This Privacy Policy for California Residents (the “Policy”) describes how Anchor Loans, LP and our affiliated companies (“Anchor Loans”, “we”, “our”, “us,” or the “Company”) uses Personal Information that we collect, receive, maintain, use, treat, and store about visitors, users and others who reside in the State of California (“you”, “your” or “consumers”) in connection with the use of our services and the websites, applications, and electronic communications where it appears, as well as all software, services, extensions, subdomains, and application programming interfaces related thereto (the “Platform”). This Policy has been adopted, in part, to comply with the California Consumer Privacy Act of 2018 (“CCPA”), as amended and by interacting with us through the Platform or by other means that identify this Policy, you consent to the terms and conditions of the Policy as described herein.
We are committed to respecting privacy and recognize the need for appropriate protection and management of any Personal Information that is shared with us as part of using our Platform. When used in this Policy, the term “Personal Information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information does not include publicly available information from government records or de-identified or aggregated consumer information.
We may collect Personal Information from you directly through a web-form, or indirectly through document(s) you upload to our Platform containing Personal Information, as discussed more fully in Section 3, below. When we combine Personal Information with other information (i.e. Information that does not, on its own, identify you), we treat the combined information as Personal Information.
You may choose whether or not to provide or disclose Personal Information in connection with your use of our Platform. If you choose not to provide the Personal Information we request, you may still visit and use parts of our Platform, but may be unable to access or use certain features, options, programs, products, and services.
Our Platform may include third party content and links to third party websites and services that collect Personal Information. We do not control these third parties and this Policy does not apply to their privacy practices. We are not responsible for the practices of these third parties or how they use information you provide to them. Please read the third parties’ privacy policies carefully.
We and our service providers collect a range of Personal Information.
We may collect contact information when you submit a loan application, when you register for services through the Platform, submit a job application, apply for employee benefits, or contact us through email or our website chat feature. For instance, we may collect information including your name, email address, phone number, and address.
We may collect financial information if you apply for a loan, apply for membership in an investment fund, or become an employee, contractor, or vendor of Anchor. Payment information includes your bank account information, credit reports, income, and information reported on state and federal income tax returns.
We may also collect other background Personal Information such as your date of birth, Social Security number, driver’s license number, resume information, and a list of your assets and their value.
We may also collect usage and device information when you visit our Platform. This may include information about the browser, operating system, and/or device identifier for the device you are using, your ISP and IP information, as well as the websites that you came from and the site you visit when you leave.
We collect information in a variety of ways. We collect information directly from you; for instance when you register an account, submit a loan application, submit a job application, apply for employee benefits, or communicate with us through our website chat function or via our SMS and phone line. Similarly, we collect information directly from you when you submit a job application or when you upload documents into our Platform.
We also collect information from you passively. Our Platform uses tracking tools like cookies, pixels, and web beacons. We do this both on our Platform and in emails that we send to you. Through these tools we collect information about users over time when you use our Platform. This collection includes usage and browser information. We may also have third parties collect Personal Information this way. For more information about the trackers that we use, please see Section 5 of this Policy.
We may also collect your Personal Information from third parties. For instance, we may obtain your credit report from credit reporting agencies. These providers may collect Personal Information about you in performing their services and/or functions on our Platform. For more information on who we employ as a service provider or vendor, their business purpose, and their privacy practices, please click hereto submit a request. Additionally, we have worked with certain third-party social media providers to offer you their social networking services through our Platform. For example, you can use third-party social networking services to share information about your experience on our Platform with your friends and followers on those social networking services. If you choose to access or make use of third-party social networking services, we may receive information about you that you have made available to those social networking services, including information about your contacts on those social networking services. You also may be able to link an account from a social networking service (e.g. Facebook) to an account through our Platform. This may allow you to use your credentials from the other site or service to sign in to certain features on our Platforms. If you link your account from a third-party site or service, we may collect information from those third-party accounts, and any information that we collect will be governed by this Policy.
We may combine Personal Information we obtain. For example we may combine information that we have collected online with information that we have collected offline, for instance during calls between you and our support team. We may also combine information that we have collected across other third party sites or from other third parties with information we already have. Finally, we combine information across devices.
We collect information about users over time on the Platform by using several common types of cookies and other tracking technologies including web beacons, pixels, and flash cookies. We also have third parties that collect information in this way on our behalf and for their own purposes. Cookies are small files that download when you access certain websites. For more information about cookies visit: http://www.allaboutcookies.org/. Web beacons, pixels, and other tracking technologies operate independent of cookies.
To assist us with analyzing our website traffic through cookies and similar technologies, we use analytics services such as Google Analytics. For more information on Google Analytics’ processing of your information, please see “How Google uses data when you use our partners' Platforms or apps.” You can opt out of Google Analytics by installing Google’s opt-out browser add-on.
These cookies may be ones placed by us (first-party) or by a third party. These cookies may also be Flash Cookies. To learn how to manage privacy and storage settings for Flash cookies click here. We may use cookies that are session-based or persistent. Session cookies expire when you close your browser or turn off your device. Persistent cookies remain on your device after you close your browser or turn off device.
We may use a variety of cookies:
Type of Cookies Description
Required
Required cookies are essential for the Platform to function properly and for you to navigate our Site and use its features, such as accessing secure areas of the Platform and using our services.
Performance
These cookies collect information about how you use the Platform, including which pages you go to most often and if they receive error messages from certain pages. These cookies do not collect information that individually identifies you. All information these cookies collect is aggregated and anonymous. It is only used to improve how the Platform functions and performs.
Functionality
Functionality cookies allow the Platform to remember information you have entered or choices you make (such as your username, language, or your region) and provide enhanced, more personal features. These cookies also enable you to optimize your use of the Platform after logging in. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize.
Targeting or Advertising
From time-to-time, we may engage third parties to track and analyze usage and volume statistical information from individuals who visit the Platform. We sometimes use cookies delivered by third parties to track the performance of our advertisements. For example, these cookies remember which browsers have visited the Platform. The information provided to third parties does not include Personal Data, but this information may be re-associated with Personal Data after we receive it.
By way of example, as you visit the Platform, advertising cookies may be placed on your computer so that we can understand what you are interested in. Our advertising partners then enable us to present you with retargeted advertising on other sites based on your previous interaction with the Platform.
We also contract with third-party advertising networks and similar partners that collect IP addresses and other information on our Platform, from emails, and on third-party sites. Ad networks follow your online activities over time by collecting Site Navigational Information through automated means, including through the use of cookies. They use this information to provide advertisements about products and services tailored to your interests. You may see these advertisements on other websites. This process also helps us manage and track the effectiveness of our marketing efforts.
Third parties, with whom we partner to provide certain features on the Platform or to display advertising based upon your web browsing activity, use Flash cookies to collect and store information. Flash cookies are different from browser cookies because of the amount of, type of, and how data is stored.
You can control cookies and tracking tools. Some browsers have a “do not track” feature that prevents a website from tracking you, as well as additional cookie settings. Our Platform does not currently respond to these signals. If you choose to block cookies and other trackers, certain features of the Platform may not work. Blocking or rejecting cookies will not stop all of the tracking described in this Policy. These features and options are browser and device specific and are not uniform. You can usually find these settings in the options or preferences menu of your browser. To understand these settings, the following links for commonly used browsers may be helpful, or you can use the help option in your browser for more details:
· Cookie settings in Internet Explorer
· Cookie settings in Firefox
· Cookie settings in Chrome
· Cookie settings in Safari web and iOS.
To find out more on how to manage and delete cookies, visit aboutcookies.org. Formore details on your choices regarding use of your web browsing activity forinterest-based advertising you may visit the following sites:
· networkadvertising.org
· optout.aboutads.info
· youradchoices.com
· youronlinechoices.eu
Ona mobile device, you may also be to adjust your settings to limit ad tracking.
You have certain choices about how we use your Personal Information. You can opt-out of certain marketing, and you can also limit the use of your Sensitive Personal Information to those uses specified in California Civil Code Sec. 1798.121 However, we may be allowed to use your Sensitive Personal Information for reasons not listed, but allowed by law. To opt-out of marketing communication emails email us at privacypolicy@anchorloans.com or by clicking “unsubscribe” at the bottom of our promotional communications. To limit the use of your Sensitive and Personal Information, submit your request to us via email at privacypolicy@anchorloans.com. You will continue receiving transactional and relationship related communications, as permitted by law.
We use your Personal Information in a number of ways. If you are a loan applicant, borrower, or investor, we may use your Sensitive and Personal Information in order to process your loan application and to perform services you have requested. If you are a job applicant or employee, we may use your Sensitive and Personal Information to evaluate your job application, or process your employee-benefits request.
We also use your Sensitive and Personal Information to respond to your requests or questions, including questions about our Platform, our products and services, and your relationship with us. This includes communicating with you to review any loan or investment applications and to process and service them, as well as respond to your feedback.
We may also use your information to improve our Platform and services, including customizing your experience with us. We may also use your information for marketing purposes. For example, we may send you information about new features on the Platform, new services we offer, and special offers. When legally permitted, this may also include using your information to serve you ads and to tell you about products or offers available through third parties we think you might find interesting.
Additionally, we may use your information for security purposes to protect our company, Platform, and customers. Finally we may use your information for other purposes, as required and permitted by law, including to fulfill legal and regulatory requirements.
We may share your Personal Information in the following ways and to the following third parties:
· Our Service Providers. We may share your Personal Information with third parties who perform services on our behalf. For example, we may share information with vendors that operate our Platform or send out our email communications. We also use third parties for technical and customer support, application development, tracking and reporting functions, quality assurance, administering employee benefits, and other services.
· Business Partners. We may also share Personal Information with our trusted third party partners. For example, we may share information with partners when we co-sponsor a promotion. These partners may use your information to, among other things, send you information or contact you about services and products. We may also share your information with our business partners in order to obtain better loan rates and terms for your loan.
· Advertisers. From time-to-time, we engage advertising services to assist us in advertising our brand and Platform. Those services may target advertisements on third-party websites based on cookies or other information indicating previous interaction with our Platform.
· Companies Involved in Mergers and Acquisitions Transactions. If we sell or otherwise transfer part or the whole of our business or assets to another organization (e.g., in the course of a transaction like a merger, acquisition,bankruptcy, dissolution, or liquidation), any information collected through thePlatform, including Personal Information, may be among the items sold ortransferred.
· Fraud and Other Investigations. We may share your information in the course of an investigation or prevent a violation by you related to fraud, illegal or harmful activity, or contractual violation.
· Law Enforcement, Government Agencies, and Courts. We may disclose Personal Information at the request of law enforcement or government agencies or in response to subpoenas, court orders, or other legal process to establish, protect, or exercise our rights or to defend against a legal claim or as otherwise required or allowed by law, or to protect the rights, property, or safety of any other person.
We may also share information as described to you in other disclosures relating to additional services we provide.
We reserve the right to retain any Personal Information as long as the Personal Information is reasonably necessary to: (i) fulfill the purposes that are described in Section 7, and(ii) comply with applicable law.
The privacy and security of Personal Information is very important to us. Taking into account the nature, scope, context and purposes of processing Personal Information as well as the risks of varying likelihood and severity for the rights and freedoms of natural persons, Anchor Loans has implemented appropriate technical and organizational measures to ensure and to be able to demonstrate that its processing of Personal Information is performed in accordance with applicable law. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect Personal Information, we cannot guarantee its absolute security.
The Platform is not intended for children. Our Platform is meant for adults and we do not knowingly collect personally identifiable information from children under 13 without permission from a parent or guardian, or from children between the ages of 13-16 without their consent. If you are a parent or legal guardian and think your child has given us information, or for children between the ages of 13-16 to opt-in , you can email us at privacypolicy@anchorloans.com. You can also write to us at the address listed in the “Contact Us” section of this Policy. Please mark your inquiries “CCPA Inquiry.”
Pursuant to the CCPA (effective 2020), California residents have certain rights concerning their Personal Information, including Sensitive Personal Information. This section further describes (1)the categories of Personal Information, collected and disclosed by Anchor Loans, subject to the CCPA, (2) your privacy rights under the CCPA, and (3) how to exercise your rights.
We collect, process, and maintain Sensitive and Personal Information to fulfill certain business purposes related to our Platform. We will not collect additional categories of Sensitive and Personal Information or use Sensitive and Personal Information collected for additional purposes without providing you notice. Within the preceding twelve (12) months we and our service providers have and may collect, and you may consent to provide, the categories of Sensitive and Personal Information set forth below. We disclose each of these categories of Sensitive and Personal Information with our service providers for our business purposes (to enable the service providers to provide their services) and as otherwise described in the “How We Disclose Personal Information” section above.
· Identifiers (for example, name, postal address, date of birth, email address, IP address, and online identifiers);
· Categories of Personal Information as defined by Cal. Civ. Code § 1798.140 (for example, name, signature, Taxpayer Identification Number, telephone number, passport number, driver’s license number, insurance policy number, account numbers);
· Categories of Sensitive Personal Information as defined by Cal. Civ. Code § 1798.140 (for example social security number, driver’s license number, account log-in, precise geolocation, racial or ethnic origin, genetic data, health information, or sexual orientation.)
· Protected classifications under California orfederal law (for example, age, citizenship status, national origin orancestry);
· Commercial information (for example, transactionhistory);
· Internet or other electronic network activityinformation, including information on your usage of our Sites;
· Geolocation data;
· Sensory data (for example, audio from callrecordings);
· Professional and employment related information;
· Education information
· Inferences drawn from any information identified above to create a profile.
In accordance with the CCPA, California consumers may exercise under certain conditions the following four (4) categories of privacy rights with respect to their Sensitive and Personal Information. Please note: you will not be discriminated against in any way by virtue of your exercise of the rights listed below, which means we will not deny goods or services to you, provide a different prices or rates for goods or services to you, or provide a different level or quality of goods or services to you.
Privacy Right
Description
Notice
You have the right to be notified of what categories of Personal Information will be collected at or before the point of collection and the purposes for which they will be used and shared.
Access
You have the right to request the categories of Personal Information that we collected in the previous twelve (12) months, the categories of sources from which the Personal Information was collected, the specific pieces of Personal Information we have collected about you, and the business purposes for which such Personal Information is collected and shared. You also have the right to request the categories of Personal Information which were disclosed for business purposes, and the categories of third parties in the twelve (12) months preceding your request for your Personal Information.
Data Portability
You have the right to receive the Personal Information you have previously provided to us.
Erasure
You can request to have your Personal Information deleted from our servers and we will direct our service providers to do the same. However, please be aware that we may not fulfill your request for deletion if we (or our service provider(s)) are required to retain your Personal Information for one or more of the following categories of purposes: (1) to complete a transaction for which the Personal Information was collected, provide a good or service requested by you, or complete a contract between us and you; (2) to ensure our website integrity, security, and functionality; (3) to comply with applicable law or a legal obligation, or exercise rights under the law (including free speech rights); (4) to otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Correct
You have the right to request correction of your Personal Information
Limit Use of Sensitive Personal Information
You have the right to limit the use of Sensitive Personal Information.
To Opt Out
You have the right to opt-out of our sharing of your Personal Information with our Business Partners for cross-contextual behavioral advertising. We do not sell Personal Information to third parties.
Additionally, CaliforniaCivil Code Section 1798.83 permits you to, one time annually, requestinformation regarding the disclosure of Personal Information about you byAnchor Loans to third parties for the third parties’ direct marketing purposes.To make such a request, please send an email to privacypolicy@anchorloans.com. You can also write to us at the addresslisted in the “Contact Us” section of this Policy. In your request please indicate that you area California resident and that you are making a “Shine the Light” request.
If you would like to exercise your rights listed above, please send (or have your authorized agent send) an email to privacypolicy@anchorloans.com or call us toll-free at 310-395-0010. You have a right not to receive discriminatory treatment by any business when you exercise your CCPA rights.
While we take measures to ensure that those responsible for receiving and responding to your request are informed of your rights and how to help you exercise those rights, when contacting us to exercise your rights, we ask you to please adhere to the following guidelines:
· Tell Us Which Right You Are Exercising: Specify which right you want to exercise and the Personal Information to which your request relates (if not to you). If you are acting on behalf of another consumer, please clearly indicate this fact and your authority to act on such consumer’s behalf;
· Help Us Verify Your Identity: Provide us enough information to verify your identity. For example, provide us(at a minimum) the name or names used for contact with Anchor, an associated property address, or a loan number if Anchor made a loan to you. Please note that if we cannot initially verify your identity, we may request additional information to complete the verification process. Any Personal Information you disclose to us for purposes of verifying your identity will solely be used for the purpose of verification.
· Direct Our Response Delivery: Inform us of the delivery mechanism with which you prefer to receive our response. You may specify, for example, email, mail, or through your account(if you have one with us).
Please note that you don’t need to create an account with us in order to make a request to exercise your rights hereunder.
In all cases, we will respond to your request within 45 days, except that opt-out requests will be handled within 15 business days of receipt. However, where reasonably necessary, we may extend our response time by an additional 45 days, provided we send you notice of such extension first. We will provide the information to you via your preferred delivery mechanism. If the information is provided to you electronically, we will provide you the information in a portable format and, to the extent technically feasible, in a machine readable, readily useable format that allows you to freely transmit this information without hindrance.
Please note that we will not charge you for making a request, provided that you make no more than two (2) requests per year. If you make three (3) or more requests in any given twelve (12) month period, we may refuse to respond to such requests, if determined by us to be unfounded or excessive (e.g. repetitive in nature), or we may charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested. If we refuse to act on the request, we will provide you notice and the reason for our refusal to act.
As our organization changes over time, this Policy is expected to change as well. We reserve the right to amend the Policy at any time, for any reason, without notice to you, other than the posting of the amended Policy on our Platform. We may e-mail periodic reminders of our notices and terms and conditions, but you should check our Platform frequently to see the current Policy that is in effect and any changes that may have been made to it.
Any comments, concerns, complaints, or questions regarding our Privacy Policy may be addressed to privacypolicy@anchorloans.com.
