Introduction

This California Residents Privacy Notice (‘Notice’) applies to California residents pursuant to the California
Consumer Privacy Act of 2018 (‘CCPA’). This Notice supplements the rights contained in our Privacy
Statement, Customer Privacy Notice, and in our Site Terms and Conditions. To the extent of any inconsistency
between these documents, the standard affording the higher privacy right to the consumer prevails.

The CCPA requires that we tell you about the categories of personal information collected by Credit Corp and its affiliates (“Credit Corp”, “we”, “us” or “our”), the categories of your personal information that we share, the kinds of third parties with whom we share your personal information, and what rights you have under the CCPA with respect to your personal information. We have set out that information in this Notice to comply with the CCPA and any terms defined in the CCPA have the same meaning when used in this Notice.

Credit Corp regularly collects and uses information which identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device (“Personal Information”).

Please note that this Notice does not apply to:

  • Publicly available information, being that which is lawfully made available from federal, state, or local government records; or
  • Information which has been de-identified, or is aggregate consumer information;
  • information which is collected, processed, sold, or disclosed pursuant to the Federal Gramm-Leach-Bliley Act (‘GLBA’) and implementing regulations;
  • information governed by:
    • the Fair Credit Reporting Act (‘FCRA’);
    • the California Financial Information Privacy Act (‘FIPA’);
    • the Health Insurance Portability and Accountability Act 1996 (‘HIPAA’);
    • the California Confidentiality of Medical Information (‘CMIA’); and
    • the Drivers Privacy Protection Act of 1994 (‘DPPA’).

Most of the information that Credit Corp collects is subject to the GLBA as Credit Corp is a financial institution as that term is defined by U.S. Code Ann. §6809(3)(A) and is covered by the GLBA pursuant to U.S. Code Ann. §6809(4)(A)(i-iii). Information subject to the GLBA and processed by Credit Corp is not covered by this Notice because it is not subject to the CCPA.

Data Collection Notice

All California residents have the right to know what Personal Information has been collected about them, what Personal Information has been disclosed about them, and what Personal Information about them has been sold to another party.

Credit Corp regularly collects, and has previously collected, Personal Information from or about California residents, including:

Category

What this may include

Does Credit Corp Collect this Information?

Identifiers

Names, sequence post nominals (such as Jr. Snr.), dates of birth, alias names, residential and mailing addresses, unique personal identifiers, online Identifiers, Internet Protocol (‘IP’) addresses, email addresses, account numbers, account names, social security numbers, Medicare numbers, driver's license numbers, passport numbers or other similar identifiers.

Yes

Personal Information pursuant to California Customer Records Statute (Cal.Civ.Code § 1798.80(e)

Names, signatures, social security numbers, physical characteristics or descriptions, addresses, telephone numbers, passport numbers, driver's license or state identification card numbers, insurance policy numbers, education, employment, employment history, bank account numbers, credit card numbers, debit card numbers, or any other financial information, medical information, or health insurance information.

Yes

Characteristics of protected classifications under California or federal law

Records relating to race, religion, creed, color, national origin, ancestry, physical disability, mental disability, medical condition, marital status, gender or gender identification, sexual orientation, citizenship, age, veteran or military status, or genetic information.

Yes (excluding genetic information)

Commercial Information

Information relating to personal property, products or services purchased, obtained or considered, or other purchasing, consuming histories and tendencies and payment history.

Yes

Biometric Information

Information about an individual's physiological, biological, or behavioral characteristics, including an individual's DNA that can be used, singly or in combination with each other or with other identifying data, to establish individual identity, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a face print, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.

No

Internet or other electronic network activity information

Internet Protocol (‘IP’) addresses, Media Access Control (‘MAC’) addresses, online identifiers, computer type and operating system type and version, screen resolution, internet browser type and version, browsing history, search history, web site interaction history, device type and network service provider, unique device identifiers associated with the device you use to access the site and cookies stored on your computer or device.

Yes

Geolocation Data

Identification or estimation of your real world geographical location, based on your cell phone, internet-connected computer terminal or other device.

Yes

Audio, electronic, visual, thermal, olfactory, or similar information

Voice/audio recordings, electronic, visual or similar information.

Yes, (excluding thermal and olfactory information)

Professional or employment-related information.

Employer name, employment status, role, tenure, employment income, profession, professional qualifications, work history

Yes

Education Information which is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99).

Records that contain information directly related to a student and which are maintained by an educational agency or institution or by a party acting for the agency or institution.

No

Certain inferences drawn from any of the above information

Information to create a profile about a consumer reflecting the consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Yes

Sources of Personal Information:

We collect the above Personal Information:

  • directly from you – such as by telephone, mail, email or web portal;
  • indirectly from you;
  • from third parties;
  • from publically available sources, such as property records, court records or other government records;
  • from our clients and their agents;
  • from our agents or attorneys;
  • from our website, computer systems or telephony system;
  • from our service providers including payment processing and data vendors.

How We Use Your Personal Information:

We regularly use or disclose, and have previously used and disclosed, Personal Information that we collect for one or more of our business or commercial purposes, including:

  • to perform our obligations or exercise our rights under any contract entered into with, or assigned to, Credit Corp;
  • to complete the transaction for which the Personal Information was collected, for example, if you provide us with an updated address, to correspond with you at that address;
  • to perform services on behalf of a business, such as servicing or collecting on accounts owed to that business, including processing payments or transactions and providing customer service;
  • to review and respond to complaints that you raise in relation to our products or services or those of our clients;
  • for quality assurance and compliance purposes;
  • to provide you information that you request we provide, or that we are required to provide by law;
  • to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
  • to debug to identify and repair errors that impair existing intended functionality or improve, upgrade or enhance our service to you or our clients.
  • to comply with any legal obligation;
  • to respond to law enforcement requests as required by law, court order or government regulation;
  • to protect, as may be appropriate, our rights, property or safety, or that of our clients, employees or agents;
  • as described to you at the time of collecting your personal information;
  • in relation to due diligence, mergers, acquisitions or assignment of assets;
  • to contact you about products or services that we, or a related entity provides that might be of interest to you.
  • To develop and carry out marketing activities in order to keep our customers informed about our products and services.
  • To personalize your consumer experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our website, and via email.
  • any other business purpose for which you provide consent.

Credit Corp shall not collect additional categories of Personal Information or use Personal Information collected for materially different purposes without first providing you with notice, including informing you of your right to opt out of the sale of your data.

How We Disclose your Personal Information:

We disclose, and have previously disclosed, Personal information to:

  • our affiliates;
  • our service providers;
  • our attorneys;
  • state and federal regulators;
  • law enforcement agencies;
  • you, or your authorized third parties.

The types of Personal Information we disclose and have previously disclosed includes:

  • names, including alias names;
  • dates of birth,
  • gender;
  • residential and mailing addresses and history,
  • account numbers;
  • payment history and financial information;
  • email addresses;
  • social security numbers;
  • other identifiers;
  • employment information;
  • telephone numbers;
  • IP addresses,
  • military or veteran status;
  • audit information;
  • user name;
  • information collected and shared pursuant to the GLBA, FCRA and FIPA;
  • Other information collected by Credit Corp detailed in the ‘Your Right to Know’ section.

Sales of Personal Information

We do not sell your Personal Information and have not sold your Personal Information over the past 12 months. We do not sell personal information about minors under sixteen (16) years of age.

California Rights and Choices

Subject to certain restrictions, the CCPA gives California residents certain rights to request access to personal information that the Credit Corp has about you and to request deletion of personal information that we collect and maintain. This section describes how you can exercise those rights and our process for handling your requests.

Access to Your Information

You have the right to request information in relation to:

  • the categories of Personal information that we collected about you;
  • the categories of sources of that Personal Information;
  • the specific pieces of Personal Information we have collected about you;
  • our business or commercial purpose or purposes for collecting or selling that Personal Information;
  • The categories of third parties with whom we share that Personal Information;
  • The categories of Personal Information about you which we have sold and, if we sold your Personal Information, the categories of Personal Information that each category of recipient purchased;
  • The categories of Personal Information about you disclosed for a business purpose, and, If we disclosed your information for a business purpose, the categories of Personal Information that that each category of recipient obtained.
  • Any financial incentive offered by us for the collection, sale or deletion of your Personal Information.

If you are a California resident, you can make a right-to-know request to Credit Corp Solutions Inc., under the CCPA regarding your personal information by:

  • Emailing us at:   customercare@creditcorponline.com;
  • Calling us toll free on:   1-800- 483 2361; or
  • Writing to us at:              Credit Corp Solutions Inc;
                                                  Customer Care Department
                                                  2nd floor 121 S Election Rd, Draper, UT 84020

To meet our obligations to protect your privacy, we will need to verify your identify before disclosing any Personal Information to you.

In order to verify you are the person about whom we collected personal information we will verify your identity by matching at least two pieces of personal information provided by you with personal information maintained by us that we have determined to be reliable.

If your request involves receiving specific pieces of personal information (rather than categories of personal information), we must first verify your identity by matching at least three pieces of personal information provided by you with personal information maintained by us that we have determined to be reliable. We may also request that you provide a signed declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

Credit Corp will not use the information that you provide when making a request under the CCPA for any other purpose, other than confirming your identity and processing and responding to your CCPA request. However, we may be required to provide this if compelled by law.

If you are a third party making a request on behalf of a California resident, you will be required to provide sufficient authority, executed by the individual to whom the request relates unless we already hold an effective authority on our files.

Upon receipt of a request under the CCPA, Credit Corp will generally provide you with information within 45 calendar days of your verifiable request. If we determined that we do not hold any Personal Information of are not obligated to provide it, we will write to you within 45 calendar days to notify you.

If you have not provided sufficient information for us to verify your identify or to confirm whether we hold Personal Information relating to you, we will promptly notify you and advise what further information we require to enable us to process your request.

Right to Request Deletion of Personal Information

If you are a California Consumers you have the right to request that Credit Corp deletes all or a part of the Personal Information that we hold in relation to you, subject to some exceptions.

If you are a California resident, you can make a deletion request in relation to Personal Information that we hold about you to Credit Corp Solutions Inc., by:

  • Emailing us at:   customercare@creditcorponline.com;
  • Calling us toll free on:   1-800- 483 2361; or
  • Writing to us at:              Credit Corp Solutions Inc;
                                                  Customer Care Department
                                                  2nd floor 121 S Election Rd, Draper, UT 84020

We will need to verify your identify before we are able to action your request. You may verify your information by providing three points of identification, including your full name, social security number and either your date of birth or your Credit Corp account number. We will also require a point of contact so that we may respond to your request.

Credit Corp will not use this information for any other purpose other than confirming your identity and processing and responding to your CCPA request. However, we may be required to provide this if compelled by law.

If you are a third party making a request on behalf of a California resident, you will be required to provide effective authority, executed by the individual to whom the request relates unless we already hold an effective authority on our files.

Upon receipt of a request under the CCPA, Credit Corp will review its records to determine whether we or our vendors or agents hold any Personal Information about you, whether such information is within scope under the CCPA. We will notify you whether your information has been deleted.

We may not agree to delete your Personal Information if it is necessary for us to maintain the information for any of the following purposes:

  • to complete the transaction for which the Personal Information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between Credit Corp and you;
  • detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
  • debug to identify and repair errors that impair existing intended functionality.
  • exercise free speech, ensure the right of another consumer to exercise that consumer's right of free speech, or exercise another right provided for by law.
  • comply with the California Electronic Communications Privacy Act;
  • 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 our deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent.
  • to enable solely internal uses that are reasonably aligned with your expectations based on your relationship with our business.
  • to comply with a legal obligation.
  • otherwise use your Personal Information internally, in a lawful manner that is compatible with the context in which you provided the information.

If we do not agree to delete your Personal Information, we will advise you of the reasons why it has not been deleted and any rights of appeal that you may have. We will generally do this within 45 calendar days of your verifiable request.

If you have not provided sufficient information for us to verify your identify or to confirm whether we hold your Personal Information relating to you, we will promptly notify you and advise what further information we require to enable us to process your request.

If you have not provided sufficient information for us to verify your identity, however we have been able to reasonably identify you, we will treat your request to delete your Personal Information as a request to opt-out of the sale of your Personal Information.

Right to Opt-Out of the Sale of Personal Information

As a California consumer you have the right to opt out of the sale of your Personal Information by Credit Corp.

Credit Corp does not currently sell Personal Information. To the extend it may do so in the future, notice will be given along with information about your right to opt out of the sale of Personal Information.

If you are a California resident, you can make an Opt-Out request in relation to the sale of your Personal Information that we hold about you to Credit Corp Solutions Inc., by:

  • Emailing us at:   customercare@creditcorponline.com;
  • Calling us toll free on:   1-800- 483 2361; or
  • Writing to us at:              Credit Corp Solutions Inc;
                                                  Customer Care Department
                                                  2nd floor 121 S Election Rd, Draper, UT 84020

We will need to be able to reasonably identify you before we are able to action your request. We will also require a way to communicate the outcome, such as an address or email address.

If you are a third party making a request on behalf of a California resident, we will require evidence that you have authority on behalf of the individual to whom the request relates, unless we already hold records of such authority on our files.

Financial Incentives

Credit Corp does not offer any incentives, including payment, to consumers as compensation for the collection of Personal Information, the sale of Personal Information or the deletion of Personal Information.

Non-Discrimination

California residents have the right to be free from discrimination based on their exercise for their rights pursuant to the CCPA. Credit Corp will not discriminate against you for exercising your rights under the CCPA, including by charging, or suggesting that it may charge, you a different price or provide, or suggest that it may provide, different quality of goods or services due to you exercising, having exercised or intending to exercise your rights under the CCPA.

Authorized Agents

A California resident may appoint an individual or company to act as your authorized agent to exercise any of their rights under the CCPA. For us to be able to interact with this authorized agent, we will require the appropriate authority, as detailed in this policy. In addition to the providing the appropriate authority, your agent will need to verify your identity as outlined in this policy.

More information

For more information in relation this California Privacy Notice, or you're your Personal Information, please feel free to contact us by:

  • Calling us toll free on:   1-800- 483 2361; or
  • Emailing us at:   customercare@creditcorponline.com;
  • Writing to us at:              Credit Corp Solutions Inc;
                                                  Customer Care Department
                                                  2nd floor 121 S Election Rd, Draper, UT 84020

Notice to California Consumers: Collection of Personal Information

  • Credit Corp is a Financial institution as that term is defined by U.S. Code Ann. 15 § 6809(3)(A) (“GLBA”). In the course of business, Credit Corp, may collect data, including personal information from you. Because Credit Corp is a Financial Institution under the GLBA, it takes all measures required under the GLBA to protect the privacy of your data.
  • Information that is collected about you in connection with providing a financial service is exempt from the operation of the CCPA pursuant to Cal. Civ. Code 1798.145(e). This is because it is covered under the GLBA.

Changes to our California Privacy Notice

We may update our California Privacy Notice from time to time. Where we do this we will publish the updated version on our webpage.

 

This Californian Privacy Notice was last updated on 24/12/2019