ADDITIONAL CALIFORNIA PRIVACY DISCLOSURES
Effective Date: 1/1/2020
Last Revised on: 12/30/2019
Scope of Disclosures
These Additional California Privacy Disclosures (the “CA Disclosures”) supplement the information contained in our Online Privacy Statement and apply solely to individual residents of the State of California (“consumers” or “you”).
These CA Disclosures describe how we collect, use, disclose and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 (“CCPA”).
Unless otherwise expressly stated, all terms in these CA Disclosures have the same meaning as defined in our Online Privacy Statement or as otherwise defined in the CCPA.
Personal Information Disclosures
When we use the term “personal information” in these CA Disclosures, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
For the purposes of these CA Disclosures, personal information does not include:
- Publicly available information from government records.
- Deidentified, aggregated or information that is maintained in a form that is not reasonably capable of being associated with or linked to you.
- Information excluded from the CCPA’s scope, such as information covered by certain sector-specific privacy laws, including the Gramm-Leach-Bliley Act (“GLBA”).
- Information relating to job applicants, employees, contractors, and other of our personnel.
Collection and Use of Personal Information
In the last 12 months, we have collected the following categories of personal information from the categories of sources and for the purposes set forth below:
|Category||Examples||Does the Company collect this Category of Information?||Categories of Sources from which the Information was Collected||Business Purpose|
|A. Identifiers||A real name, postal address, Internet Protocol address, email address, and other online identifiers||YES||Consumer directly||To provide our Services, to contact you as requested, and to otherwise market to you|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))||Address and telephone number. Some personal information included in this category may overlap with other categories||YES||Consumer directly||To provide our Services, to contact you as requested, and to otherwise market to you|
|C. Protected classification characteristics under California or federal law||Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, veteran or military status, genetic information||NO||N/A||N/A|
|D. Commercial information||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies||NO||N/A||N/A|
|E. Biometric information||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, gait, or other physical patterns, and sleep, health, or exercise data||NO||N/A||N/A|
|F. Internet or other similar network activity||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement||YES||Consumer directly (through your browser or device)||To provide our Services and to market to you|
|G. Geolocation data||Your general location or more precise location to the extent permitted by law||YES||Consumer directly (through your browser or device)||To provide our Services and to market to you|
|H. Sensory data||Audio, electronic, visual, thermal, olfactory, or similar information||NO||N/A||N/A|
|I. Professional or employment-related information||Current or past job history or performance evaluations||NO||N/A||N/A|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records||NO||N/A||N/A|
|K. Other personal information||Personal information you provide us in relation to a question, request or inquiry||YES||Consumer directly||To provide our Services, to contact you and to otherwise market to you|
|L. Inferences drawn from other personal information||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes||NO||N/A||N/A|
For more information about how we collect and use personal information, please refer to the “How We Collect and Use Information” section of our Online Privacy Statement
Disclosure and Sale of Personal Information
In the last 12 months, we have not sold personal information about you, but we have disclosed for a business purpose the following categories of personal information, which reference the categories of personal information described above:
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
- Internet or other similar network activity
- Geolocation data
- Other personal information
The categories of third parties to whom we have disclosed personal information for a business purpose may include:
- Our subsidiary;
- Servicers Providers processing personal information on our behalf.
For more information on how we disclose personal information, please refer to the “Sharing of Your Personal Information” section of our Online Privacy Statement.
California Privacy Rights
The CCPA provides certain consumers the following rights in relation to their personal information (subject to certain limitations at law):
- Right to Know: Consumers have the right to
request any or all of the following information relating to their personal
information collected or disclosed in the last 12 months, upon verification of
- The specific pieces of personal information collected about them;
- The categories of personal information collected about them;
- The categories of sources of the personal information collected about them;
- The categories of their personal information disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
- The categories of their personal information sold (if any), and the categories of third parties to whom this information was sold; and
- The business or commercial purposes for collecting or, if applicable, selling their personal information.
- Right to Deletion: Consumers have the right to request the deletion of personal information collected from them, subject to certain exceptions and upon verification of their identity.
Consumers also have the right to be free from discrimination for exercising these rights.
Please note, if you have not inquired about, applied for or obtained a financial product or service from us, we do not accept Right to Know or Right to Deletion requests because we do not maintain sufficient information to be able to match the information you could provide and verify your identity to the degree of certainty required to process your request.
If you have inquired about, applied for or obtained a financial product or service from us, we provide specific disclosures and rights applicable to you in a separate notice available here. We do not maintain personal information about you that is not subject to this separate notice (such as general internet or other similar network activity) in a form that could reasonably be connected to you. As a result, we do not otherwise accept Right to Know or Right to Deletion requests under the CCPA at this time.
If you have any questions about these disclosures or the rights described above, please contact us as set forth in the Contact Us section below.
Updates to These CA Disclosures
We will update these CA Disclosures from time to time. When we make changes to these CA Disclosures, we will change the date at the beginning of these CA Disclosures. All changes shall be effective from the date of publication unless otherwise provided.
If you have any questions or requests in connection with these CA Disclosures or other privacy-related matters, please send an email to email@example.com or phone us at 866-219-7753.
Alternatively, inquiries may be addressed to:
Customer CARES Department
3800 W Chapman Avenue
Orange, CA 92868