Privacy Policy

Effective Date: May 28, 2026

Siena Lending Group (“Siena Lending”, “we”, “us” or “our”) has adopted this privacy policy (“Privacy Policy”) to explain how we collect, use, disclose and otherwise process the information learned about you from your interactions with us, including but not limited to your visits to our websites, including https://ablserve.com/ (opens in a new tab) (opens in a new tab) (the “Site”).

PLEASE REVIEW THIS PRIVACY POLICY CAREFULLY. When you provide us with your information, including when you visit our Site, you accept the terms of this Privacy Policy, and consent to our collection, use, disclosure, retention and other processing of your information as described in this Privacy Policy. 

1. Information We Collect

1a. Personal Information

Siena Lending collects personal information about you, which may include:

• Identifiers: name, mailing address, unique personal identifier, online identifier, Internet Protocol (“IP”) address, email address, login information (e.g., username and password).
• Categories Listed in the California Customer Records Statute: telephone number, bank account number or any other payment information (e.g., account name, routing number).
• Commercial Information: details of your specific transactions with us, information about your preferences (e.g., account settings, if applicable, and marketing preferences).
• Internet or Other Electronic Network Activity Information: IP address, access times and dates, approximate geographic location, operating system type, browser type, device type, your interaction with our Site, browsing URLs, and other technical information such as protocol status and substatus, bytes sent and received, and server information.
• Geolocation Data: approximate geographic location based on IP address or your zip code.
• Audio, Electronic, Visual or Similar Information: call recordings.
• Professional or Employment-Related Information: company name, job title, job description/function, business email address, business address.
• Inferences and Profiles based on other Personal Information: information about your account.
• Sensitive Personal Information: account log-in.
• Miscellaneous: Any information you may provide when you contact us. 

This information is collected when you:

• Access or use our Site
• Register an account with us
• Purchase and/or obtain our financing solutions and related services
• Contact us.

Where permitted by applicable law, we may combine your personal information with other information we have collected from you. We may also combine your personal information with information we receive about you from other sources, such as our service providers, our website analytics partners, third parties to determine a debtor’s credit worthiness and retrieve borrowers’ recent news (e.g., management changes), and publicly available information. 

1b. Information Collected Automatically

In addition, Siena Lending may automatically collect information about your device’s hardware and software when you use the Site. This information may include:

• IP address
• Access times and dates
• Approximate geographic location
• Operating system type
• Browser type
• Device type
• Browsing URLs
• Other technical information such as protocol status and substatus, bytes sent and received, and server information

We may also collect information regarding traffic patterns and your interaction with our Site. This information is used by us for our business purposes, including for the operation and improvement of the Site, for technical troubleshooting, to maintain the quality of the Site and to provide general statistics regarding use of the Site.

We may also receive similar data from our website analytics partners and may share this data with such third parties. 

1c. Cookies and Other Information Collection Tools

Cookies

A cookie is a small file containing a string of characters that is sent to your computer when you visit a website or use an online service. When you visit the website or use the service again, the cookie allows that website or online service to recognize your browser or device. Cookies may store unique identifiers, user preferences and other information. 

We may use “session cookies” or “persistent cookies.” Session cookies are temporary and expire once you close your browser or once your session ends. Persistent cookies remain on your device for much longer or until you or your browser erase them. Persistent cookies have varying durations that are dependent on their expiration date. 

We may also use third-party cookies, like Google Analytics, for example, which sets cookies on the Site to help analyze how visitors use the Site. You can visit https://www.google.com/settings/ads (opens in a new tab) to learn more about Google’s use of cookies. If you would like to opt-out from the use of your information by Google Analytics, you may use Google Analytics’ opt-out browser add-on (opens in a new tab) designed for this purpose. Please note that information collected via third-party cookies may be shared with our website analytics partners.

Cookies help us improve the Site by providing us with information about which parts of the Site are most popular, enabling us to analyze technical and navigational information about the Site, and helping us to detect and prevent fraud. We also use cookies and other data collection tools to help improve your experience with the Site.

Web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to manage and delete cookies, visit www.allaboutcookies.org (opens in a new tab) (opens in a new tab). Some web browsers provide settings that allow a user to reject cookies or to alert a user when a cookie is placed on the user’s computer, tablet or mobile device. Most mobile devices also offer settings to reject mobile device identifiers. Although users are not required to accept cookies or mobile device identifiers, blocking or rejecting them may prevent access to some features available through the Site and/or may not allow the Site to function properly. You may also manage your cookie preferences by emailing privacy@sienalending.com.

2. How Information is Used

We may use the information we collect for any of the following purposes:

• to provide the Site to you and to improve the Site;
• to operate and personalize the solutions and services we offer, and to give each user a more consistent and personalized experience when interacting with us;
• to deliver information about our solutions and services that we think may interest you;
• to create and manage your account with us;
• to keep records and track the entire lifecycle of a loan you may obtain from or through us, including disbursements, payments, interest calculations and remaining balances;
• to calculate and determine your entity’s borrowing availability;
• to facilitate the underwriting process;
• for security, to detect fraud or illegal activities, and for archival and backup purposes in connection with the provision of the Site;
• to respond to your inquiries and communicate with you;
• for any purpose for which we obtained your consent; 
• for our other business purposes, such as authentication, data analytics, accounting, auditing and reporting, developing new or improving our solutions and services and identifying Site usage trends;
• as we believe to be necessary or appropriate: (i) under applicable law; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities; (iv) to enforce this Privacy Policy; (v) to protect our operations; (vi) to protect our rights, privacy, safety or property, and/or that of you or others; and (vii) to allow us to pursue available remedies or limit the damages that we may sustain.

3. Disclosure of Information

 We may disclose your information:

• With Third Party Service Providers Performing Services on Our Behalf. We share your personal information with our service providers to perform the functions for which we engage them. For example, we may use third parties to host the Site or assist us in providing functionality or security on the Site, provide data analytics on the Site, send out email updates about the Site and our solutions and services.
• Through Tracking Technologies. We may share information collected through tracking technologies set on the Site with our website analytics partners, including but not limited to cookies as described above.
• For Legal Purposes. We also may share information that we collect from users as needed to enforce our rights, protect our property or protect the rights, property or safety of others, or as needed to support external auditing, compliance and corporate governance functions. We will disclose personal information as we deem necessary to respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental or law enforcement request or other legal or regulatory process. We may also share personal information as required to pursue available remedies or limit damages we may sustain. 
• Changes of Control. We reserve the right to transfer or assign the information that we have collected from users in connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

4. Links to External Websites and Online Services

Our Site may contain links to third-party websites and online services. Any access to and use of such third-party websites and online services is not governed by this Privacy Policy, but is instead governed by the privacy policies of those third-party websites and online services, and we are not responsible for the information practices of such third-party websites and online services.

5. Your Rights and Choices

5a. Opt-out

You may choose to stop receiving our marketing emails by following the unsubscribe instructions included in such emails or contacting us at privacy@sienalending.com. Please note that opting out of receiving marketing emails will not impact the informational or administrative emails we may send to you, including emails relating to activities on your account (e.g., month end fees, charges, advance requests, upcoming Site maintenance notices, holiday closure, etc.).

6. Data Security and Retention

Siena Lending uses reasonable security measures designed to prevent unauthorized intrusion to the Site and the alteration, acquisition or misuse of personal information. However, please note that no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. It is your responsibility to protect the security of your login information. You are the sole authorized user of any account you create through the Site and are solely and fully responsible for all activities that occur under your account. You may not authorize others to use your accountholder status or share your credentials, and you may not assign or otherwise transfer your account to any other person or entity. If you do so, we reserve the right to suspend or terminate your account and refuse any and all current or future use of the Site (or any portion thereof).

We will retain your personal information for as long as necessary to fulfill the purpose for which it was collected, or as required by applicable laws or regulation.

7. Do Not Track

Our Site does not currently take any action when it receives a Do Not Track request. Do Not Track is a privacy preference that you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For details, including how to turn on Do Not Track, visit www.donottrack.us (opens in a new tab) (opens in a new tab).

8. Children

We do not knowingly collect or maintain personal information from any person under the age of 16. No parts of our Site are directed to or designed to attract anyone under the age of 16. 

9. Nevada Residents

Under Nevada law, Siena Lending does not sell your personal information. However, if you are a Nevada resident, you may submit a request that we not sell any personal information we have collected about you by contacting us at privacy@sienalending.com. 

10. California Residents

CCPA

The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, and its implementing regulations (“CCPA”) provides California residents with specific rights regarding their personal information. The below describes such rights and how you may exercise such rights, and our information practices, including the categories of personal information we collect, use, retain, disclose, sell or share, and how and why we collect, disclose, sell or share such information. 

CCPA Rights

Right to Know

You have the right to request that we disclose what personal information we collect, use, disclose, sell or share. Specifically, you may request that we disclose to you the following:

1. The categories of personal information we have collected about you.
2. The categories of sources from which the personal information is collected.
3. The business or commercial purpose for collecting, selling or sharing personal information.
4. The categories of third parties with whom we disclose personal information.
5. The specific pieces of personal information we have collected about you.

You may also request that we disclose to you:

1. The categories of personal information that we have sold or shared about you and the categories of third parties to whom the personal information was sold or shared, by category or categories of personal information for each third party to whom the personal information was sold or shared.
2. The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.

Right to Delete

You have the right to request that we delete any personal information about you which we have collected from you. If it is necessary for us to maintain your personal information for certain purposes, we are not required to comply with your deletion request. If we determine that we will not delete your personal information when you request us to do so, we will inform you and tell you why we are not deleting it. 

Right to Opt-Out of Sale or Sharing of Personal Information

You have the right to direct a business that sells or shares personal information about you to third parties not to sell or share your personal information. We do not sell your personal information for monetary consideration. However, we do use tracking technologies such as cookies for analytics purposes. The collection of data through certain tracking technologies for analytics purposes may be considered a “sale” under the CCPA. To opt-out of having your information sold and shared with third-party website analytics partners for this purpose, email privacy@sienalending.com. 

The CCPA requires businesses to process opt-out preference signals (“OOPS”), such as global privacy control (“GPC”) signals, which are signals sent by a platform, technology or mechanism, enabled by individuals on their devices or browsers, that communicate the individual’s choice to opt-out of the sale and/or sharing of personal information. To use an OOPS/GPC, you can download an internet browser or a plugin to use on your current internet browser and follow the settings to enable the OOPS/GPC (for example, https://globalprivacycontrol.org/ (opens in a new tab) (opens in a new tab)). We have configured the settings of our consent management platform to receive and process GPC signals on our Site.

Siena Lending does not have actual knowledge that it sells or shares personal information about minors under the age of 16.

Right to Correct Inaccurate Personal Information

You have the right to request a business that maintains inaccurate personal information about you to correct that inaccurate personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.

Right to Limit Use and Disclosure of Sensitive Personal Information

You have the right to direct a business that collects sensitive personal information about you to limit its use of your sensitive personal information (1) to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services; (2) for certain business purposes; and (3) as authorized by the implementing regulations of the CCPA. Siena Lending does not use or disclose your sensitive personal information for any purpose other than those permitted under the CCPA.

No Discrimination

You have the right not to be discriminated against because you exercised any of your aforementioned rights. 

How to Submit a Request

To exercise the rights to know, delete and correct described above, you must submit a verifiable request to us. You can do so by calling us at 203.883.5666, completing this form, or emailing privacy@sienalending.com. 

To submit a verifiable request, you will be asked to provide certain information to help us verify your identity. The information we ask you to provide to initiate a request may differ depending upon the type of request, the type, sensitivity and value of the personal information that is the subject of the request, and the risk of harm to you that may occur as a result of unauthorized access or deletion, among other factors.

You may designate an authorized agent to make a request on your behalf by providing the agent with signed written permission to do so.

If we cannot verify your identity or authority to make the request, we will not be able to comply with your request. We will inform you if we cannot verify your identity or authority. We will only use personal information provided in a verifiable request to verify the requestor’s identity or authority to make the request. 

How We Collect, Use, Disclose, Sell and Share Personal Information

Please see Section 1 (Information We Collect) for the categories of personal information we have collected about you in the twelve (12) months prior to the effective date of this Privacy Policy. Each of the categories are disclosed for a business or commercial purpose as described above in Section 2 (How Information is Used) to the third parties listed in Section 3 (Disclosure of Information).

Siena Lending collects the personal information described in Section 1 (Information We Collect) from or through the following categories of sources:

• You, directly and indirectly, including when you access or use the Site, register an account with us, purchase and/or obtain our financing solutions and related services or contact us; 
• Service providers
• Website analytics partners;
• Third parties, to determine a debtor’s credit worthiness and retrieve borrowers’ recent news (e.g., management changes)
• Publicly available information.

As noted in Section 6 (Data Security and Retention), we will retain the personal information described above for as long as necessary to fulfill the purpose for which it was collected, or as required by applicable laws or regulations. 

The following categories of personal information were sold or shared in the twelve (12) months prior to the effective date of this Privacy Policy:

• Identifiers: unique personal identifier, online identifier, IP address.    
• Internet or Other Electronic Network Activity Information: IP address, access times and dates, approximate geographic location, operating system type, browser type, device type, your interaction with our Site, browsing URLs, and other technical information such as protocol status and substatus, bytes sent and received, and server information.
• Geolocation Data: approximate geographic location based on IP address or your zip code.

Such information is sold to or shared with our third-party website analytics partners. 

We share or sell such information:

• to provide the Site to you and to improve the Site;
• to operate and personalize the solutions and services we offer, and to give each user a more consistent and personalized experience when interacting with us;
• for security, to detect fraud or illegal activities, and for archival and backup purposes in connection with the provision of the Site;
• to respond to your inquiries and communicate with you;
• for our other business purposes, such as authentication, data analytics, accounting, auditing and reporting, developing new or improving our solutions and services and identifying Site usage trends;
• as we believe to be necessary or appropriate: (i) under applicable law; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities; (iv) to enforce this Privacy Policy; (v) to protect our operations; (vi) to protect our rights, privacy, safety or property, and/or that of you or others; and (vii) to allow us to pursue available remedies or limit the damages that we may sustain.

Shine the Light

Under California Civil Code Section 1798.83, also known as California’s “Shine the Light” law, if you are a California resident, you have a right to prevent your personal information from being disclosed to third parties for those third parties’ direct marketing purposes. If you would like to exercise this right, please email privacy@sienalending.com.

11. Questions / Contact Us

If you have any questions regarding this Privacy Policy, please contact us by completing this form or emailing us at privacy@sienalending.com.

12. Notification of Changes

Any changes to our Privacy Policy will be posted to this page so users are always aware of the information we collect and how we use it. Accordingly, please refer back to this Privacy Policy frequently as it may change.