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CALIFORNIA RESIDENTS PRIVACY POLICY

INTRODUCTION

This California Privacy Policy explains how Civic Financial Services, LLC (“CIVIC,” “we,” “us,” or “our”) collects, shares, uses, and protects your personal information through your online and offline interactions with us. This California Privacy Policy applies only to California residents and supplements our Privacy Policy at https://www.civicfs.com/privacy. Please click here for a printable PDF version of this Disclosure.

NOTICE OF COLLECTION

We collect personal information from and about you in the administration and processing of your loan application, and servicing of your loan. We also collect personal information from job applicants, as well as when you interact with CIVIC as an employee, representative, or agent of a merchant, vendor, or other business entity.

California residents have the right under the California Consumer Privacy Act (CCPA) to receive notice of the categories of personal information (as defined under the CCPA) that we collect, the purposes for which those categories of personal information will be used, and the types of entities with whom we disclose or “sell” such information. To the extent that we collect personal information that is subject to the CCPA, that information and our practices are described below. The categories we use to describe the information are those enumerated in the CCPA. Certain personal information may fall into multiple categories.

Categories of consumer's Personal Information collected 
Identifiers

Name; Alias; Postal address; Email address; Any provided phone number; Account name; Passwords and other security information for authentication and access; Insurance information; IP address; Social security number; Driver’s license number; Passport number; State identification card number; Unique personal identifier

Source: You; Service Providers that perform support services for your account or facilitate your transactions with us; From a business entity you represent

Purpose of collection and use: To provide you with services; To market our services to you; To fulfill any regulatory or legal obligation that may arise from servicing you; To process payments; To contact you and respond to your request and inquiries; To communicate with you about open and pending matters; To analyze preferences, trends, and statistics; To process job applications

Categories of parties to whom PI is sold: None

Categories of parties to whom PI is disclosed: Service Providers; Assignees; Necessary or Appropriate Purposes, as described below
Financial information

Credit or debit card number, along with its verification number and expiration date; Bank account information; Payroll cards

Source: You; Service Providers that perform support services for your account or facilitate your transactions with us

Purpose of collection and use: To provide you with services; To fulfill any regulatory or legal obligation that may arise from servicing you; To process payments; To contact you and respond to your request and inquiries; To communicate with you about open and pending matters

Categories of parties to whom PI is sold: None

Categories of parties to whom PI is disclosed: Service Providers; Assignees; Necessary or Appropriate Purposes, as described below
Geolocation data

The general region or area from which you access our websites; Badge swipes at our offices

Source: You; Service Providers that perform support services for your account or facilitate your transactions with us

Purpose of collection and use: To analyze preferences, trends, and statistics; To operate, understand, optimize, develop, or improve our sites, applications, products, services and operations; To detect security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; To debug, to identify and repair errors that impair existing intended functionality; To investigate and prevent activities that may violate our policies

Categories of parties to whom PI is sold: None

Categories of parties to whom PI is disclosed: Service Providers; Assignees; Necessary or Appropriate Purposes, as described below
Demographic information

Race; Gender; National origin; Age; Religion or creed; Marital status; Medical condition, physical or mental disability; Citizenship status; Sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions); Sexual orientation; Veteran or military status

Source: You; Service Providers that perform support services for your account or facilitate your transactions with us

Purpose of collection and use: To provide you with services; To market our services to you; To fulfill any regulatory or legal obligation that may arise from servicing you; To analyze preferences, trends, and statistics; To process job applications (if provided)

Categories of parties to whom PI is sold: None

Categories of parties to whom PI is disclosed: None
Professional, educational, or employment-related information

Education records; Current or past job history

Source: You; External parties (including previous employers and reference); Service Providers that perform support services for your account or facilitate your transactions with us

Purpose of collection and use: To provide you with services; To contact you and respond to your request and inquiries; To communicate with you about open and pending matters; To process job applications

Categories of parties to whom PI is sold: None


Categories of parties to whom PI is disclosed: Service Providers; Assignees; Necessary or Appropriate Purposes, as described below
Internet or electronic network activity information

Email; Browsing history; Search history; Information regarding a consumer’s interaction with an Internet website, application or advertisement; Internet Protocol address; Device ID; Unique Personal Identifier; Online Identifier

Source: Automatically generated when you interact with our website or advertisements

Purpose of collection and use: To analyze preferences, trends, and statistics; To operate, understand, optimize, develop, or improve our sites, applications, products, services and operations; To detect security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; To debug, to identify and repair errors that impair existing intended functionality; To investigate and prevent activities that may violate our policies

Categories of parties to whom PI is sold: Advertising and Analytics Providers


Categories of parties to whom PI is disclosed: Service Providers; Necessary or Appropriate Purposes, as described below
Commercial information

Records of personal properties, investments, products or services purchased, obtained or considered; Other purchasing or consuming histories

Source: You; Service Providers that perform support services for your account or facilitate your transactions with us

Purpose of collection and use: To provide our services; To market our services to you; To fulfill any regulatory or legal obligation that may arise from servicing you; To contact you and respond to your request and inquiries; To communicate with you about open and pending matters; To analyze preferences, trends, and statistics

Categories of parties to whom PI is sold: None

Categories of parties to whom PI is disclosed: Service Providers; Necessary or Appropriate Purposes, as described below
Audio and visual information

Security camera recordings in our facilities; call recordings

Source: You

Purpose of collection and use: To analyze preferences, trends, and statistics; To detect security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; To debug, to identify and repair errors that impair existing intended functionality; To investigate and prevent activities that may violate our policies

Categories of parties to whom PI is sold: None

Categories of parties to whom PI is disclosed: Service Providers; Necessary or Appropriate Purposes, as described below

 

COOKIES AND INTERNET ADVERTISING

When you visit our site or interact with us through your device we may collect “User Activity Information” through cookies, web beacons and other similar or related technologies (collectively, referred to as cookies). Cookies are small text files saved on your device via your browser as you visit our site. Web beacons (also known as pixels or tags) are a common form of web technology used on our site to monitor visits to certain pages within, interactions with, and the effectiveness of, our sites and our marketing efforts. User Activity Information collected on our sites could potentially be used by third parties for their own purposes, some of whom may be able to associate such information with you based on other information they have collected independently of CIVIC. See our Privacy Policy at https://www.civicfs.com/privacy for additional information about cookies, and below at RIGHT TO OPT-OUT for details on how to opt-out.

DISCLOSING YOUR PERSONAL INFORMATION

We will disclose personal information in your loan file if your loan is assigned to another creditor or serviced by another institution. Under both circumstances, your personal information will be used consistent with the purpose for which it was originally collected.

We also disclose personal information to service providers who do things on our behalf. For example, we will disclose information to title companies, appraisers, and insurance companies who assist us in the administration, processing, and servicing of your application and loan, as well as with vendors who provide technology, user assistance, research, and analysis services to us, and to recruiters in the case of job applicants. When we disclose personal information for a business or commercial purpose, we enter a contract that describes the purpose and requires the recipient to keep that Information confidential and not to use it for any purpose except performing the contract, unless otherwise permitted by law.

Personal information may also be disclosed when we believe it is necessary or appropriate to: (i) comply with applicable legal requirements, (e.g. regulatory, court, and law enforcement demands); (ii) respond to an emergency or otherwise protect the rights and property of CIVIC and our employees, customers, or others, including to enforce any contract between you and us; (iii) address fraud, security, or technical issues; and (iv) in connection with, or during negotiation of, any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets.

RIGHT TO OPT-OUT

We recognize Global Privacy Control signals if enabled in your browser. You can also opt-out of the use of certain third-party cookies on our website by clicking the “Cookie Settings” link on our website. (The California Consumer Privacy Act refers to this as a “Do Not Sell” request.)

RIGHT TO KNOW/ACCESS

You may request that we provide to you (1) the categories of personal information collected; (2) the sources from which personal information was collected; (3) the business or commercial purpose for collecting or sharing the personal information; (4) the categories of third parties with whom we share the personal information, if any; and (5) the specific pieces of personal information we collected about you. Some information we have is subject to exceptions under California law.

RIGHT TO CORRECT

You can review and update your personal information by logging into Origin8 at https://www.origin8now.com/ and visiting your account profile page, or by submitting a request to correct as noted below.

RIGHT TO DELETE/LIMIT USE OF CERTAIN INFORMATION

In some circumstances, you may request that we delete or limit the use of certain of your personal information. Such requests are subject to certain limitations, for example, we are not required to delete information if the information is necessary for us to complete a transaction for you or otherwise perform a contract; to detect, protect against, or prosecute security incidents, fraud or illegal activity; to use the information only internally in ways reasonably aligned with your expectations as our customer and to comply with legal obligations.

HOW TO SUBMIT YOUR REQUEST

To submit a request relating to your personal information, please call our toll-free number at (855) 956-0661 or submit an online form at https://civicfs.com/ccpa. When you submit your request, you will be required to provide please provide your name, email address, physical address, phone number, and last four digits of your loan number (as applicable). Thereafter we will contact you (via email at the address provided) with instructions on how to verify your request before we fulfill it.  If additional information is necessary to authenticate your request, we will also let you know.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your Personal Information (“Authorized Agent”). If you choose to use an Authorized Agent, we require that you provide the Authorized Agent with written permission to allow him or her to submit your request and that you verify your identity directly with us. Failure to do so may result in us denying your request.

We will not discriminate against you in price or service if you submit a privacy request.

RETENTION

We will retain your personal information for as long as is necessary to complete the purposes for which it was collected, or as may be required by law. We utilize the following criteria to determine the length of time for which we retain information: (i) the business purposes for which the information is used, and the length of time for which the information is required to achieve those purposes; (ii) whether we are required to retain the information in order to comply with legal obligations or contractual commitments, to defend against potential legal claims, or is otherwise necessary to activities potentially in violation of our policies and procedures applicable to you or against the law, to ensure a secure online environment, or to protect health and safety; (iii) the privacy impact on the consumer of ongoing retention; and (iv) the manner in which information is maintained in our systems, and how best to manage the lifecycle of information in light of the volume and complexity of the systems in our infrastructure.

CHANGES TO THIS DISCLOSURE

We may change or update this California Privacy Policy in the future. When we do, we will post the revised California Privacy Policy on our website.

CONTACT INFORMATION

If you have any questions about this privacy policy, you can email us at privacy@civicfs.com. To reach us by mail, write to us at the following address: Attention: Compliance Department, Civic Financial Services, LLC, 2015 Manhattan Beach Blvd., Suite 106, Redondo Beach, CA 90278.

This Policy was last modified on December 12, 2022.