California Privacy Notice
This Privacy Notice for California Residents is an addendum to the Privacy Policy of ADVANTAGE FIRST FINANCIAL and its affiliates (collectively referred to as “we,” “us,” or “our”). This notice applies specifically to visitors, users, households, and other individuals residing in California (“consumers” or “you”). We issue this notice in compliance with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Terms defined in the CCPA carry the same meaning in this notice.
Information We Collect
We collect information that identifies, relates to, describes, references, or is associated with, or could reasonably be linked directly or indirectly with a particular consumer or device (“personal information”). The following chart lists the categories of personal information we have collected in the past twelve (12) months:
|
Category |
Examples |
Collected |
|
A. Identifiers |
A real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. |
YES |
|
B. 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 ID card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. |
YES |
|
C. 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 |
|
D. Commercial information. |
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
YES |
|
E. 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 |
|
F. Internet or other similar network activity. |
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. |
YES |
|
G. Geolocation data. |
Physical location or movements. |
YES |
|
H. Sensory data. |
Audio, electronic, visual, thermal, olfactory, or similar information. |
YES |
|
I. Professional or employment-related information. |
Current or past job history or performance evaluations. |
YES |
|
J. 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 |
|
K. 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, such as:
- Health or medical information covered by the Health Insurance Portability and Accountability Act (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data.
- Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), the California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
Sources of Personal Information
We obtain the categories of personal information listed above from the following sources:
- Directly from our clients or their agents (e.g., from documents related to the services they engage us for).
- Indirectly from our clients or their agents (e.g., through information collected in the course of providing services to them).
- Directly and indirectly from activity on our website (www.advantagefirst.com), such as 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 (e.g., from affiliate marketers who place ads and forward activity to us or from credit reporting agencies (“CRA”)).
- Publicly available information online or elsewhere.
- 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 (e.g., if you provide personal information to assist in debt consolidation activities).
- To provide you with information, products, or services that you request from us.
- To send you email alerts, newsletters, and other notices about our products, services, or events that may interest you.
- To carry out our obligations and enforce our rights arising from contracts entered into between you and us, including for billing and collections.
- To assist you in identifying appropriate resources if we cannot serve you.
- To provide a third party with qualified leads for a program 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 service 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 into a contract that describes the purpose and requires the recipient to keep that personal information confidential and not use it for any purpose except performing the contract.
In the past 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 a business purpose 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. In such cases, we have a compensatory relationship that requires the recipient to abide by data privacy regulations and use the information only as described.
In the past 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 Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. These rights and choices are detailed in our Privacy Policy.
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you here, by a notice on our homepage, and/or by any other acceptable means.
Contact Information
If you have any questions or comments about this notice, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact us at:
Toll Free: 855-661-3328
Effective Date: March 2024