Privacy Policy

Last updated 21 October 2026

This policy explains what Cole Benefit Group INC, doing business as CBG Funds ("CBG Funds", "we", "us"), collects from you, why we collect it, who we share it with, and what you can ask us to do about it. KLIERD is the funding platform we operate; information you give us through KLIERD is held by CBG Funds under this policy.

We are a financial services business. Much of what you give us is sensitive by nature, and some of it is protected by federal law. We have tried to write this plainly rather than defensively.

1. Who to contact

Company	Cole Benefit Group INC, d/b/a CBG Funds
Registered	State of Georgia, United States
Email	info@cbgfunds.com
Mailing address	3379 Peachtree Rd NW, Atlanta, GA

Email is the fastest way to reach us about anything in this policy, including a request to see, correct or delete what we hold about you.

2. What we collect

Information you give us

Identity — name, date of birth, Social Security number or ITIN, and a government-issued photo ID.
Contact — email address, mobile and other phone numbers, mailing and property addresses.
Financial — bank account and routing numbers, statements, income, existing debts and monthly obligations.
Business — business name, EIN, entity type, time in business and use of funds.
Property — address, estimated value, and balances on any existing mortgage or lien.
Documents — anything you upload to your portal, and anything you send to us by email.

Information we obtain about you

Credit reports and scores from consumer reporting agencies, with your authorisation.
Identity verification results from our verification provider, including whether the name on your ID matches your file.
Signature and audit records from our e-signature provider, including the time and IP address of signing.

Information collected automatically

Sign-in records, IP address, browser and device type, and the pages you open in your portal.
Whether and when our emails to you were delivered.

We do not collect this information to build a profile of you for advertising. We collect it because a funding file cannot be assembled, verified or submitted to a lender without it.

3. Text messages (SMS)

We do not sell, rent or share your mobile phone number, or your consent to receive text messages, with any third party or affiliate for their own marketing purposes. Mobile information is shared only with the service providers that deliver our messages for us, and those providers may not use it for anything else.

Two separate consents

We ask for your agreement to text you in two separate places, and you can agree to one without the other:

Service messages — your sign-in code, the status of your file, document requests, and appointment reminders. These relate to a file you asked us to open.
Marketing messages — offers and information about funding programmes. This is a separate, optional box. It is never ticked for you, and declining it has no effect on your application.

Frequency, cost and how to stop

Message frequency varies. Service messages depend on activity on your file; marketing messages are limited to no more than six per month.
Message and data rates may apply. Your mobile carrier's charges are between you and your carrier.
Reply STOP at any time to end messages. We will send one confirmation and then stop.
Reply HELP for help, or email info@cbgfunds.com.
Carriers are not liable for delayed or undelivered messages.
Stopping texts does not withdraw your application or close your file. We will reach you by email instead.

4. How we use your information

To verify who you are, which federal law requires us to do.
To assess a request for funding and assemble a file for submission.
To submit your file to lenders you have authorised us to approach.
To prepare, send and store the agreements you sign.
To contact you about your file by email, text or phone.
To take payment of fees owed under your agreement with us.
To keep records we are required by law to keep, and to detect and prevent fraud.
With your separate consent, to tell you about funding programmes that may suit you.

5. Who we share it with

We share only what the recipient needs, and only for the reasons below. We do not sell your personal information.

Who	What for
Lenders and funding partners	To seek an offer on your behalf, when you have authorised that submission.
Consumer reporting agencies	To obtain your credit report with your authorisation.
Identity verification provider	To confirm your identity from your government ID.
E-signature provider	To deliver and store documents you sign.
Email and SMS providers	To deliver our messages to you, and nothing else.
Payment processor	To take payment of fees owed under your agreement.
Hosting and storage provider	To run the platform and store your documents securely.
Referral partners	If a partner referred you, we confirm the status of your file to them. They do not see your Social Security number, bank details or credit report.
Professional advisers	Our attorneys and accountants, where they need it.
Authorities	Where a law, subpoena or regulator requires it.

6. Your financial information is protected by federal law

As a financial services business, we are subject to the Gramm-Leach-Bliley Act. It limits what we may do with the non-public personal information you give us and requires us to protect it. We do not disclose that information to anyone except as described in this policy or as the law permits.

7. How we protect it

Information is encrypted in transit and at rest.
Bank account and routing numbers are stored encrypted.
Access is granted per person, by area, and staff see only the areas they are assigned.
Viewing a full Social Security number is restricted and recorded.
Sign-ins to the platform are recorded and staff sessions expire automatically.

No system is perfectly secure, and we will not claim otherwise. If a breach affects your information we will notify you as the law requires.

8. How long we keep it

We keep your file for as long as you are a client and afterwards for as long as we are required to — generally seven years for tax, lending and anti-fraud records, and longer where a specific law or a dispute requires it. When a retention period ends we delete or anonymise the record.

9. Your choices and rights

Access — ask for a copy of what we hold about you.
Correction — ask us to fix anything inaccurate.
Deletion — ask us to delete your information, subject to the records we must keep by law.
Marketing — opt out of marketing email or text at any time, without affecting your file.
Credit report disputes — inaccuracies on a credit report are raised with the reporting agency; we will tell you how.

We work with clients across the United States, and several states — California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon and others — give their residents specific privacy rights. Rather than make you work out which law applies to you, we extend the rights above to everyone, in every state.

Where your state gives you a right we have not listed, you keep it. In particular, we do not sell personal information or share it for cross-context behavioural advertising, so there is nothing for you to opt out of on that front. We will not treat you differently for exercising any of these rights.

To make a request, email info@cbgfunds.com. We may need to verify your identity first — the information involved is sensitive enough that we would rather check than hand it to the wrong person. We will respond within the time the law allows, and if we have to refuse part of a request we will say which part and why.

10. Children

Our services are for adults. We do not knowingly collect information from anyone under 18. If we learn we have, we delete it.

11. Changes

If we change this policy we will update the date at the top. If the change materially affects how we use your information, we will tell you directly.