Privacy Policy

Last Updated: April 6, 2026

Welcome to CityTown Capital. Your privacy is of paramount importance to us. This Privacy Policy explains how CityTown Capital (“we,” “us,” or “our”) collects, uses, discloses, and safeguards your information when you visit our website https://citytowncapital.com/ and use our services.

By using our services, you agree to the collection and use of information in accordance with this policy. We comply with the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA/CPRA), and other applicable international privacy standards.

1. Legal Basis for Processing (GDPR)

Under GDPR Articles 6 and 7, we process your personal data only when we have a valid legal basis:

  • Consent: You have given clear consent for us to process your data for a specific purpose (e.g., signing up for a newsletter).
  • Contract: Processing is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract (e.g., processing a loan application).
  • Legitimate Interests: Processing is necessary for our legitimate business interests, provided those interests do not override your fundamental rights (e.g., fraud prevention or website analytics).
  • Legal Obligation: Processing is necessary for us to comply with the law (e.g., financial reporting or tax obligations).

2. Information We Collect

We collect several types of information, including:

  • Identifiers: Name, mailing address, email address, phone number, and Social Security Number (where required for financial services).
  • Financial Information: Bank statements, credit history, and income details necessary for lending assessments.
  • Technical Data: IP address, browser type, and operating system.
  • Sensitive Personal Information: We may process government identifiers or financial login credentials solely to provide our lending services. We do not use this information to infer characteristics about you.

3. Your Rights and Choices

Regardless of your location, we honor the following rights:

GDPR (EU/UK Residents)

  • Access & Portability: Request a copy of your data in a structured format.
  • Rectification: Correct inaccurate or incomplete data.
  • Erasure (“Right to be Forgotten”): Request deletion of your data under certain conditions.
  • Restriction & Objection: Limit how we use your data or object to its processing.
  • Automated Decision-Making: The right not to be subject to a decision based solely on automated processing which produces legal effects.

CCPA/CPRA (California Residents)

  • Right to Know: Request disclosure of what personal information we collect and how it is used.
  • Right to Opt-Out: You have the right to opt-out of the “sale” or “sharing” of your personal information. CityTown Capital does not sell your personal data.
  • Right to Non-Discrimination: We will not deny services or change prices if you exercise your privacy rights.

4. Cookies & Consent Policy

We use cookies to enhance your experience. Cookies are small files stored on your device.

  • Essential Cookies: Necessary for the website to function (e.g., security and session management). These do not require prior consent.
  • Non-Essential Cookies: We use analytics and marketing cookies to understand user behavior. These require your explicit opt-in.

Managing Consent: You can adjust your cookie preferences at any time via the “Cookie Settings” banner on our website or through your browser settings.

5. International Data Transfers

CityTown Capital is based in the United States. If you are accessing our site from the EEA, UK, or Switzerland, your data will be transferred to and processed in the U.S. To ensure your data remains protected, we utilize Standard Contractual Clauses (SCCs) approved by the European Commission and implement supplementary technical safeguards.

6. Data Security Measures

We take data security seriously and have implemented the following:

  • Encryption: All sensitive data is encrypted at rest and in transit using TLS/SSL protocols.
  • Access Controls: Access to personal data is restricted to authorized employees with a “need-to-know” basis.
  • Audits & Training: We conduct regular security audits and provide mandatory privacy training for all staff handling sensitive information.
  • Network Security: We utilize firewalls, intrusion detection systems, and regular vulnerability scanning.

7. Data Retention

We retain personal information only for as long as necessary to fulfill the purposes outlined in this policy, or as required by law.

  • Loan Applications: Retained for the duration of the loan plus statutory periods (typically 7 years) for regulatory compliance.
  • Marketing Data: Retained until you withdraw consent or unsubscribe.

8. Children’s Privacy

Our services are not intended for individuals under the age of 18. We do not knowingly collect data from children under 13 (COPPA) or 16 (GDPR). If we become aware that we have inadvertently collected such data, we will take immediate steps to delete it.

9. Data Sale and Sharing Disclosure

  • Sale of Data: CityTown Capital does not sell your personal information to third parties for monetary consideration.
  • Sharing of Data: We share data with trusted service providers (e.g., credit bureaus, cloud hosting, payment processors) strictly to facilitate our services. These providers are contractually bound to protect your data.

10. Contact Information

If you have questions about this policy or wish to exercise your rights, please contact our Privacy Team:

CityTown Capital
100 Overlook Center, Floor 2
PRINCETON, NJ 08540-7814
Email: loans@citytowncapital.com

11. Updates to This Policy

We may update this Privacy Policy to reflect changes in our practices or legal obligations. When we do, we will revise the “Last Updated” date at the top of this page. We encourage you to review this policy periodically.

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