California Consumer Privacy Policy

Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers)

Name, alias, postal address, unique personal identifier, online identifier, address, access code, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers 

Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Name, signature, social security number,  address, telephone number, passport number, driver’s license or state identification card number, employment, employment history, bank account number, credit card number, debit card number, and other financial information. 

Characteristics of protected classifications under California or federal law

Gender and age

Commercial information (e.g., records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)

Credit information including payment history, outstanding balance, and credit account status.

Biometric information

Voice information from audio recordings and other biometric collected from government IDs and images to verify your identity

Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)

BirdEye, CallRail, ClickCease, Crazy Egg, Hotjar, Adroll, Meta Ads, Google Analytics, Google Ads, Microsoft Ads, Klaviyo, LeadPost, Google Optimize, Rockerbox, Quantcast, StackAdapt, TikTok ads, Twitter ads, VWO

Geolocation data

Postal address

Audio, electronic, visual, thermal, olfactory, or similar information

Recordings of telephone calls

Professional or employment-related information

Name of employer and current employment status.

Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA)

None

Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

Qualification for financial services and products and future performance related to defaults.

Sensitive Personal Information

Social security number, driver’s license and passport numbers, account numbers and credentials, precise geolocation,

To provide financial services or products to you

For the performance of our contract with you or to take steps at your request before entering into a contract

To prevent and detect fraud against you or the Company     

For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you

Conducting checks to identify our customers and verify their identityScreening for financial and other sanctions or embargoesOther processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g., under regulations or rules issued by our professional regulator

To comply with our legal and regulatory obligations

Gathering and providing information required by or relating to audits,      inquiries or investigations by regulatory bodies

To comply with our legal and regulatory obligations

Ensuring business policies are adhered to, e.g., policies covering customer service, compliance, underwriting, privacy, security and internet use

For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you

Operational reasons, such as improving efficiency, training and quality control

For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price

Ensuring the confidentiality of commercially sensitive information

For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable informationTo comply with our legal and regulatory obligations

Statistical analysis to help us manage our business, e.g., in relation to our financial performance, customer base, services and product  range or other efficiency measures     

For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price

Preventing unauthorized access and modifications to systems

For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you.To comply with our legal and regulatory obligations

Updating and enhancing customer records

For the performance of our contract with you or to take steps at your request before entering into a contractTo comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing services and new products and services.

Statutory returns

To comply with our legal and regulatory obligations.

Ensuring safe working practices, staff administration and assessments

To comply with our legal and regulatory obligationsFor our legitimate interests or those of a third party, e.g., to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you

Marketing our services and those of selected third parties to:—existing and former customers;—third parties who have previously expressed an interest in our services;—third parties with whom we have had no previous dealings.

For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers

Credit reference checks via external credit reference agencies

For our legitimate interests or those of a third party, i.e., to ensure our customers are likely to be able to pay for our products and services

External audits and quality checks, e.g., for accreditations and the audit of our accounts

For our legitimate interests or a those of a third party, i.e., to maintain our accreditations so we can demonstrate we operate at the highest standards.To comply with our legal and regulatory obligations

You have the right to know, and request disclosure of:

• The categories of personal information we have collected about you, including sensitive personal information;• The categories of sources from which the personal information is collected;
• Our business or commercial purpose for collecting, selling, or sharing personal information;
• The categories of third parties to whom we disclose personal information, if any; and
• The specific pieces of personal information we have collected about you.
• Please note that we are not required to:
• Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
• Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
• Provide the personal information to you more than twice in a 12-month period.

In connection with any personal information we may sell, share, or disclose to a third party for a business purpose, you have the right to know:

• The categories of personal information about you that we sold or shared and the categories of third parties to whom the personal information was sold or shared; and
• The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom the personal information was disclosed for a business purpose.You have the right to opt-out of the sale of your personal information or sharing of your personal information for the purpose of targeted behavioral advertising. If you exercise your right to opt-out of the sale or sharing of your personal information, we will refrain from selling or sharing your personal information, unless you subsequently provide express authorization for the sale or sharing of your personal information.

To opt-out of the sale or sharing of your personal information, visit our homepage and click on the “Opt-out/Requests” link here: https://symplelending.com/opt-out.

You have the right to limit the use and disclosure of your sensitive personal information to the use which is necessary to: Perform the services or provide the services reasonably expected by an average consumer who requests those services; To perform the following services:

• 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;
• Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with the business, provided that the consumer’s personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business;
• Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing transactions, verifying customer information, processing payments, providing consumer financial services or products, providing analytic services, providing storage, or providing similar services on behalf of the business; and
• Undertaking activities to verify or maintain the quality of a service, and to improve, upgrade, or enhance the service; and  As authorized by further regulations you have a right to know if your sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes.

To limit the use of your sensitive personal information, visit our homepage and click on the “Opt-out/Requests” link here: https://symplelending.com/opt-out

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

• Delete your personal information from our records; and
• Direct any service providers or contractors to delete your personal information from their records.
• Direct third parties to whom the business has sold or shared your personal information to delete your personal information unless this proves impossible or involves disproportionate effort.

Please note that we may not delete your personal information if it is reasonably necessary to:

• Complete the transaction for which the personal information was collected, provide a service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
• Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes;
• 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;
• Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us
• Comply with an existing legal obligation; or
• Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

If we maintain inaccurate personal information about you, you have the right to request us to correct that inaccurate personal information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.

You have the right to not be retaliated against by us because you exercised any of your rights under the CCPA/CPRA. This means we cannot, among other things:

• Deny services to you;
• Charge different prices or rates for services, including through the use of discounts or other benefits or imposing penalties;
• Provide a different level or quality of services to you; or
• Suggest that you will receive a different price or rate for services or a different level or quality of services. Please note that we may charge a different price or rate or provide a different level or quality of services to you, if that difference is reasonably related to the value provided to our business by your personal information. We may also offer loyalty, rewards, premium features, discounts, or club card programs consistent with these rights or payments as compensation, for the collection of personal information, the sale of personal information, or the retention of personal information.