Privacy Policy

Effective Date: June 3, 2024

CONTENTS

Online Privacy and Cookie Notice

U.S. Consumer Privacy Notice

California Consumer Privacy Act (“CCPA”) Privacy Policy

PRIVACY POLICY

We have developed this Privacy Policy to address our collection, use and disclosure of confidential or personally identifiable information. This Privacy Policy applies to all persons and/or businesses who visit our website or mobile application as well as those who do business with us. Sierra Vantage Lending, LLC, is committed to protecting the privacy of our customers and website visitors. References to “we,” “us,” and “our” refer to Sierra Vantage Lending, LLC. References to “you,” “your” and “yours” shall mean the members, customers and website visitors. References to “App” refers to our mobile applications that run on smartphones, tablets, and other devices, through which you will be able access our services.

The following provides a brief explanation of the contents of this Privacy Policy:

• Online Privacy and Cookie Notice. The Online Privacy and Cookie Notice discloses how we collect, use, and share information from visitors to our website and users of our App.

• U.S. Consumer Privacy Notice. The U.S. Consumer Privacy Notice discloses how we collect, use, and share the personal information of individuals who apply for or obtain our financial products and services for personal, family, or household purposes pursuant to the federal Gramm-Leach Bliley Act (“GLBA”).

• California Consumer Privacy Act (“CCPA”) Privacy Policy. The CCPA Privacy Policy applies to residents of California to the extent that the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”), applies to Sierra Vantage Lending, LLC. The specific personal information that we collect, use, and disclose relating to a California resident in different contexts covered by the CCPA will vary based on our relationship or interaction with that individual. For example, the CCPA Privacy Policy does not apply with respect to information that we collect about California residents who apply for or obtain our financial products and services for personal, family, or household purposes (i.e., information subject to the GLBA). For more information about how we collect, disclose, and secure information relating to these customers, please refer to the U.S. Consumer Privacy Notice.

ONLINE PRIVACY AND COOKIE NOTICE

This Online Privacy and Cookie Notice (“Online Privacy Notice”) describes Sierra Vantage Lending, LLC’s online and mobile privacy practices and applies to websites, mobile applications that run on smartphones, tablets, and other devices (“Apps”), and additional services that we offer which link to this Online Privacy Notice.

By using this website or our Apps, you agree to the terms and conditions of this Online Privacy Notice and consent to our online data collection activities as described in this Online Privacy Notice.

The terms “personal information” or “personally identifiable information” used in this Online Privacy Notice refers to information such as your name, mailing address, email address, telephone number, Social Security number, or other information that identifies you. This information may be collected when you voluntarily provide it to us on our website or in our App.

INFORMATION WE COLLECT ONLINE – AND HOW WE COLLECT IT

You may visit our website to find out about products and services and check rates, without giving us any personal information. We may use software tools and/or “cookies” to track and gather information about your browsing activities in order to analyze usage, target areas for improvement, and create marketing programs to benefit our customers or potential customers that visit our site.

1. Use of Cookies and Similar Tracking Technologies
   The use of cookies and similar tracking technologies (including pixels or clear GIFs, tags, and we beacons) is a common internet practice. Cookies are small text files containing small amounts of information which are downloaded to your computer, smartphone, tablet or other mobile device when you visit a website. Cookies are useful in several ways, including allowing a site or mobile app you use to recognize your device, save your settings on a site or mobile app, facilitate navigation, display information more effectively and to personalize the user’s experience. Cookies are also used to gather statistical information about how sites and mobile apps are used to continually improve design and functionality and assist with resolving questions regarding the sites and mobile apps.

   1. Attributes of Cookies

      Cookies set by us are called first-party cookies. We may also have third-party cookies, which are cookies from a domain different than the domain of the website you are visiting, for our advertising and marketing efforts. There can be first-party and/or third-party cookies within any of the below Categories of Cookies.

      Cookies have a duration period. Cookies that expire at the end of a browser session are called “session” cookies. Cookies that are stored longer are called “persistent” cookies. There can be session and/or persistent cookies within any of the below Categories of Cookies. Persistent cookies are stored on your system and can be accessed again for multiple visits. Persistent cookies usually have an expiration date and will be automatically deleted from your system at that time.

   2. Categories of Cookies

      Below is a list of the types of cookies that may be used on our website and mobile app. We classify cookies into the following categories:

      • Necessary. These cookies are necessary for the sites and mobile apps to function and cannot be switched off in our systems. Without these cookies, the sites and mobile apps will not work properly. Examples include setting your privacy preferences, setting your language preferences or logging in a secured area requiring authentication.
      • Preferences. Preference cookies enable the sites and mobile apps to remember information that changes the way that the sites and mobile apps behave or looks, like the preferred language or the region that you are in.
      • Statistics. Statistical cookies enable us to measure and improve the performance of our sites and mobile apps. These cookies collect information about how visitors use a site and mobile app, for instance, which pages visitors go to most often and if they get error messages. These cookies can also be used to make collective inferences based on choices and browsing behavior for marketing research.
      • Targeting. Targeting cookies are used to deliver advertisements that may be relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of an advertising campaign. This information may be shared with other organizations such as advertisers.
      • Unclassified. Unclassified cookies are cookies that we are in the process of classifying, together with the providers of individual cookies.

   3. How to Control and Delete Cookies

      1. Using Your Browser
         Many of the cookies used on our website can be enabled or disabled through our consent tool or by disabling the cookies through your browser. To disable cookies through your browser, follow the instructions usually located within the “Help,”

         “Tools” or “Edit” menus in your browser. Please note that disabling a cookie or category of cookies does not delete the cookie from your browser unless manually completed through your browser function.

         A growing number of browsers are adopting Global Privacy Control (“GPC”), which was created in 2020 and is similar to DNT. The GPC is a technical specification for transmitting universal opt-out signal that communicates a consumer’s choice to opt-out of the sale or sharing of their personal information for behavioral advertising. Where required to do so under applicable law, our website will honor GPC signals.

      2. Using Your Mobile Device
         Some mobile devices come with a non-permanent advertising identifier or ID which gives companies the ability to serve targeted ads to a specific mobile device. In many cases, you can turn off mobile device ad tracking or you can reset the advertising identifier at any time within your mobile device privacy settings. You may also choose to turn off location tracking on your mobile device. By turning off ad tracking or location tracking on your mobile device, you may still see the same number of ads as before, but they may be less relevant because they will not be based on your interests.
      3. Interest-Based Advertising on Third-Party Websites

         Online activity data collected on our website or apps may be used to advertise our products and services that may be of interest to you on third party websites. You may opt-out of such adverting through several tools. You may opt-out of such advertising by visiting http://optout.aboutads.info/ or click on the AdChoices icon in an ad and follow the instructions. You may also use the Network Advertising Initiative’s (NAI) Opt-Out Tool by visiting https://optout.networkadvertising.org/?c=1. Furthermore, you may download the Google Analytics opt-out plug in, available at https://tools.google.com/dlpage/gaoptout/, to prevent your data from being collected and used by Google Analytics. Moreover, there may be other tools provided by the publishing platform to enable you to opt-out. Opting out relies on information in the unique cookies placed on your web browser by our service providers, so if you delete cookies, use a different device, or change web browsers, you may need to opt out again. Additionally, we may partner with websites like Google and Yahoo to display ads to you based on search terms you use on those websites. Please review the privacy policies of those websites for instructions on how to limit these ads. Please note that you may still receive general online advertising from us even after you adjust your ad preferences with certain web search engines or opt out of online advertising through AdChoices or the NAI tool. Such advertising, however, should not be based on online activity data or search term information.

         However, since we do not own or control these third-party resources, we cannot ensure that you will stop receiving our advertisements by using these tools or that such advertisements will not be based on online activity data or search term information, and we do not guarantee the functionality or availability of such third-party tools.

      4. Third Party Website Cookies That We Cannot Control
         When using our website, you may be directed to other websites for such activities as surveys, completing job applications, and to view content hosted on those sites such as an embedded video or news article. These websites may use their own cookies. We do not have control over the placement of cookies by other websites you visit, even if you are directed to them from our website.

2. Location Data
   When allowed by you, our mobile App collects your location data to provide branches and ATMs near you. Location access can be allowed once, only while using the App, or you can choose to not allow location data to be collected.

3. IP Addresses
   If you log on to OB, you pass through a “firewall” used for security purposes and the Internet Protocol (IP) address associated with the computer you are using may be identified. The IP address does not identify you personally. In certain instances, it may also obtain other information about your computer to better identify you as an online user. This information may be retained in case it is needed for security or protection of member information.
4. Social Media
   We may collect information, such as your likes, interests, feedback, and preferences when you interact with our official pages on social media websites such as Facebook, Twitter, LinkedIn, YouTube, and Instagram or from our social media partners (but only if you choose to share with them and they, in turn, share that information with us). Please refer to the policies of those companies to better understand your rights and obligations with regard to your activity on those websites.

HOW WE USE AND SHARE INFORMATION WE COLLECT

We do not and will not sell your personal information. We share your information as required to meet legal and regulatory obligations. We share your personal information that you have provide to us in connection with applying for membership and/or financial products with us (“personally identifiable financial information”) with affiliates and third parties in accordance with the practices set forth in the U.S. Consumer Privacy Notice.

With respect to other information that we collect from you online, which includes personal information as well as online activity data that does not personally identify you or your household, we use such information for a variety of reasons, including:

• to present our website and its contents to you;
• to enable you to use online tools or perform certain online transactions;
• to service and manage your account, including responding to or updating you on inquiries, or to contact you about your accounts or feedback;
• to offer you special products and services and deliver advertisements to you in the form of banner ads, interstitial pages (ads that appear as you sign in or sign out of your online accounts) or other promotions;
• to analyze whether our ads, promotions, and offers are effective;
• to help us determine whether you might be interested in new products or services, and to improve existing products and services;
• to verify your identity and/or location to allow access to your accounts and conduct online transactions;
• to manage fraud and data security risk;
• to personalize and optimize your website browsing and app experiences by examining which parts of our website you visit or which aspect of our apps you find most useful;
• to comply with federal, state or local laws; civil, criminal or regulatory investigations; or other legal requirements;
• to share with trusted third parties who are contractually obligated to keep such information confidential; and
• to use it only to provide the services we have asked them to perform.

We disclose your personal information and non-personally identifiable online activity data to third parties for our business purposes. The general categories of third parties that we share with are as follows:

• our third-party service providers;
• other companies to bring you co-branded services, products or programs;
• third parties that help us advertise our products or services;
• 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;
• third parties or affiliates in connection with a corporate transaction, such as a sale, consolidation or merger of our company or affiliated business; and
• other third parties to comply with legal requirements such as the demands of applicable subpoenas and court orders; to verify or enforce our terms of use, our other rights, or other applicable policies; to address fraud, security or technical issues; to respond to an emergency; or otherwise, to protect the rights, property or security of our customers or third parties.

MISCELLANEOUS

Security: Protecting the confidentiality and security of your personal and financial information is our highest priority. We value your trust, and we understand that handling your financial information with care is one of our most important responsibilities. Our policies, procedures, and protections are always evolving to adapt to new strategies used by fraudsters. Our security measures include ensuring that our websites, online services, online banking, mobile banking, and online applications are hosted on secure servers, have SSL certificates, device safeguards, and secured files and buildings, as well as oversight of our third-party service providers that have access to your personal information and limiting our employees’ access to your personal information on a need-to-know basis.

Linking to Other Websites: Our websites, online services, online or mobile banking may contain links to third party websites. Although these links were established to provide you with access to useful information, we do not control and are not responsible for any of these websites or their contents. We do not know or control what information third-party websites may collect regarding your personal information. We provide these links to you only as a convenience, and we do not endorse or make any representations about using such third-party websites or any information, software or other products or materials found there, or any results that may be obtained from using them. We encourage you to review the privacy statements of websites you choose to link to from our websites so that you can understand how those websites collect, use, and share your information. We are not responsible for the security or privacy practices of the linked websites.

Protecting Children’s Privacy: We respect the privacy of children and comply with the practices established under the Children’s Online Privacy Protection Act (COPPA). Our website and mobile application do not target children. We do not knowingly collect or retain personally identifiable information from consumers under the age of thirteen. For more information about COPPA please visit the Federal Trade Commission website: www.ftc.gov.

U.S. CONSUMER PRIVACY NOTICE

WHAT DOES SIERRA VANTAGE, LLC, DO WITH YOUR PERSONAL INFORMATION?

Why? – Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

What? – The types of personal information we collect and share depend on the product or service you have with us. This information can include: Social Security number and income; payment history and credit scores; and employment information. When you are no longer a customer, we continue to share your information as described in this notice.

How? – All financial companies need to share members’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their members’ personal information; the reasons Sierra Vantage Lending, LLC chooses to share; and whether you can limit this sharing.

‌Reasons We Can Share Your Personal Information

Questions? – Call (805) 988-2151

Who Are We

Who is providing this notice? Sierra Vantage Lending, LLC.

What We Do

How does Sierra Vantage Lending, LLC protect my personal information? – To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. We also have strict policies, vendor requirements, and staff training all designed to protect your personal information and privacy.

How does Sierra Vantage Lending, LLC collect my personal information? – We collect your personal information, for example, when you open an account, make deposits or withdrawals from your account, pay your bills, apply for a loan, use your credit or debit card, make a wire transfer, show your Driver’s License, visit our web site, use our external funds transfer or bill payment services, and complete an application or form. We also collect your personal information from others such as credit bureaus, or other companies.

‌Why can’t I limit all sharing?
Federal law gives you the right to limit only:

• Sharing for affiliates “everyday business purposes” information about your creditworthiness
• Affiliates from using your information to market to you
• Sharing for non-affiliates to market to you

State laws and individual companies may give you additional rights to limit sharing. California residents, see above for more on your rights under state law.
What happens when I limit sharing for an account I hold jointly with someone else? – Your choices will apply to everyone on your account.

Definitions

Affiliates – Companies related by common ownership or control. They can be financial and nonfinancial companies.

Sierra Vantage Lending, LLC does not share with our affiliates.

Non-affiliates – Companies not related by common ownership or control. They can be financial and nonfinancial companies.

Sierra Vantage Lending, LLC does not share with nonaffiliates so they can market to you.

Joint marketing – A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Our joint marketing partners include insurance companies, insurance brokers and agents, lenders and other financial institutions. Sierra Vantage Lending, LLC does not jointly market.

Other important information

For California Residents : You may have additional rights under the CCPA Privacy Policy. The CCPA Privacy Policy applies to residents of California to the extent that the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”), applies to Sierra Vantage Lending, LLC. The specific personal information that we collect, use, and disclose relating to a California resident in different contexts covered by the CCPA will vary based on our relationship or interaction with that individual. For example, the CCPA Privacy Policy does not apply with respect to information that we collect about California residents who apply for or obtain our financial products and services for personal, family, or household purposes. Such information is instead covered under this U.S. Consumer Privacy Notice.

For Nevada Residents: We are providing this notice pursuant to Nevada law. If you prefer not to receive marketing calls from us, you may be placed on our Internal Do Not Call List by calling (800) 477-2890. For more information, contact us at this toll-free number. You may also contact the Nevada Attorney General’s office: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; telephone number: (702)-486-3132; email aginfo@ag.nv.gov.

CCPA PRIVACY POLICY

Rev. June 3, 2024

This California Consumer Privacy Act Privacy Policy (“CCPA Privacy Policy”) explains how we collect, share, use, and protect your personal information through your online and offline interactions with us. This CCPA Privacy Policy applies to residents of California to the extent that the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”), applies to Sierra Vantage Lending, LLC. As used in this CCPA Privacy Policy, “personal Information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. However, personal Information does not include: (i) publicly available information; (ii) deidentified or aggregated consumer information; or

(iii) personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (“FRCA”) and the Gramm-Leach-Bliley Act (“GLBA”).

The specific personal information that we collect, use, and disclose relating to a California resident in different contexts covered by the CCPA will vary based on our relationship or interaction with that individual. For example, this CCPA Privacy Policy does not apply with respect to information that we collect about California residents who apply for or obtain our financial products and services for personal, family, or household purposes (i.e., information subject to the GLBA). For more information about how we collect, disclose, and secure information relating to these customers, please refer to our

U.S. Consumer Privacy Notice. We may use the information described below for any of the purposes described in this CCPA Privacy Policy or for our business, security, or operational purposes compatible with the context in which the personal information was collected, unless limitations are listed in this CCPA Privacy Policy or described elsewhere at the time of collection of the information.

1. CATEGORIES OF INFORMATION WE COLLECT

   In the preceding 12-months, we have collected the following categories of personal information (please note that some categories overlap):

   Category	Examples	Collected (Y/N)
   A. Personal identifiers	You name, age, postal address, signature, home phone number or mobile phone number, email address, membership number, driver’s license number or state identification card number, citizenship, and similar identifiers, some of which may be listed in the California Records statute (Cal. Civ. Code § 1798.80(e) and be protected classification characteristics under state or federal law.	Y
   B. Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Y
   C. Biometric information	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.	N
   D. Internet or other similar network activity	Browsing history, search history, and information on a consumer’s interaction with a website, application, or advertisement.	Y
   E. Geolocation data	Physical location or movements. For example, city, state, country, and ZIP code associated with your IP address or derived through Wi-Fi triangulation; and, with your permission in accordance with your mobile device settings, precise geolocation information from GPS- based functionality on your mobile devices.	N
   F. Sensory data	Audio, electronic, visual, or similar information.	Y
   G. Professional or employment- related information	Current or past job history, performance evaluations, disciplinary records, workplace injury records, disability accommodations, and complaint records; Emergency contact information, such as the name, phone number, address and email address of another person in the context of having an emergency contact on file; Personal information necessary for us to collect and retain to administer benefits for you and another personal relating to you (e.g., your spouse, domestic partner, and dependents), such as their name, Social Security Number, date of birth, telephone number, email, and address.	Y
   H. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Educational 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.	Y
   I. Inferences drawn from other personal information	Profile reflecting a person’s preference, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	N
   J. Sensitive Personal Information	A consumer’s social security, driver’s license, state identification card, or passport number, precise geolocation, union membership, and citizenship and naturalization status.	Y

   For purposes of the CCPA, “personal information” does not include:

   • Publicly available information.
   • De-identified information that cannot reasonably be used to identify you or your household.
   • Aggregated consumer information that relates to a group or category of consumers, from which consumer identities have been removed, that is not linked or reasonably linkable to any consumer or household, including via a device.
   • 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.
2. CATEGORIES OF SOURCES OF INFORMATION WE COLLECT
   We obtain the categories of personal information listed above from the following categories of sources:
   • Directly from consumers or their agents. For example, the information we receive from you to verify your identity when you call us.
   • Indirectly from consumers or their agents. For example, when you use your debit or credit cards or when you pay your loan.
   • Directly and indirectly from activity on our website or our mobile applications. For example, from application submissions through our website, application portals, or website usage collected automatically.
   • From third-parties, such as credit reporting agencies, government agencies, law enforcement agencies, and service providers.
   • From our clients with whom you have a business relationship where we are performing one or more functions as a service provider, such as acting as a servicer or subservicer of your loans with our client.
3. HOW WE USE YOUR PERSONAL INFORMATION
   We may use or disclose personal information we collect for one or more of the following operational or other notified purposes (“business purposes”):
   • To fulfill or meet the reason for which the information is provided. For example, if you apply for a loan, we use the information in your loan application to evaluate your credit request and grant you the loan if approved.
   • To provide you with information, products, or services that you request from us.
   • To provide you with email alerts, event registrations, or 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 improve our website and present its contents to you.
   • For testing, research, and analysis to improve our products and services and for developing new ones.
   • To protect the rights, property, or safety of us, our employees, our members, or others.
   • To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity.
   • 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.
   • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, in which personal information held by us is among the assets transferred.
   • As otherwise permitted under law.

     With respect to your personal information that is deemed “sensitive personal information” under the CCPA, we do not use or disclose it for any purpose other than, as reasonably necessary and proportionate, for the following purposes:

   • To perform the services or provide the goods reasonably expected by an average consumer who requests those goods and services.
   • To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information.
   • To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions.
   • To ensure the physical safety of natural persons.
   • For short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of your current interaction with the business, provided that the personal information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside of your current interaction with us.
   • For our service providers or contractors to perform services on our behalf, such as maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on our behalf; provided, however, that the use of your sensitive personal information is reasonably necessary and proportionate for this purpose.
   • To verify or maintain the quality or safety of a service or device that is owned, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured for, or controlled by us; provided, however, that the use of your sensitive personal information is reasonably necessary and proportionate for this purpose.
   • To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about you.
4. HOW WE SHARE AND DISCLOSE PERSONAL INFORMATION

   In addition to the specific situations discussed elsewhere in this CCPA Privacy Policy, we may disclose your personal information in the following situations:

   • Service Providers. We may share your information with service providers. Among other things, service providers may help us to administer our website, conduct surveys, provide technical support, process payments, assist in the fulfillment of services, and help us market our own products and services.
   • Joint Marketing Partners. We may share your information with other companies to offer you co-branded financial products and services.
   • Advertising Networks. We may share your information with advertising networks such as Google and Facebook to help deliver our advertisements to you as you are browsing online.
   • Compliance with Laws and Other Lawful Uses. We may disclose information to law enforcement agencies and other government entities or private parties in litigation in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information with this parties to establish or exercise our rights, to defend against a claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies. We may also disclose your personal information with our acquisition or merger partners in the event of an acquisition or merger. Furthermore, we may disclose your personal information as permitted by applicable law. All of the categories of personal information we collect from you may disclosed for this purpose.
   • Your Consent. All the categories of personal information we collect from you may be disclosed to third parties with your consent or direction.

   In addition to the information above, California law requires that organizations disclose whether the specific categories of personal information defined in the CCPA have been disclosed to third parties for a “business purpose,” or “sold” or transferred for “valuable consideration, or “shared” for purposes of cross-context behavioral advertising. The table below indicates which of these specified categories we may collect and transfer in a variety of contexts.

   CATEGORY OF PERSONAL INFORMATION	CATEGORY OF RECIPIENTS (FOR BUSINESS PURPOSE)	CATEGORY OF RECIPIENTS (FOR “SALE” OR “VALUABLE CONSIDERATION”	CATEGORY OF RECIPIENTS (CROSS-CONTEXT BEHAVIORAL ADVERTISING)
   Identifiers such as name, address, unique personal identifier, email address, or account name.	Service providers; Joint marketing partners; Advertising networks; Third parties for compliance with laws and other lawful purposes; and Third parties with your consent.	Not sold.	Not shared.
   Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	Service providers; Joint marketing partners; Advertising networks; Third parties for compliance with laws and other lawful purposes; and Third parties with your consent.	Not sold.	Not shared.
   Protected classification characteristics under state or federal law	Service providers; Joint marketing partners; Advertising networks; Third parties for compliance	Not sold.	Not shared.
   	with laws and other lawful purposes; and Third parties with your consent.
   Commercial information	Service providers; Joint marketing partners; Advertising networks; Third parties for compliance with laws and other lawful purposes; and Third parties with your consent.	Not sold.	Not shared.
   Biometric information	Service providers; Third parties for compliance with laws and other lawful purposes; and Third parties with your consent.	Not sold.	Not shared.
   Internet or other similar network activity	Service providers; Advertising networks; Third parties for compliance with laws and other lawful purposes; and Third parties with your consent	Not sold.	Not shared.
   Geolocation data	Service providers; Joint marketing partners; Advertising networks; Third parties for compliance with laws and other lawful purposes; and Third parties with your consent.	Not sold.	Not shared.
   Sensory data	Service providers; Third parties for compliance with laws and other lawful purposes; and Third parties with your consent.	Not sold.	Not shared.
   Professional or employment-related information	Service providers; Third parties for compliance with laws and other lawful purposes; and Third parties with your consent.	Not sold.	Not shared.
   Non-public education information	Service providers; Third parties for compliance	Not sold.	Not shared.
   	with laws and other lawful purposes; and Third parties with your consent.
   Inferences drawn from other personal information	Service providers; Joint marketing partners; Advertising networks; Third parties for compliance with laws and other lawful purposes; and Third parties with your consent.	Not sold.	Not shared.
   Sensitive personal information	Service providers; Third parties for compliance with laws and other lawful purposes; and Third parties with your consent.	Not sold.	Not shared

5. YOUR RIGHTS AND CHOICES
   This section describes your rights and choices regarding how we collect, share, use, and protect your personal information, how to exercise those rights, and limits and exceptions to your rights and choices.
   1. Exceptions
      The rights and choices in this Section do not apply:
      • If you are not a California resident;
      • If we collected personal information covered by certain financial sector-specific privacy laws, including the Fair Credit Reporting Act (“FCRA”), the Gramm-Leach-Bliley Act (“GLBA”) and/or California Financial Information Privacy Act (“CFIPA”). How we collect, share, use, and protect your personal information is covered under such laws instead of the CCPA; or
      • To aggregate consumer information; or
      • To deidentified personal information; or
      • Publicly available personal information.
   2. Right to Know
      If the above exceptions do not apply, and you have not made this request more than twice in a 12- month period, you have the right to request that we disclose certain information to you about our collection and use of your personal information. Once we receive and confirm your request and verify that the request is coming from you or someone authorized to make the request on your behalf, we will disclose to you or your representative:
      • 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, sharing or selling that personal information, as applicable.
      • The categories of third parties to whom we disclosed, shared or sold the personal information, as applicable.
      • The specific pieces of personal information we collected about you in a form that you can take with you (also

        called a “data portability request”).

   3. Right to Delete
      You have the right to request that we delete any of your personal information that we collect from you and retained, subject to certain exceptions. Once we receive and verify your 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 that activity;
      3. Debug to identify and repair errors that impair existing intended functionality;
      4. 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;
      5. 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 our deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you previously provided informed consent;
      6. Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us and compatible with the context in which you provided the information; or
      7. Comply with a legal obligation.
   4. Right of Correction
      ‌You have the right to request correction of any personal information that we retain about you that is incorrect. We generally rely on you to update and correct your personal information.
   5. Exercising Access, Data Portability, Deletion and Correction Rights
      To exercise the access, data portability, deletion and correction rights described above, you or your authorized agent may submit a verifiable consumer request to us by any of the following methods:
      • Calling (805) 988-2151
      • Submitting a CCPA Submission Form available via this link.
      • Mail your request to 2151 E Gonzales Rd, Oxnard, CA 93036. Include a completed CCPA Submission Form with your request.

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

        When we receive a verifiable request from your authorized agent we may require:

        1. Submission of a written document signed by you with your permission for the authorized agent to submit a verifiable request on your behalf and require the authorized agent to verify its own identity to us; or
        2. You may directly verify with us that you have authorized the agent to submit the request.

        We will not require either of the above if the authorized agent provides a copy of a power of attorney pursuant to California

        Probate Code sections 4121 to 4130 and we are able to verify the authorized agent’s identity.

        We will deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf and cannot verify their own identity to us.

        We will 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. We will deliver our written response to the mailing address of record according to our files. 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 hinderance.

        The response 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 verifiable consumer request.

   6. Right of Non-Discrimination
      We will not discriminate against you for exercising any of your rights in this CCPA Privacy Policy and under applicable laws. Unless permitted by law, 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; or suggest that you may receive a different price for goods or services or a different level or quality of goods or services.
   7. Opt-Out Rights Regarding Sale of Personal Information or Sharing Personal Information for Cross-Context Behavioral Advertising

   It is not our policy to sell personal information and we have not done so in the preceding 12-month period.

   In the preceding 12-months, we have not shared your personal information to third-parties for cross-context behavioral advertising purposes.

6. CHANGES TO THIS CCPA PRIVACY POLICY
   We reserve the right to amend this CCPA Privacy Policy at our discretion and at any time. When we make changes to this CCPA Privacy Policy, we will post an updated CCPA Privacy Policy on our website and mobile application.
7. CONTACT INFORMATION

If you have any questions or comments about this CCPA 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, call (805) 988-2151 or mail us at 2151 E Gonzales Rd, Oxnard, CA 93036.