Effective Date: January 1, 2021
Any business that collects a California consumer’s personal information must inform consumers of the categories of personal information collected and the purpose for which the categories of personal information shall be used.
The CCPA gives California residents the right to know about information collected, disclosed, or sold, the right to opt out of the sale of certain information, and a limited right to have businesses delete information collected about the consumer. These rights only extend to California residents and information specifically covered under the CCPA. The CCPA does not cover all consumer data in all situations and only certain consumer data is subject to these rights.
Information We Collect
Our website may collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). More specifically, our website may have collected the following categories of personal information form California consumers since January 1, 2020, the effective date of the CCPA:
|Category of Personal Information||Examples (not all will be collected)||Collected|
|Identifiers||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.||YES|
|Personal information categories listed in the California Customer Records statute (Cal. Civ. Code Section 1798.80(e))||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.||YES|
|Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||YES|
|D. Commercial Information||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||YES|
|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, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO|
|Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|Geolocation Data||Physical location or movements.||YES|
|Sensory Data||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|Professional or employment-related information||Current or past job history or performance evaluations.||YES|
|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.||YES|
|Inferences drawn from other personal information||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||NO|
We obtain the categories of information provided above from the following sources:
- through our website;
- when a consumer acquires a product or a service from us;
- when signing up for communications from us;
- when entering promotions or sweepstakes offered by us;
- through telephone or web-based surveys, online chat, customer service correspondence or general feedback;
- when applying for a position with us;
- third parties such as lead buy partners, data brokers and credit bureaus; and
- using web technologies.
The following does not constitute personal information:
- Information outside of the scope of the CCPA, for example:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data.
- Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
- De-identified or aggregated consumer information.
- Information from government records that is publicly available.
Your Data and Our Third Parties
Below are the parties with whom we could share your data and what information might be shared.
|Service Providers||Affiliates||Mortgage partners||Partner companies||Regulators|
|Personal information categories||YES||YES||YES||YES||NO|
|Protected classification characteristics||YES||YES||YES||YES||NO|
|Internet or other similar network activity||YES||YES||NO||NO||NO|
|Professional or employment-related information||YES||NO||YES||YES||NO|
|Non-public education information||YES||NO||NO||NO||NO|
|Inferences drawn from other personal information||YES||YES||YES||YES||NO|
Our potential uses for your data:
- Fraud detection;
- Internal Research;
- Marketing (unless you previously opted out);
- Prepopulate info when applicable for ease of use;
- Providing Services; and
- Quality Control;
Purposes for which we might share your data with third-parties:
- Business Purposes;
- Detecting Fraud;
- Internal Research;
- Providing Services; or
- Quality Control.
If you provide your prior consent, we will share your personal data with third parties for the following reasons:
- Marketing; and
- Pre-populating your information for ease of use.
If you have previously agreed to allow us to share your data and now wish to opt-out, please contact us.
Sales of Personal Information
We have not sold personal information since January 1, 2020, the effective date of the CCPA.
Your California Privacy Rights
We do not share personal information (as defined by California Civil Code Section 1798.83) with other people or non-affiliated businesses for their direct marketing purposes. Our website does not respond to browser do-not-track signals.
Under the California Consumer Privacy Act of 2018 (“CCPA”), California consumers have the right to request:
- The deletion of the personal information we have about them;
- Additional information about whether and how we have collected, used, disclosed, and sold personal information about them; and
- The specific pieces of information we have about them.
California consumers also have the right not to receive discriminatory treatment if they exercise the rights listed above.
How to Submit a Verifiable Consumer Request to Know, Delete, or Opt-Out
For a request to be acknowledged, you may call our toll-free number at (855) 455-7026 or send an email to firstname.lastname@example.org. After submitting a request, we will verify your identity by matching the identifying information provided to you to the personal information already maintained by us, or in cases where your request requires a higher degree of certainty, we may use a third-party identity verification service to ask for a photo ID or for more information. Any information you provide us that is not already in our system will be deleted after your request has been fulfilled.
You may use an authorized agent to submit a request to know or a request to delete. If you use an authorized agent to submit a request to know or a request to delete, you must provide us with written permission from you giving the authorized agent permission to submit the request on your behalf, and you may be required to verify the authorized agent’s identity with us. We may deny a request from an agent that does not submit proof that they have been authorized by the consumer to act on their behalf.
Changes to Our Privacy Notice
We reserve the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this Privacy Notice, we will post the updated Privacy Notice on the website and update the Privacy Notice’s effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.
If you have any questions or comments regarding this Privacy Notice, the way we collect and use your information describe above, your choices and rights regarding such use, or you wish to exercise your rights under California law, please contact us, as follows:
Phone: (855) 455-7026
Send a letter to us at:
Attn: Compliance Officer
4000 MacArthur Blvd., Suite 300
Newport Beach, CA 92660