California Consumer Privacy Notice

MoneySpot Direct, LLC California Privacy Policy

The State of California requires that we provide privacy information for individuals that are residents of California.  If you are not a resident of California, you can disregard this document.

For California residents, here is a summary of what you will learn from this privacy policy:

1.0. Personal Information We Collect

1.1. What Personal Information Does Not Include

1.2. Categories of Personal Information Collected

1.3. How We Obtain Your Personal Information

1.4. How We Use Your Personal Information

1.5. How We Disclose Your Personal Information

1.6. Sale or Sharing of Personal Information

2.0. Your Rights Under the California Consumer Privacy Act of 2018

2.1. Right to Know

2.2. Right to Delete

2.3. Right to Opt-Out of Sale or Sharing

2.4. Right to Correct

2.5. Right to Limit Use and Disclosure of Sensitive Personal Information

2.6. Right to Non-Discrimination

3.0. Submitting a Request

3.1. How to Submit a Request

3.2. Authorized Agents

3.3. Response Timing and Delivery Method

4.0. Do Not Track Signals/Global Privacy Controls

5.0. Retention of Your Information

6.0. Changes to this California Privacy Policy

7.0. How to Contact Us

Below is the legal information we are required to share:

This California Privacy Policy, a copy of which can be found at www.sunshineloans.com , supplements the information contained in the Privacy Policy of MoneySpot Direct LLC and MoneySpot USA LLC, (collectively, “we,” “us,” or “our”) and applies solely to visitors, users, and others who are residents of the State of California (“consumers” or “you”).  We adopt this privacy policy to comply with the California Consumer Privacy Act (“CCPA”), as amended from time to time and its implementing regulations, and other California privacy laws.  Any terms defined in the CCPA have the same meaning when used in this Privacy Policy.

1. PERSONAL INFORMATION WE COLLECT

We collect information that identifies, relates to, describes, or could reasonably be linked, directly or indirectly, with a particular consumer (“personal information”).

1.1. What Personal Information Does Not Include

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:
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

1.2. Categories of Personal Information We Collect

In the last 12 months, we collected the following categories of personal information:

• “Identifiers” such as name, date of birth, postal address, unique personal identifier, online identifier, internet protocol address, email address, account number, or other similar identifiers;
• “Other Personal Information” such as name, signature, physical characteristics or description, address, telephone number, insurance policy number, education, employment, employment history, bankruptcy status, bank account number, credit card number, debit card number, or any other financial information, or medical information. Some personal information included in this category may overlap with other categories;
• “Protected Characteristics” under California or federal law for classifications such as 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, or veteran or military status;
• “Commercial Information” such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
• “Internet or Network Activity” such as browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement;
• “Biometric Information” such as 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, or gait;
• “Geolocation Data” such as physical location or movements;
• “Sensory Data” such as audio, electronic, or visual information;
• “Professional or Employment Related Information” such as current or past job history or performance evaluations;
• “Inferences” such as a profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes; and
• “Sensitive Personal Information” such as Social Security Number, passport number, driver’s license or state identification card number, precise geolocation, and financial account information in combination with applicable account access credentials.

1.3. How We Obtain Your Personal Information:

1.4. How We Use Your Personal Information:

We may use or disclose the personal information we collect for one or more of the following purposes:

1. Performing services on behalf of us or our service provider, including maintaining or servicing accounts, providing customer service, processing transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of us or our service providers.  This includes:
   1. to fulfill or meet the reason for which the information is provided;
   2. to provide you with information, products, or services that you request from us;
   3. to provide you with email alerts and other notices concerning our products or services, or events or news, that may be of interest to you; and
   4. to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
2. Undertaking internal research for technological development and demonstration;
3. Debugging to identify and repair errors that impair existing intended functionality;
4. Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes;
5. Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
6. Undertaking activities to verify or maintain the quality or safety or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us;
7. For short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about you or otherwise to alter your experience outside the current interaction, including, but not limited to, the contextual customization of advertisements shown as part of the same interaction; and
8. To comply with our legal or regulatory obligations.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

1.5 How We Share Your Personal Information:

We may disclose your personal information to a business for whom we are a service provider, our service providers or a third party for a business or commercial purpose. We may disclose the following categories of Personal Information for a business purpose: Identifiers, Other Personal Information, Protected Characteristics, Commercial Information, Internet or Network Activity, Geolocation Data, Professional or Employment Related Information, Biometric Information, Sensitive Personal Information, and Sensory Data. When we disclose personal information to a service provider, we enter into a contract that describes the purpose and requires the service provider to both keep the personal information confidential and not use it for any purpose except performing the services described in the contract or as provided for in the CCPA. Examples of who we disclose personal information with include:

• Businesses for whom we are a service provider;
• Our service providers; and
• Third parties:
  • With our affiliates we disclose personal information of the following categories: Identifiers, Other Personal Information, Protected Characteristics, Commercial Information, Internet or Network Activity, Geolocation Data, Sensitive Personal Information, and Professional or Employment Related Information.
  • With our bank and lending relationships we disclose personal information of the following categories: Identifiers, Other Personal Information, Protected Characteristics, Commercial Information, Internet or Network Activity, Sensitive Personal Information, and Geolocation Data.
  • With credit reporting agencies we disclose personal information of the following categories: Identifiers, Other Personal Information, Protected Characteristics, Commercial Information, Sensitive Personal Information, and Geolocation Data.
  • With government entities we disclose personal information of the following categories:  Identifiers, Other Personal Information, Protected Characteristics, Commercial Information, Biometric Information, Geolocation Data, Sensitive Personal Information, and Sensory Data.
  • With advisors such as lawyers, accountants, banks, and insurers, we disclose personal information of the following categories: Identifiers, Other Personal Information, Protected Characteristics, Commercial Information, Biometric Information, Geolocation Data, Sensitive Personal Information, and Sensory Data.

1.6. Sale of Personal Information:

We do not sell or share your personal or sensitive personal information.  We do not sell or share the personal information of minors of 16 years of age or less.

2.0. YOUR RIGHTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT OF 2018

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights, if applicable.

2.1. Right to Know:

You have the right to request (“Request to Know”) that we disclose certain information to you about our collection, use and disclosure of your personal information over the past 12 months (“Right to Know”).  Once we receive and verify your request, we will disclose to you:

• For requests for categories of personal information collected and disclosed:
  • 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 that personal information.
  • The categories of third parties with whom we disclose that personal information.
  • If we disclosed your personal information for a business purpose, the categories of personal information disclosed with each category of third-party recipients.
• For requests for specific information
  • specific pieces of personal information we collected about you.

2.2. Right to Delete:

You have the right to request that we delete any of your personal information that we collected from you, subject to certain exceptions (“Right to Delete”). Once we receive and verify your request, we will delete, de-identify, or aggregate your personal information (and direct our service providers to do the same), unless an exception applies.

We may deny your Request to Delete if retaining the personal information is necessary for us or our service providers to:

• complete the transaction for which the personal information was collected, provide a good or service requested by the consumer, or reasonably anticipated within the context of a business’s ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer;
• 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 his or her right of free speech, or exercise another right provided for by law;
• comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code;
• 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 businesses’ deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent;
• enable solely internal uses that are reasonably aligned with your expectations based on our relationship with you;
• comply with legal or regulatory obligations; or
• otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

2.3. Right to Opt-Out of Sale or Sharing:

Under the CCPA, you have the right to opt-out of the sale or sharing of your personal information (“Right to Opt-Out”).  However, we do not sell or share your personal information.  Further, we do not sell or share the personal information of minors 16 years of age or less without affirmative authorization.

2.4. Right to Correct:

You have the right to ask us to correct (“Right to Correct”) any inaccurate personal information we maintain about you. Once we receive and confirm your verifiable consumer request, we will undertake a review and amend and correct your personal information found to be inaccurate.

2.5. Right to Limit Use and Disclosure of Sensitive Personal Information:

You have the right to ask us to limit our use and disclosure of your sensitive personal information (“Right to Limit Use and Disclosure”). However, we do not use or share your sensitive personal information beyond what is necessary for our ongoing business relationship with you.

2.6. Right to Non-Discrimination or No Retaliation:

You have the right to not be discriminated or retaliated against for exercising your rights under the CCPA (“Right to No Discrimination or Retaliation”).  Unless permitted by the CCPA, we will not:

• deny you goods or services;
• charge you higher prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
• provide you a lower level or quality of goods or services; or
• suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

3.0. SUBMITTING A REQUEST

3.1. How to submit a request:

To make a request, please contact us by either:

• Calling us at (800) 504-9776
• Visiting www.sunshineloans.com and clicking on the California Consumer Privacy Act (CCPA) Requests link located in the footer.

Only (1) you, (2) a person authorized by you to act on your behalf, or (3) an entity registered with the California Secretary of State and authorized by you to act on your behalf, may make a Request to Know or Request to Delete related to your personal information. You may also make a request on behalf of your minor child.

You may only make certain requests twice within a 12-month period.

A request must:

• provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized agent.  Given the sensitivity of your personal information that we collect and retain, we will need to verify your identity with at least 3 separate pieces of information such as name, address, account number, date of birth, last 4 digits of your Social Security number, phone number, etc.; and
• describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to it.

For Requests to Know specific pieces of information (as opposed to categories of personal information), you will need to sign and return a declaration signed under the penalty of perjury stating that you are making the request on behalf of yourself.  Please be aware that for certain types of personal information, such as your Social Security number, we will inform you whether we have collected the type of information, but we will not disclose the actual piece of information.

3.2. Authorized Agents:

Before we can respond to a Request to Know or Request to Delete submitted by an authorized agent, we need to verify not only that person or entity’s authority to act on your behalf but also verify the identity of the authorized agent.

If you are authorized to submit a request on behalf of a California resident, please email us at [email protected] and provide the following information:

1. To verify your authorization to submit a request on behalf of a California resident, please attach a copy of one or more of the following to your request email:

• California Secretary of State authorization,
• written permission from the California resident, or
• power of attorney.

2. To verify your identity, please attach copies of the following to your request email:

• valid Government-Issued ID (not expired) AND
• a utility bill, bank statement, or similar documentation to verify your name and address.

3. To verify the identity of the consumer for whom you are submitting the request, please submit the required information by calling us at (800) 504-9776 or visiting www.sunshineloans.com and clicking on the California Consumer Privacy Act (CCPA) Requests link located in the “Legal” section of the footer.

We cannot respond to your Request to Know or Request to Delete or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a request to verify the requestor’s identity or authority to make the request.

3.3. Response Timing and Delivery Method:

We will acknowledge receipt of a request within 10 business days of its receipt.  We will respond to a request within 45 days of its receipt. If we require more time (up to 45 additional days for a total of 90 days from receipt of the request), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, depending on whether or not you include your email with the request submission. Any response to a Request to Know that we provide will only cover the 12-month period preceding our receipt of the Request to Know. Responses to any request that we provide will also explain the reasons we cannot comply with a request, if applicable.

We do not charge a fee to process or respond to your 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.

We may deny your request if we are unable to verify your identity or have reason to believe that the request is fraudulent.  We may also deny your request if the personal information is subject to an exemption under the FCRA, the GLBA, the FIPA, or the DPPA.

Please be aware that the CCPA does not require us to comply with requests related to information under certain exceptions, including:

• health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and the California Confidentiality of Medical Information Act (“CMIA”) or clinical trial data; or
• personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (“FCRA”), the Gramm-Leach-Bliley Act (“GLBA”) or California Financial Information Privacy Act (“CalFIPA”), and the Driver’s Privacy Protection Act of 1994 (“DPPA”).

4.0. DO NOT TRACK SIGNALS / GLOBAL PRIVACY CONTROLS

Our site does not respond to Do Not Track signals configured in your web browser.

5.0. RETENTION OF YOUR INFORMATION

The length of time we retain your personal information depends on several factors.  We retain your personal information throughout our relationship with you and for additional time as required by applicable laws and regulations or for other legal purposes, such as preparing for and defending against litigation.  Additional factors that may impact our retention include: contractual obligations.

6.0. CHANGES TO THIS CALIFORNIA PRIVACY POLICY

We reserve the right to amend this California Privacy Policy at our discretion and at any time. If we make material changes to this California Privacy Policy, we will notify you by email or by posting the updated notice on our website with its effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

7.0. HOW TO CONTACT US

If you have any questions or comments about this California Privacy Policy, the ways in which we collect and use your personal information, your rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us by:

Email: [email protected]

Toll-Free Number: (800) 504-9776

Website: www.sunshineloans.com

Postal Address: Sunshine Loans

Attn: Customer Service

312 Arizona Ave, Suite 218

Santa Monica, CA 90401

REV 7.28.23