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CALIFORNIA CONSUMER PRIVACY ACT (CCPA)
If you are a California resident and use our consumer Services, you may have certain rights under the California Consumer Privacy Act (CCPA) which are described below.
WHAT INFORMATION WE COLLECT
In the past 12 months, we collected the following personal information:
- Identifiers, such as your name, age, date of birth, address and other contact details, a copy of your identification (such as your driver’s license or passport), as well as your social security number and/or other government identification or registration data.
- Professional or employment-related information, such as your occupation.
- Internet activity, as set out in our Cookies Notice, but including history of visiting and interacting with our Services, IP address, browser type, browser language and other information collected automatically.
- Geolocation data to the extent we need to verify your location for regulatory or anti-fraud purposes depending on the Services provided and your use of them (for example, some laws may require us to identify your location if the use of any Services involves gambling).
- Commercial information, such as information about your banking relationships, including account numbers, debit and credit card numbers, account balances, and the length of time you have maintained those accounts.
We collect this personal information to underwrite and set up your account and for the purpose of providing our Services to you.
SHARING YOUR PERSONAL INFORMATION WITH THIRD PARTIES
In the past 12 months, we shared with third parties any of the information described above for our business purposes, e.g., with our affiliates or in relation to using a service provider to assist us in providing Services to you. The categories of such service providers are described in the Disclosure of Your Information section.
You can switch ‘on’ or ‘off’ your cookie usage in the online consent dashboard available via the ‘Cookie Settings’ link on all our websites and portals.
Do Not Sell My Personal Information
YOUR CCPA PRIVACY RIGHTS
You have rights that you can exercise in relation to your personal information. In particular:
- Right to access: you may ask for information about the categories of personal information we have collected about you, the categories of sources from which your personal information has been collected, the business or commercial purpose for collecting or selling your personal information, as well as the categories of third parties with whom we may share or to whom we sell your personal information and the categories of personal information that have been provided to such third parties. You may also ask us for a copy of the specific pieces of personal information we have collected about you in a machine-readable format.
- Right to deletion: you have the right to request the deletion of your personal information.
- To the extent we sell your personal information you have the right to ask us to stop selling personal information about you to third parties or you can switch "off" your cookie settings here (which will have the same effect as opting out of sale of your personal information).
- Right to nondiscrimination: you have the right not to be discriminated against because you have exercised any of your consumer’s rights listed above. In other words, we shall not provide a different quality of services to you because you have chosen to exercise one of your rights.
You may authorize a person to act on your behalf in relation to exercising these rights but we may need to take certain steps to verify the request made is legitimate, i.e., that it is indeed coming from you and that it is made on your behalf. For example, we may require your signed permission demonstrating that you have authorized the agent to submit the request on your behalf.
Please note that where we use and disclose personal information for purposes related to security, fraud detection and other similar purposes, some of your rights may be limited. As such, please consider that there might be cases where your request cannot be fulfilled. For example, as permitted by the CCPA, it is possible that we may not comply with a request to delete your personal information if we need that information for the purpose of detecting security incidents, or protecting against malicious, deceptive, fraudulent or illegal activities, where such information is necessary to record our contractual dealings or your transactions or where required or otherwise permitted by law.
If you want to know more about your rights, or you want to exercise them, you can reach us at the details provided in the Contact Us section.
California residents may also call us at +1 855 719 2087 (toll free number, available 9AM-7PM EST) or via the Contact Us details provided above.
This Notice was last revised on 30 December 2022.