Privacy Policy for California Residents

This Privacy Policy for California Residents (this “Policy”) supplements the information contained in Lima One Capital, LLC’s Privacy Policy and applies solely to residents of the State of California (“consumers” or “you“). Lima One Capital, LLC and its affiliates and subsidiaries (collectively referred to as “Company“, “we“, “us”, and “our”) adopt this notice to comply with the California Consumer Privacy Act of 2018 (the “CCPA”), as may be amended, and any terms defined in the CCPA have the same meaning when used in this Policy.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“Personal Information“). Personal Information does not include:

  • Publicly available information from government records.
  • Deidentified 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 (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

In particular, we may have collected the following categories of Personal Information from consumers within the last 12 months for business purposes:

Category Examples
Identifiers. 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.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A 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. Some Personal Information included in this category may overlap with other categories.

 

Protected Classification Characteristics under California or federal law. Age, race, color, 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, veteran or military status.
Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
Geolocation data. Physical location or movements.
Professional, educational or employment-related information. Current or past job history, performance evaluations, education records.

We will not collect additional categories of Personal Information without providing you notice.

  • The categories of sources from whom we collected the categories of Personal Information listed above in the past 12 months are: Directly from you. For example, from forms you complete.
  • Indirectly from you. For example, from observing your actions on our Website.
  • From third parties, such as technology vendors, marketing and advertiser providers, analytics providers, and consumer reporting agencies (with your permission).

Use of Personal Information

  • In the past 12 months, we have collected and used the categories of Personal Information listed above for the following business purposes: To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a quote or ask a question about our products or services, we will use that Personal Information to respond to your inquiry. If you provide your Personal Information in connection with a product or service, we will use that information to process your payment and facilitate delivery.
  • To provide, support, personalize, and develop our Website, products, and services.
  • To create, maintain, customize, and secure your account with us.
  • To process your requests, transactions, and payments and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
  • To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
  • For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
  • 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 of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our Website users is among the assets transferred.

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.

Disclosure of Personal Information

In the past 12 months, we have disclosed the following categories of Personal Information for a business purpose:

  •  
  • Personal information categories described in the California Customer Records statute.
  • Protected classification characteristics under California or federal law.
  • Commercial information.
  • Internet or other similar network activity.
  • Professional, educational or employment-related information.

 

We disclosed the above noted categories of Personal Information for a business purpose to the following categories of third parties:

  • Service providers, vendors, or third parties that provide mortgage, real property, or credit or financial-related services (e.g., appraisers, closing agents, title agents, PMI companies, or consumer reporting agencies).
  • Service providers, vendors, or third parties that provide services related to compliance, website hosting, information technology, data security, or support services.
  • Investors or wholesale lenders.
  • Government agencies.

We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the Personal Information confidential, and prohibit using the disclosed information for any purpose except performing the contract.

Sale of Personal Information

We do not sell, and have not sold in the past 12 months, Personal Information (including Personal Information of minors under the age of 16) to third parties.

Your Rights under the CCPA

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.

Right to Know

You have the right to request that we disclose certain information to you about our collection, use, disclosure, and sale of your Personal Information over the past 12 months (the “right to know”), subject to certain exemptions specified in the CCPA. Once we receive and verify your request and confirm your identity (see “Exercising Your Rights to Know or Delete” herein), we will disclose to you:

  • The categories of Personal Information we collected about you.
  • The categories of sources from which your Personal Information was collected.
  • Our business or commercial purpose for collecting or sharing that Personal Information.
  • The categories of Personal Information about you that we shared for a business purpose.
  • The categories of third parties with whom we shared that Personal Information.
  • The specific pieces of Personal Information we collected about you.

Right to Delete

You have the right to request that we and our service providers delete any of your Personal Information that we collected from you, subject to certain exceptions (the “right to delete”). Once we receive and verify your request and confirm your identity (see “Exercising Your Rights to Know or Delete” herein), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the Personal Information, provide a 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.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug to identify and repaid errors that impair existing intended functionality.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.) or any other legal obligation.
  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify Personal Information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Right to Opt Out

If we sold Personal Information, you would have the right to request that we not sell your Personal Information to third parties. However, as noted above, we do not sell Personal Information.

Right to Nondiscrimination

You have the right to not be discriminated against for exercising any of your rights under the CCPA. 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 will receive a different price or rate for goods or services or a different level or quality of goods or services.

Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please submit a verifiable consumer request using one of the following methods:

A verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify that you are the person about whom we collected Personal Information or an authorized representative. This may include requesting that you provide us with at least two or more pieces of Personal Information to match against Personal Information about you that we maintain and which we have determined to be reliable for the purpose of verification (e.g., we may request that you provide your email address and validate the last 4 digits of your Social Security number).
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Only you, or a person you have designated in writing as your authorized agent, or whom is registered with the California Secretary of State to act on your behalf, or whom you have provided power of attorney pursuant to California Probate Code sections 4000 to 4465, 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. If you wish to have an authorized agent make a verifiable consumer requests on your behalf, they will need to provide us with sufficient written proof that you have designated them as your authorized agent and we will still require you to provide sufficient information to allow us to reasonably verify that you are the person about whom we collected Personal Information.

You may only submit a request to know twice within a 12-month period. Your 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.

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.  You do not need to create an account with us to submit a request to know or delete.  We will only use Personal Information provided in the verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

Upon receiving a consumer request, we will confirm receipt of the request within 10 business days and provide information on how we will process the request. We endeavor to respond to a verifiable consumer request within 45 calendar days of its receipt. If we require more time (up to an additional 45 calendar 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 our receipt of your verifiable 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 requests unless they are excessive or manifestly unfounded, in particular because of their repetitive nature. If we determine that the request warrants a reasonable fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Please note that, in response to a request to know, we will not disclose Social Security numbers, driver’s license numbers or other government-issued identification numbers, financial account numbers, health insurance or medical identification numbers, account passwords, security questions and answers, or unique biometric data generated from measurements or technical analysis of human characteristics, as applicable. However, in response to a request to know, we will inform you with sufficient particularly if we have collected this type of information.

Changes to This Policy

We reserve the right to amend this Policy at our discretion and at any time. When we make changes to this Policy, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website and/or services following the posting of changes constitutes your acceptance of such changes.

This Policy was last updated August 16, 2021.

Contact Information

If you have any questions or comments about this Policy, the ways in which Lima One Capital, LLC collects and uses your information described here and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact us by:

  • Calling us at 1-800-390-4212.
  • Completing our online form: https://limaone.com/contact-us/
  • Emailing us at [email protected]

Please click here to download a printable copy of this Policy.