Privacy Notice for California ResidentsEffective Date: November 11, 2021
1.Information We Collect. Our Services 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”). Below, we have provided a list of categories of Personal Information and examples of the types of Personal Information that may fall within those categories. For clarity, even where we indicate that we collect a category of Personal Information, we may not collect all types of Personal Information described in that category.
Within the past twelve (12) months, our Services have collected the following categories of Personal Information from consumers:
- Directly from you. For example, from information you provide through the Site and Services and through any payments or transactions, or through any correspondences, such as when you request to receive information or support.
- Indirectly from you. For example, from observing your actions on our Site through the use of automated data collection tools.
|A. 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|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 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.||YES|
|C. 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).||NO|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||NO|
|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, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|G. Geolocation data.||Physical location or movements.||YES|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment-related information.||Current or past job history, performance evaluations, or professional memberships.||YES|
|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|
|K. Inferences drawn from other Personal Information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||NO|
- To fulfill or meet the reason you provided the Personal Information. For example, if you share your name and contact information to ask a question about our Site, we will use that Personal Information to respond to your inquiry.
- To establish and secure accounts to use the Services, check on your account status, and to validate your username, e-mail, password, and/or other login credentials.
- To provide, support, personalize, and develop our Services, including without limitation, to conduct aggregate or research analysis and develop business intelligence that helps us to enhance, improve, evaluate, operate, protect, make informed decisions about, and report on the performance of our Services.
- To communicate information and promotional materials to you, where you have not expressed a preference otherwise, and to send you information and updates about the Services.
- To notify you of any changes to relevant agreements, policies, or other terms, and to enforce such terms.
- To work with our service providers, who perform certain business functions or services on our behalf.
- To prevent or investigate fraud, or for risk management purposes, and to help maintain the safety, security, and integrity of our Site, databases and other technology assets, and business.
- To comply with legal obligations, court orders, or in order to exercise any legal claim or to defend against any legal claim.
- 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 about our consumers is among the assets transferred.
- As otherwise described to you when collecting your Personal Information or as set forth in the CCPA.
3.Sharing Personal Information. We do not sell or rent your personal information. We may, however, disclose your Personal Information to a third party for a business purpose. In the preceding twelve (12) months, OpenWallet has disclosed the following categories of Personal Information for a business purpose:
- Category A: Identifiers.
- Category B: California Customer Records Personal Information categories.
- Category F: Internet or other similar network activity.
- Category G: Geolocation data.
- Category I: Professional or employment-related information.
- Category K: Inferences drawn from other Personal Information
We share your Personal Information with the following categories of third parties:
- Service providers and other third parties that help us administer and provide the Site and Services (for example, a web hosting company whose services we use to host our platform). These third parties have access to your Personal Information only for the purpose of performing services on our behalf. While we may seek to require such third parties to follow appropriate privacy policies and to prohibit them from using your Personal Information except for the express purpose for which it is provided, you agree that we do not bear any responsibility for any actions or policies of third parties.
- The categories of Personal Information we collected about you.
- The categories of sources for the Personal Information we collected about you.
- Our business or commercial purpose for collecting that Personal Information.
- The categories of third parties with whom we share that Personal Information.
- The specific pieces of Personal Information we collected about you (also called a data portability request).
- If we disclosed your Personal Information for a business purpose, a separate list identifying the Personal Information categories that each category of recipient obtained.
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- e. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
- Calling us at [XXX-XXX-XXXX];
- Visiting our request page at [placeholderurl]; or
- Emailing us at firstname.lastname@example.org.
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
8.Response Timing and Format. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, up to an additional forty-five (45) days, we will inform you of the reason and extension period in writing.
We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the twelve (12) month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically, .CSV format.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
|Mailing address||Fresh Start Funding LLC DBA OpenWallet Attn: Website Inquiry 1805 N Scottsdale RoadSuite 100 Tempe, AZ 85281|