Last updated and effective as of January 1, 2020
These Additional California Privacy Disclosures (the “Disclosures”) supplement the information contained in our Privacy Notice and applies solely to individual residents of the State of California (“consumers” or “you”).These Disclosures describe 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 these Disclosures have the same meaning as defined in our Privacy Notice or as otherwise defined in the CCPA.
What is Personal Information
When we use the term “personal information” in these Disclosures, 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. It does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to you.
Collection, Disclosure and Sale of Personal Information
In the last 12 months, we have not sold personal information about you, but we have collected and disclosed for a business purpose the following categories and examples of specific pieces of personal information, which reference the personal information described in the Our Collection and Use of Personal Information section of our Privacy Notice:
|Category of Personal Information||Collected||Disclosed for Business Purpose||Sold*|
|Identifiers, including your name, email address, and Government Identification||✔||✔||X|
|California Customer Records (Cal. Civ. Code § 1798.80(e)), including your home address, business address, phone number, borrower/broker status, Financial Information, and, for disregarded entities, your bank account number and financial information||✔||✔||X|
|Protected Classification Characteristics||X||X||X|
|Commercial Information, including Transaction Information and Investment Information||✔||✔||X|
|Internet/Network Information, including Log Data and Analytics Data||✔||✔||X|
|Geolocation Data, including your general geographic location or more precise location to the extent permitted by law||✔||✔||X|
|Professional/Employment Information, including your employer, company name or the name you are doing business as, your business’s contact information, your job title or description, length of employment, real estate experience, company affiliations, trust affiliations, professional licenses and license status, relevant education, and Diligence Information||✔||✔||X|
|Non-Public Education Information (20 U.S.C. § 1232g, 34 C.F.R. Part 99)||X||X||X|
|Other Personal Information, including Legal History, personal information you permit us to see when interacting with us through social media and personal information you provide us in relation to User Generated Content or your questions, requests or inquiries.||✔||✔||X|
* Note about “Sales”: We do not “sell” personal information as most people would typically understand that term. However, we do allow certain third-party partners and providers to collect information about consumers directly through our website for purposes of analyzing and optimizing our services, delivering ads, providing content and ads that are more relevant, measuring statistics and the success of ad campaigns, and detecting and reporting fraud. To the extent this practice is interpreted to constitute a “sale” under the CCPA, please see the Submitting Requests section below.
Sources of Personal Information
As described in the Our Collection and Use of Personal Information section of the Privacy Notice, we collect personal information directly from you when you provide it to us, automatically when you visit our website, and from service providers and other third parties.
Purposes for Collecting Personal Information
Recipients of Personal Information
Your 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 or disclosed in the last 12 months, upon verification of your identity:
|The Right to Request Deletion||
|The Right to Opt Out of Personal Information Sales||You have the right to direct us not to sell personal information we have collected about you to third parties. If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales.|
|The Right to Non-Discrimination||You have the right not to receive discriminatory treatment for exercising any of the rights described above. However, please note that if the exercise of the rights described above 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 or services or engage with you in the same manner.|
To Exercise Your Right to Know or Right to Deletion
To submit a request to exercise your right to know and/or right to deletion, please contact:
- Email us at firstname.lastname@example.org, or
- Call us at 1-833-551-0321.
We will need to verify your identity before processing your request. To do so, please include the following information with your request:
- The full name of the individual the personal information is about (the consumer);
- The full name of the individual making the request and their relationship to the consumer;
- The consumer’s address, including the state of residency;
- The consumer’s relationship to 5 Arch, including the 5 Arch entity, products and/or services relevant to the consumer;
- The right to be exercised, the associated request and the scope of personal information involved (e.g., all or a subset of the information); and
- The best phone number or email address for us to contact the requesting individual.
In order to verify your identity, we may also require additional personal information to match against the information we maintain about you in our systems.
In certain circumstances, we may decline a request to exercise the right to know and/or right to deletion, particularly where we are unable to verify your identity. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.
To Exercise Your Right to Opt Out of Personal Information “Sales”
To the extent our third-party advertising and analytics partners’ and providers’ collection of information from our website visitors constitute a “sale” under the CCPA, please visit our Cookie Notice for more information about the choices and opt-out options you may have in relation to those practices.
Although we have not “sold” any other personal information in the last 12 months, we may from time to time engage in data transfers that constitute a “sale” under the CCPA. You may exercise your right to be added to our opt-out list in the event of future sales by clicking the link below to email us at email@example.com:Do Not Sell My Personal Information
Please include with your request the information described in the To Exercise Your Right to Know or Right to Deletion section above. Once you make an opt-out request, you may change your mind and opt back in to personal information sales at any time by contacting us at firstname.lastname@example.org.
Minors Under Age 16
We do 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. Please contact us at email@example.com to inform us if you, or your minor child, are under the age of 16.
Updates to These Disclosures
We will update these Disclosures from time to time. When we make changes to these Disclosures, we will change the “Effective Date” at the beginning of these Disclosures. If we make material changes to these Disclosures, we will notify you by prominent posting on this website or through other appropriate communication channels. All modifications will be effective upon their posting to our website unless we indicate otherwise in the post; it is therefore important that you review these Disclosures regularly.
If you have any questions or requests in connection with these Disclosures or other privacy-related matters, please send an email to firstname.lastname@example.org.
Alternatively, inquiries may be addressed to:
5 Arch 19800 Mac Arthur Blvd., Suite 1150 Irvine, CA 92612 866.973.6278