CCPA/CPRA Notice at Collection Disclosure

CCPA/CPRA Notice at Collection

Last Updated: December 21, 2022

Data Categories Collected by Us

We currently collect the following categories of personal information listed in the chart below:

Category of Personal Information Description Collected
(Yes/No)
Identifiers Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, Social Security number, or other similar identifiers.
Sold or Shared? We do not sell or share this category of personal information.
Retention Period. We will retain and use this category of Personal Information for an appropriate period of time as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to provide our Services, and other purposes to the extent provided in this California Privacy Policy. We take reasonable steps to delete this category of Personal Information when (1) we have a legal obligation to do so; (2) we no longer have a purpose or obligation for retaining the information; or (3) if you ask us to delete the information unless there is an applicable exception to deleting the information under California Privacy Laws.
We will retain and use this category of Personal Information for an appropriate period of time as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to provide our Services, and other purposes to the extent provided in this California Privacy Policy. We take reasonable steps to delete this category of Personal Information when (1) we have a legal obligation to do so; (2) we no longer have a purpose or obligation for retaining the information; or (3) if you ask us to delete the information unless there is an applicable exception to deleting the information under California Privacy Laws.
Yes
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) Examples: A name, signature, Social Security number, address, telephone number, employment, employment history, bank account number, debit card number, or any other financial information. Some personal information included in this category may overlap with other categories.
Sold or Shared? We do not sell or share this category of personal information.
Retention Period. We will retain and use this category of Personal Information for an appropriate period of time as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to provide our Services, and other purposes to the extent provided in this California Privacy Policy. We take reasonable steps to delete this category of Personal Information when (1) we have a legal obligation to do so; (2) we no longer have a purpose or obligation for retaining the information; or (3) if you ask us to delete the information unless there is an applicable exception to deleting the information under California Privacy Laws.
We are required to maintain records of Consumer requests submitted under California Privacy Laws, which may include this category of Personal Information, and how we responded to such requests for at least twenty-four (24) months. Such information related to Consumer requests is retained only for recordkeeping purposes.
Yes
Protected classification characteristics under California or federal law Examples: Age (40 years or older), gender, race, ethnicity or national origin, or veteran or military status.
Sold or Shared? We do not sell or share this category of personal information.
Retention Period. We will retain and use this category of Personal Information for an appropriate period of time as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to provide our Services, and other purposes to the extent provided in this California Privacy Policy. We take reasonable steps to delete this category of Personal Information when (1) we have a legal obligation to do so; (2) we no longer have a purpose or obligation for retaining the information; or (3) if you ask us to delete the information unless there is an applicable exception to deleting the information under California Privacy Laws.
We are required to maintain records of Consumer requests submitted under California Privacy Laws, which may include this category of Personal Information, and how we responded to such requests for at least twenty-four (24) months. Such information related to Consumer requests is retained only for recordkeeping purposes.
Yes
Commercial Information Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Sold or Shared? We do not sell or share this category of personal information.
Retention Period. We will retain and use this category of Personal Information for an appropriate period of time as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to provide our Services, and other purposes to the extent provided in this California Privacy Policy. We take reasonable steps to delete this category of Personal Information when (1) we have a legal obligation to do so; (2) we no longer have a purpose or obligation for retaining the information; or (3) if you ask us to delete the information unless there is an applicable exception to deleting the information under California Privacy Laws.
We are required to maintain records of Consumer requests submitted under California Privacy Laws, which may include this category of Personal Information, and how we responded to such requests for at least twenty-four (24) months. Such information related to Consumer requests is retained only for recordkeeping purposes.
Yes
Biometric Information Examples: 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 Examples: Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
Sold or Shared? We do not sell or share this category of personal information.
Retention Period. We will retain and use this category of Personal Information for an appropriate period of time as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to provide our Services, and other purposes to the extent provided in this California Privacy Policy. We take reasonable steps to delete this category of Personal Information when (1) we have a legal obligation to do so; (2) we no longer have a purpose or obligation for retaining the information; or (3) if you ask us to delete the information unless there is an applicable exception to deleting the information under California Privacy Laws.
We are required to maintain records of Consumer requests submitted under California Privacy Laws, which may include this category of Personal Information, and how we responded to such requests for at least twenty-four (24) months. Such information related to Consumer requests is retained only for recordkeeping purposes.
Yes
Geolocation data Examples: Physical location or movements.
Sold or Shared? We do not sell or share this category of personal information.
Retention Period. We will retain and use this category of Personal Information for an appropriate period of time as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to provide our Services, and other purposes to the extent provided in this California Privacy Policy. We take reasonable steps to delete this category of Personal Information when (1) we have a legal obligation to do so; (2) we no longer have a purpose or obligation for retaining the information; or (3) if you ask us to delete the information unless there is an applicable exception to deleting the information under California Privacy Laws.
We are required to maintain records of Consumer requests submitted under California Privacy Laws, which may include this category of Personal Information, and how we responded to such requests for at least twenty-four (24) months. Such information related to Consumer requests is retained only for recordkeeping purposes.
Yes
Sensory Data Examples: Audio, Electronic, visual, thermal, olfactory, or similar information.
Sold or Shared? We do not sell or share this category of personal information.
Retention Period. We will retain and use this category of Personal Information for an appropriate period of time as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to provide our Services, and other purposes to the extent provided in this California Privacy Policy. We take reasonable steps to delete this category of Personal Information when (1) we have a legal obligation to do so; (2) we no longer have a purpose or obligation for retaining the information; or (3) if you ask us to delete the information unless there is an applicable exception to deleting the information under California Privacy Laws.
We are required to maintain records of Consumer requests submitted under California Privacy Laws, which may include this category of Personal Information, and how we responded to such requests for at least twenty-four (24) months. Such information related to Consumer requests is retained only for recordkeeping purposes.
Yes
Professional or employment-related information Examples: Current or past job history.
Sold or Shared? We do not sell or share this category of personal information.
Retention Period. We will retain and use this category of Personal Information for an appropriate period of time as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to provide our Services, and other purposes to the extent provided in this California Privacy Policy. We take reasonable steps to delete this category of Personal Information when (1) we have a legal obligation to do so; (2) we no longer have a purpose or obligation for retaining the information; or (3) if you ask us to delete the information unless there is an applicable exception to deleting the information under California Privacy Laws.
We are required to maintain records of Consumer requests submitted under California Privacy Laws, which may include this category of Personal Information, and how we responded to such requests for at least twenty-four (24) months. Such information related to Consumer requests is retained only for recordkeeping purposes.
Yes
Non-public education information Examples: 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.
Sold or Shared? We do not sell or share this category of personal information.
Retention Period. We will retain and use this category of Personal Information for an appropriate period of time as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to provide our Services, and other purposes to the extent provided in this California Privacy Policy. We take reasonable steps to delete this category of Personal Information when (1) we have a legal obligation to do so; (2) we no longer have a purpose or obligation for retaining the information; or (3) if you ask us to delete the information unless there is an applicable exception to deleting the information under California Privacy Laws.
We are required to maintain records of Consumer requests submitted under California Privacy Laws, which may include this category of Personal Information, and how we responded to such requests for at least twenty-four (24) months. Such information related to Consumer requests is retained only for recordkeeping purposes.
Yes
Inferences Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
No
Sensitive Personal Information Examples: (1) Social Security number, driver’s license number, state identification number, passport number; (2) account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (3) precise geolocation information; (4) racial or ethnic origin, religious, or philosophical believes, or union membership; (5) contents of mail, email, and text messages unless the business is the intended recipient of the communication; (6) genetic data; (7) biometric data for the purposes of uniquely identifying a consumer; (8) health information; (9) sex life or sexual orientation information.
**We only collect Sensitive Personal Information for legitimate business purposes appropriate for the use and disclosure of Sensitive Personal Information as defined in the California Privacy Laws, and not otherwise use it to infer characteristics about you.
Sold or Shared? We do not sell or share this category of personal information.
Retention Period. We will retain and use this category of Personal Information for an appropriate period of time as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to provide our Services, and other purposes to the extent provided in this California Privacy Policy. We take reasonable steps to delete this category of Personal Information when (1) we have a legal obligation to do so; (2) we no longer have a purpose or obligation for retaining the information; or (3) if you ask us to delete the information unless there is an applicable exception to deleting the information under California Privacy Laws.
We are required to maintain records of Consumer requests submitted under California Privacy Laws, which may include this category of Personal Information, and how we responded to such requests for at least twenty-four (24) months. Such information related to Consumer requests is retained only for recordkeeping purposes.
Yes

Business or Commercial Purposes: We use the categories of personal information listed above provide our products and services to you, to operate, manage, and maintain our business, and to accomplish the following business and commercial purposes, including the following:

  • To fulfill or meet the reason for which the information is provided;
  • To provide you with information, products or services that you request from us directly or indirectly;
  • To provide you with information, products or services that you request from us directly or indirectly;
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections;
  • To provide customer service, maintain and servicing accounts, verifying customer information, processing payments, providing financing, providing analytic services, or providing similar services on behalf of the business;
  • To improve our website and present its contents to you;
  • To establish and maintain your user account with us;
  • To authenticate you;
  • For short-term, transient use including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with the business, provided that the consumer’s personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business
  • To detect fraud and prevent loss, or as necessary or appropriate to protect the rights, property, or safety of us, our users and customers, or others;
  • To audit related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
  • To debug to identify and repair errors that impair existing intended functionality;
  • To allow you to contact us and facilitate your communication with us;
  • To respond to your feedback, requests, questions, or inquiries;
  • To provide offers to eligible users or customers;
  • To provide advertising and marketing services, except for cross-context behavioral advertising, to the consumer provided that, for the purpose of advertising and marketing, a service provider or contractor shall not combine the personal information of opted-out consumers that the service provider or contractor receives from, or on behalf of, the business with personal information that the service provider or contractor receives from, or on behalf of, another person or persons or collects from its own interaction with consumers.
  • As described to you when collecting your personal information or as otherwise set forth in the California Privacy Laws; and
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

Other Processing Activities: As permitted by applicable law, we may use all of the personal information that we collect in order to:

  • Comply with federal, state, or local laws;
  • Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities;
  • Cooperate with law enforcement agencies concerning conduct or activity that we, a service provider, or a third party reasonably and in good faith believe may violated federal, state, or local law;
  • Cooperate with a government agency request for emergency access to a consumer’s personal information if a natural person is at risk or danger of death or serious physical injury;
  • Exercise or defend legal claims; and
  • Collect, use, retain, sell, or disclose consumer information that is deidentified or in the aggregate consumer information.

Additional Data Collection and Uses:
We will not collect categories of personal information other than those discussed above and we will not use your personal information for any other purposes that are incompatible with those disclosed above without providing you notice as may be required under the California Privacy Laws.

Exclusions from Personal information: Personal information does not include:

  • Publicly available information or lawfully obtained, truthful information that is a matter of public concern;
  • Personal information that is deidentified;
  • Personal information that is aggregated;
  • Information excluded from the scope of the CPRA including, but not limited to:
    • Personal information collected, processed, sold, or disclosed subject to the Gramm-Leach-Bliley Act (GLBA). Therefore, for example, if you have submitted an application for a loan with Lendmark or are a customer of Lendmark, any information you provided in that application and in connection with your Lendmark account is subject to the GLBA and the information contained in the following federal privacy notice pertains to you: GLBA Privacy Notice; or
    • Personal information bearing on an activity involving the collection, maintenance, disclosure, sale, communication, or use of such information by an agency, furnisher, or user subject to regulation under the Fair Credit Reporting Act (FCRA).
    • Personal information collected, processed, sold, or disclosed subject to the California Financial Information Privacy Act and implementing regulations or the Driver’s Privacy Protection Act of 1994.

For our general privacy policy see our Terms of Use and Privacy Policy. For our privacy policy for California residents see our CPRA Privacy Policy.