approved draws.

Loan Payoff Requests

When you submit a loan payoff request, we collect property address, loan number, borrower entity name, requestor information, payoff date requirements, and supporting documents. This information is used to prepare an accurate payoff statement reflecting current loan balance, accrued interest, and any other charges due.

ACH Debit Authorization

When you authorize ACH debits, we collect borrower information, bank name, account type, routing number last 4 digits, account number last 4 digits, and supporting bank documents. This information is used to verify your authorization and set up electronic payments for your loan.

Banking and Payment Information

Palermo Financial Group does not store full account numbers or routing numbers as structured form fields in its borrower forms. For ACH authorization, Palermo may collect bank name, account type, the last 4 digits of account and routing numbers, and supporting bank documents such as voided checks or bank letters. Supporting bank documents may contain full banking information and are intended to be stored using private file storage and accessed only by authorized personnel or through time-limited signed links.

Information Sharing

We may share your information with third parties as necessary to process your requests, including service providers, attorneys, title companies, appraisers, inspectors, lenders, payment processors, loan servicers, regulators, and technology vendors. We may also disclose information if required by law, court order, or regulatory authority.

Data Retention

We retain information for as long as necessary to process your request, fulfill our legal obligations, and maintain records as required by law. Information may be retained for the duration of your loan and for a reasonable period thereafter to comply with regulatory and accounting requirements.

Security

Palermo Financial Group uses reasonable administrative, technical, and organizational safeguards designed to protect your information. However, no system can be guaranteed to be 100% secure. We encourage you to submit information only through secure channels and to protect your own confidential information.

User Responsibilities

You are responsible for ensuring that all information you submit is accurate, truthful, complete, and authorized. You acknowledge that misrepresentation or submission of unauthorized information may result in denial of your request or legal consequences.

Third Party Services

Our website may contain links to third-party websites and services. Palermo is not responsible for the privacy practices of third parties. We encourage you to review their privacy policies before submitting information.

No Sale of Personal Information

Palermo Financial Group does not sell borrower personal information to third parties for marketing or commercial purposes.

Website Usage Data

When you visit our website, we may automatically collect certain technical information, including your IP address, browser type, referring URLs, device information, pages visited, and the dates and times of your visits. We may use cookies or similar technologies to improve website functionality, analyze website traffic, maintain security, and understand how visitors interact with our website. You may disable cookies through your browser settings, though this may affect certain website features.

Your Information Rights

You may contact us to request access to, correction of, or deletion of personal information we hold about you, subject to applicable law, identity verification, fraud prevention, and our legal, regulatory, and business record retention obligations.

Governing Law

This Privacy Policy shall be governed by and interpreted in accordance with the laws of the State of Florida, without regard to conflict of law principles.

Relationship to Other Privacy Notices

This website Privacy Policy describes Palermo's general website and form practices. If a separate privacy notice is required by applicable law or by the nature of a specific customer relationship, that notice will supplement this policy and will control to the extent required by law.

Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated "Last Updated" date. Your continued use of our services after changes constitutes your acceptance of the updated policy.

Cross-References

This Privacy Policy should be read together with our Terms of Use, Electronic Communications Consent, and Legal & Lending Disclosures.

Contact Information

If you have questions about this Privacy Policy or our privacy practices, please contact us at: