California Privacy Policy
Important Privacy Choices for California Consumers
If you are a California Resident, you may ask businesses to disclose what personal information they have about you and what they do with that information, to delete your personal information, to correct inaccurate information that they have about you, and to limit the business’ use and disclosure of your sensitive personal information.
For purposes of this section, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer/resident or household. Personal information does not include publicly available information or information that has been de-identified. In our descriptions, we have included all data collected without regard to exempt data under other regulations such as the Gramm-Leach-Bliley Act (“GLBA”). However, by doing so, we do not intend to waive claims of preemption under the GLBA and other similar regulations.
INFORMATION WE COLLECT
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information relating to consumers within the last twelve (12) months:
| Category | Examples | Collected |
|---|---|---|
| Identifiers | 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 |
| Personal information categories listed in the California Customer Records statute (Cal.Civ. Code § 1798.80(e)) | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. | YES |
| Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | YES |
| Commercial Information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | YES |
| Biometric Information | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | NO for customers YES for certain employees |
| Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | YES |
| Geolocation data | Physical location or movements. | YES |
| Sensory data | Audio, electronic, visual, thermal, olfactory, or similar information. | YES |
| Professional or employment-related information. | Current or past job history or performance evaluations. | YES |
| Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99) | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO |
| Inferences drawn from other personal information. | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | YES |
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMMIA) or clinical trial data;
- Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Billey Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from our clients or their agents. For example, from documents that our clients provide to us related to the service for which they engage us.
- Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.
- Directly and indirectly from activity on our website (www.freedomsolve.com). For example, from submissions through our website portal or website usage details collected automatically.
- From third-parties that interact with us in connection with the services we perform. For example, from affiliate marketers who place ads and forward activity to us or from credit reporting agencies (“CRA”).
- Information that is publicly available online or elsewhere and
- Employees and job applicants
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
- To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order for us assist you in debt settlement activities.
- To provide you with information, products or services that you request from us.
- To provide you with email alerts, newsletters and other notices concerning our products or services, or events or news, that may be of interest to you.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
- To assist you in identifying appropriate resources if we cannot serve you for any of a number of reasons including, but not limited to, inability to operate in the state of request or lack of eligible debt
- To provide a third party with qualified leads for a program that they may administer
- To improve our website and present its contents to you.
- For testing, research, analysis and product development.
- To conduct audit, compliance or other legal work associated with our business.
- To perform financial reporting and accounting and other general business administration
- To assess third party vendors and services providers
- As necessary or appropriate to protect the rights, property or safety of us, our customers or others.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category D: Commercial information
Category E: Biometric data
Category F: Internet or other similar network activity.
Category I: Professional or employment-related information.
Category K: Inferences drawn from other personal information
We disclose your personal information for business purposes to the following categories of third parties:
- Our affiliates.
- Service Providers.
- Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
We may also disclose your personal information to a third party for a commercial purpose. When we disclose personal information for a commercial purpose, which may include providing your information to a provider which can assist you, we have a compensatory relationship which requires the recipient to abide by data privacy regulations and not use it for any purpose except as described.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a commercial purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category D: Commercial information
We disclose your personal information for a commercial purpose to the following categories of third parties:
- Our affiliates.
- Corporate credit facility lenders.
- Service providers.
- Vendors.
- Other third parties including marketers.
Your Privacy Rights
If you are a California resident, subject to applicable law, you have the following rights under California law with respect to your personal information, to the extent your personal information is not already subject to federal law and the required privacy and security measures applied under federal law:
- Right to know. You have the right to request what personal information we collect, use, disclose, and/or sell, as applicable.
- Right to Delete. You have the right to request the deletion of your personal information that is collected or maintained by us.
- Right to Opt–Out of Sale. You have the right to opt-out of the sale of your personal information by us.
You may access our Notice of Right to Opt-Out by clicking here. - Right to Data Portability. You have the right to request a portable version of your data.
- Right to Non–Discrimination. You have the right not to receive discriminatory treatment by us for the exercise of the privacy rights described above.
You may also authorize someone to exercise the above rights on your behalf. In order to have a third party exercise rights on your behalf as an agent, the third party would need to fill out the same forms as the consumer and have a notarized letter authorizing them to act on your behalf. The agent would also need to be able to have sufficient data to verify the identity of the consumer in question.
The above rights are subject to our being able to reasonably verify your identity and authority to make these requests. These rights are also subject to various exclusions and exceptions under applicable laws. In order to verify your identity for prospective consumers, you must provide first and last name, state of residence, phone, physical address and email. If you are a current customer, you must also provide the social security number or other identifying account number in addition to the items required for prospective consumers.
If you are a California resident and wish to seek to exercise these rights, please reach us in one of the following ways:
- By phone: (844) 378-9760
- By email: info@freedomsolve.com.
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