California Privacy Policy
Last Updated: February 12, 2021
Scope of Disclosures
This California Privacy Policy (the “CA Policy”) supplements the information contained in our Privacy Policy and applies solely to individual residents of the State of California (“consumers” or “you”). This CA Policy describes how we collect, use, disclose, and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 (CCPA). Unless otherwise expressly stated, all terms in this CA Policy have the same meaning as defined in our Privacy Policy or as otherwise defined in the CCPA.
Personal Information Disclosures
When we use the term “personal information” in this CA Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. This CA Policy does not apply to personal information we collect when we are acting as a service provider to process information on behalf of our clients to whom we provide legal services.
For the purposes of this CA Policy, personal information does not include:
- Publicly available information from government records.
- Deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to a consumer.
- Information excluded from the CCPA’s scope, such as:
- 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;
- Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
- Information relating to our job applicants, employees, contractors and other Maxwell Financial Labs, Inc. personnel.
Collection and Use of Personal Information
We collect personal information from and about consumers for a variety of purposes. To learn more about the types of personal information we collect, the sources from which we collect or receive personal information, and the purposes for which we use this information, please refer to the Information We Collect section in our Privacy Policy.
In the last 12 months, we have collected the following categories of personal information, from the following sources (in some cases the information we collect may fall within more than one category):
| Category | Collected | Categories of Sources |
| Identifiers, such as 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 | -Directly from you -Our business partners and affiliates -Third parties you direct to share information with us |
| Characteristics of protected classifications under California or federal law, such as race, religion, sexual orientation, gender identity, gender expression, or age | Yes | -Directly from you -Our business partners and affiliates -Third parties you direct to share information with us |
| Commercial Information, such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies | Yes | Directly from you |
| Biometric information: Hair color, eye color, fingerprints, height, retina scans, facial recognition, voice, and other biometric data | No | Not applicable |
| Protected Classification Characteristics, such as age, gender, religion, and disability information | Yes | Directly from you |
| Internet/Network Information, such browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement | Yes | Your browser or device |
| Geolocation Data, such as information about your physical location collected from geolocation features on your device, including your IP address | Yes | Your browser or device |
| Audio, electronic, visual, thermal, olfactory, or similar information, such as telephone recordings when you call into our customer service | Yes | Directly from you |
| Professional/Employment Information, such as your employing entity, business unit, manager and management reporting structure, job title, function and the nature of your duties and responsibilities | Yes | -Directly from you -Third parties you direct to share information with us |
| Inferences,including information generated from your use of the websites reflecting predictions about your interests and preferences | Yes | -Your browser or Device -Information generated from your online browsing and usage activity |
| Other Personal Information, such as information you permit us to see when interacting with us through social media, or comments and opinions you provide to us such as when you complete an online survey | Yes | -Directly from you -Our business partners and affiliates -Third parties you direct to share information with us -Information generated from your online browsing and usage activity |
Purposes for Collecting Personal Information
We may collect, use or disclose personal information about you for one or more of the following purposes:
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our services, we will use that personal information to respond to your inquiry.
- To assist you in sharing content from our services, such as by sending information required by your lender.
- To deal with inquiries and complaints made by or about you relating to our services.
- To communicate with you, including through email to provide you updates, alerts, news and mailings relating to products or services we think may be of interest to you.
- To operate, maintain, and provide to you the features and functionality of our services.
- To market to you, including through email.
- To send you statements and invoices in relation to any agreement between us to provide you with any part of the services.
- To better understand the demographics of our users.
- To personalize your experience and to deliver custom content and product and service offerings relevant to your interests, including targeted offers and ads through our website, third-party sites, or on other devices you may use.
- To recognize you and remember your information when you return to our websites and services.
- To help maintain the safety, security, and integrity of our services, technology assets, and business.
- For testing, research, analysis, and product development, including to develop and improve our services.
- To assist you in sharing content from our services, or your experiences on our services, with your friends, followers or contacts on a social network.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
With Whom We Share Your Personal Information.
Please refer to the Who We Share Personal Information With section in our Privacy Policy for more information on how we have shared personal information about you in the past 12 months.
Your California Privacy Rights
As a California resident, you may be able to exercise the following rights in relation to the Personal Information about you that we have collected (subject to certain limitations at law):
| The Right to Know | You have the right to request any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity: -The specific pieces of personal information we have collected about you; -The categories of personal information we have collected about you; -The categories of sources of the personal information; -The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed; -The categories of personal information we have sold about you (if any), and the categories of third parties to whom the information was sold; and -The business or commercial purposes for collecting or, if applicable, selling the personal information. |
| The Right to Request Deletion | You have the right to request the deletion of personal information we have collected from you, subject to certain exceptions. |
| The Right to Opt Out of Personal Information Sales | We do not sell your personal information for monetary consideration. However, California law may characterize our sharing of personal information with companies that provide services to us, such as companies that help us to market or advertise our products and services to you, as “sales”. We may “sell” or may have “sold” the following categories of personal information for valuable consideration to the third parties listed below: Categories we may sell or may have sold this information to Advertising companies: -Device identifiers -Online or network activity information -Commercial information -Inferences |
| The Right to Non-Discrimination | You have the right not to receive discriminatory treatment for exercising these rights. However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner. |
| “Shine the Light” | California residents that have an established business relationship with us have rights to know how their information is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law (Civ. Code §1798.83). |
How to Exercise Your California Consumer Rights
To Exercise Your Right to Know or Right to Deletion
To exercise your Right to Know and/or your Right to Deletion, please submit a request by:
- Emailing it to [email protected] with the subject line “California Rights Request,” or
- Calling 888-256-6067.
Verifiable Consumer Requests. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for access to your personal information twice within a 12-month period. The verifiable consumer request must: 1) Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative of that person; and 2) Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it. We cannot respond to your request to exercise your access and/or deletion rights if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password-protected account sufficiently verified when the request relates to personal information associated with that specific account. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format. We attempt to respond to a verifiable consumer request within 45 days after we receive it. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing within 45 days after we receive your initial request. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period prior to the date we receive the verifiable consumer request. The response we provide will also provide the reasons we cannot comply with a request, if applicable. For access 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. 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.
To Exercise Your Right to Opt-Out of Personal Information Sales
You have the right to direct us to not sell your personal information. If you would like to exercise your right to request opt-out of sale, please email [email protected] with the subject: “CCPA – Do Not Sell”. Please note that we may still use aggregated and de-identified personal information that does not identify you or any individual; we may also retain information as needed in order to comply with legal obligations, enforce agreements, and resolve disputes.
Minors Under Age 16
We do not and will not “sell” the personal information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization (the “Right to Opt In”) from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age.
California’s “Shine the Light” Law
In addition to the rights described above, California’s “Shine the Light” law (Civil Code Section §1798.83) permits California residents that have an established business relationship with us to request certain information regarding our disclosure of certain types of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year. To make such a request, please send an email to [email protected]. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the email address specified in this section.
Complaints. In compliance with the CCPA, we commit to resolve complaints about your privacy and our collection or use of your personal information. California residents with inquiries or complaints regarding this CA Policy should first contact us at 888-256-6067 or by emailing us at [email protected].
Updates to This CA Policy
We will update this CA Policy from time to time. When we make changes to this CA Policy, we will change the “Last Updated” date at the beginning of this CA Policy. All changes shall be effective from the date of publication unless otherwise provided in the notification.
Contact Us
If you have any questions or requests in connection with this CA Policy or other privacy-related matters, please send an email to [email protected].