SECURE ONE CAPITAL CCPA Notice

CALIFORNIA CONSUMER PRIVACY POLICY ACT NOTICE (CCPA)

This PRIVACY POLICY is for California residents only and supplements the information contained in the privacy notice of Secure One Capital Corporation and its subsidiaries (collectively, “we,” “us,” or “our”) and applies solely to visitors, clients, users, and others who reside in the State of California (“consumers” or “you”). We adopt this policy to comply with the California Consumer Privacy Act of 2018 (“CCPA”), and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

Under CCPA, California residents have the right to know about information collected, disclosed, or sold, the right to opt out of the sale of certain information, and a limited right to have business delete information a business has collected about the consumer. These rights extend only to California residents and information covered by CCPA. Because CCPA does not cover all consumer data in all situations, only certain consumer data are subject to these rights.

Other laws may govern data we gather about you, or you provide to us including, but not limited to:

• Information to or from a consumer reporting agency if that information is to be reported in, or used to generate, a consumer report as defined by subdivision (d) of Section 1681(a) of Title 15 of the United States Code, and use of that information is limited by the federal Fair Credit Reporting Act (15 U.S.C. Sec. 1681 et seq.)
• Information collected, processed, sold, or. disclosed pursuant to the federal Gramm-Leach-Bliley Act (Public Law 106-102), and implementing regulations, or the California Financial Information Privacy Act (Division 1.4 commencing with Section 4050) of the Financial Code). PLEASE NOTE: Any personal data collected in relation to a mortgage loan is exempt from the consumer rights to know, delete and opt-out created under CCPA because this information is governed by the Gramm-Leach-Bliley Act, the Fair Credit Reporting Act, the California Financial Information Privacy Act or other state and federal laws which exempt this data from CCPA.

Information We Collect

Secure One Capital Corporation (“Company” or “we”) collects 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”). As described above, not all of the Personal Information collected below is subject to the CCPA. All Personal Information collected pursuant to this notice that is subject to CCPA is collected for a Business Purpose and may be shared with service providers if necessary to perform a Business Purpose. We may have collected the following categories of personal information from consumers within the last twelve (12) months:

Personal information does not include:

• Publicly available information from federal, state, or local government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA’s scope, such as 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.

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from our customers or their agents. For example, from documents that our customers provide to us related to the services that we are asked to perform.
• Indirectly from our customers or their agents. For example, through information we collect from our customers in the course of providing services to them.
• Directly and indirectly from activity on our website (www.secureonecapital.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, credit reporting agencies, appraisers, and other service providers.

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 to prepare a rate quote or ask a question about our products or services, we will use that personal information to respond to your inquiry.
• To provide, support, personalize and develop our website, products, and services.
• To provide you with information, products, or services that you request from us.
• To provide you with email alerts, event registrations 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 between you and us, including for billing and collections.
• For testing, research, analysis, and product development.
• As necessary or appropriate to protect the rights, property or safety of us, our clients, or others.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all our assets, whether as a going concern or as part of bankruptcy, liquidation, or a similar proceeding, in which personal information held by us is among the assets transferred.
• To respond to audits or state or federal examinations by our regulators.

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.

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 keep both the personal information confidential and not use it for any purpose except performing the contract.

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.

In the preceding twelve (12) months, we have not sold any personal information.

Your Rights and Choices

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.

Access to Specific Information and Data Portability

Unless your personal information is excluded from the scope of the CCPA, 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 selling 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.

Deletion Request Rights

Unless your personal information is excluded from the scope of the CCPA, you have the right to request that we delete any of your personal information that we collected and retained from you, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

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

1. 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.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546).
6. 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.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Calling us at: 949-337-4700
• Visiting us at: www.secureonecapital.com
• Emailing us at: compliance@secureonecapital.com

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. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request 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. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. Our practices with regard to verifying a request will vary depending on the request and the information we have on the person making the request.

Response Timing and Format

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 receipt of the verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability 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.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, 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.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

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 by email or through a notice on our website homepage.

Contact Information

If you have any questions or comments about this notice, our Privacy Statement, 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 do not hesitate to contact us at:

Phone: 833-847-3628 or 949-337-4700
 

Website: SecureOneCapital.com

Email: compliance@secureonecapital.com
 

Postal Address: 3200 Park Place, Suite 1300, Costa Mesa CA, 92626