CALIFORNIA CONSUMER PRIVACY ACT (CCPA) DISCLOSURE AND NOTICE AT COLLECTION

Posted Date: December 20, 2023
Effective Date: January 1, 2024

This California Privacy Notice (“Notice”) is provided under California law, including the California Consumer Privacy Act (“CCPA”), Cal. Civ. Code 1798.100 et seq. and the regulations adopted pursuant to the CCPA. This Notice supplements the information contained in the Privacy Policy by explaining your privacy rights if you are a California resident, providing our “notice at collection”, and providing certain mandated disclosures about our treatment of California residents’ information, both online and offline. This Notice is provided by Renew Financial Group LLC and its affiliates and subsidiaries (collectively “Renew Financial,” “we” or “us”). Any terms defined in the CCPA have the same meaning when used in this Notice. Capitalized terms not defined herein or in the CCPA, have the same meaning as the Privacy Policy.

Notice of Collection of Personal Information

We collect this information so that we can best serve you, including to fulfill your requests and to share offers that we think you may be interested in. We may also use your information as set forth in the Privacy Policy. We collect these categories of personal information when you interact with us. Some data collected may qualify under multiple categories.

CATEGORY OF DATA COLLECTED	SHARED*	SOLD
Identifiers- including 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.	No	No
Characteristics of protected classifications under applicable laws including age, date of birth and military or veteran status.	No	No
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	No	No
Internet or other electronic network activity information, including IP address, browsing history, search history, geo-location data collected through cookies and similar technologies.	No	No
Sensory data, including audio recordings.	No	No
Professional or employment-related information, including the business or organization an individual represents, their title with that business or organization and information relating to their role with the business or organization.	No	No
Sensitive Personal Information, including social security, driver’s license, state identification card, or passport number, account log-in, financial account, credentials allowing access to an account, geolocation, racial or ethnic origin, or union membership. Each type of Sensitive Personal Information may also fall under another category of personal information.	No	No
Demographic data, including age, date of birth, location and zip code.	No	No
Inferences drawn from other personal information or data, including consumer’s preferences, credit characteristics, investment trends, financial behavior, household size.	No	No

* We do not share or sell personal information of known minors under 16 years of age. Since we do not share or sell your information to third parties, an opt-out mechanism is not offered or required. For the categories of service providers with who we share your information please see section Sharing with Service Providers in our Privacy Policy.

Your Rights

Right to Know

You have the right to know what personal information we have collected about you, including the categories of personal information, the categories of courses from which the personal information is collected, the business or commercial purpose for collecting, selling or sharing personal information, and the specific pieces of personal information we collected about you.

Right to Access

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or sharing that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Right to Limit Sharing of Sensitive Personal Information

You have the right to request that we limit the use and disclosure of your Sensitive Personal Information, subject to certain exceptions. We use your Sensitive Personal Information to perform the services reasonably expected. We may also use your Sensitive Personal Information to ensure the security and integrity of your Personal Information, conduct non-personalized advertising, perform services on behalf of our business, and undertake activities to improve or enhance our services.

Your Right to Correct

You have the right to request that we correct any inaccurate personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information. We will use commercially reasonable efforts to correct the inaccurate personal information as you direct, pursuant to § 1798.130 and regulations adopted pursuant to paragraph (8) of subdivision (1) of § 1798.185.

Your Right to Delete

California residents have the right to request that we delete personal information that we collect from you, subject to applicable legal exceptions.

Right to Opt-Out of Sale or Sharing of Personal Information

California residents have the right to “opt out” of the “sale” or “sharing” of your “personal information” to “third parties”. In the past 12 months we have sold the following categories of personal information: NONE

Your Right not to receive Discriminatory Treatment

You have a right not to be discriminated or retaliated against for the exercise of your privacy rights under the CCPA.

Process to Make a CCPA Request

Making Access and Deletion Requests

To make an access, correction, or deletion request, please call us at 844-736-3934 or visit https://renewfinancial.info/privacy-policy to access the web form. Before completing your request, we will verify your identity with the information we have on file or may reach out to you for additional information. Your authorized agent may also submit a request on your behalf by visiting https://renewfinancial.info/privacy-policy to access the web form. An authorized agent must have your written signed permission to submit a request on your behalf or provide proof that they have a power of attorney in accordance with applicable state law. Before completing requests from authorized agents, we may contact you directly to confirm you’ve given your permission and/or to verify your identity.

Once we receive and confirm your verifiable consumer request, we will act upon your request as required by law. If you requested we delete your personal information from our records, we will do so, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
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 the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. 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 preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data 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.

Making Requests to “Opt-Out” of the “Sale” or “Sharing” of “Personal Information” or Limit sharing of “Sensitive Personal Information”

You do not have a choice to opt-out as we do not sell or share personal information or personal sensitive information with third parties. We do not recognize or honor global privacy controls (also known as the “opt-out preferences” communicated by your web browser) because we do not sell or share your personal information with third parties. We only use personal sensitive information to provide the services you request. As such, you may not limit our use of your sensitive personal information. Your authorized agents are subject to the same restrictions as stated above and on requests to limit use of sensitive personal information. You have the right not to receive discriminatory treatment for the exercise of your privacy rights conferred by the CCPA.

Non-Discrimination

We will not discriminate against you for exercising any of your rights outlined in this Notice. Unless permitted, we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.

Retention of Personal Information and Sensitive Personal Information

We retain personal information and sensitive personal information (collectively referred to as ‘personal data’ in this section only) for as long as is reasonably necessary to fulfill the purpose for which it was collected. However, if necessary, we may retain personal information for longer periods of time, until set retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax and accounting requirements set by a legislature, regulator or other government authority.

To determine the appropriate duration of the retention of personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal data and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting and other applicable obligations.

We shall retain personal data for as long as the individual continues to use our Program Services for the purposes explained in our Privacy Policy. When an individual discontinues the use of our Program Services, we will retain their personal data for as long as necessary to comply with our legal obligations, to resolve disputes and defend claims, as well as, for any additional purpose based on the choices they have made, such as to receive marketing communications. In particular, we will retain personal data supplied when joining our services, including complaints, claims and any other personal data supplied during the duration of an individual’s contract with us for the services until the statutory limitation periods have expired, when this is necessary for the establishment, exercise or defense of legal claims.

Once retention of the personal data is no longer necessary for the purposes outlined above, we will either delete or de-identify the personal data or, if this is not possible (for example, because personal data has been stored in backup archives), then we will securely store the personal data and isolate it from further processing until deletion or de-identification is possible.

If you have a question about our privacy policies you can reach us through the methods listed under the Contacting Us section in our Privacy Policy.