California Consumer Privacy Act Disclosure

Last Updated: January 03, 2022

Introduction

At SmarterChoice, it is important to us that you understand how we use and share your personal information. This California Consumer Privacy Act disclosure outlines our use and disclosure of personal information. This notice identifies the categories of personal information we collect, describes how we use and share personal information, and explains how California residents can make certain requests regarding their personal information. SmarterChoice does not sell your personal information to third parties for the third parties’ direct marketing purposes, so there is no need for you to “opt-out” of it.

Note that while a category may be listed below that does not necessarily mean that we have collected personal information in that category about you.

Categories of Personal Information We Collect

Category:	To Whom We May Disclose This Type of Information for Business Purposes:
Identifiers – This may include real name, alias, postal address, phone number, unique personal identifier, online identifier, internet protocol (IP) address, device ID, email address, account name, signature, social security number, driver’s license number, passport number or other similar identifiers.	Affiliate or business partners Service providers Product and service fulfillment companies Payment processors and financial institutions Data analytics providers Internet service providers Advertising networks Social networks
Financial information – This may include credit or debit card number, bank account number, or other financial information.	Affiliate or business partners Service providers Product and service fulfillment companies Payment processors and financial institutions
Characteristics of protected classifications – This may include age, sex, race, ethnicity, physical or mental handicap, etc.	Affiliate or business partners Service providers
Commercial information – This may include information about products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Affiliate or business partners Service providers Product and service fulfillment companies Payment processors and financial institutions
Network activity data - Internet or other electronic network activity information such as, browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement	Affiliate or business partners Service providers Product and service fulfillment companies Payment processors and financial institutions Data analytics providers Advertising networks Social networks
Electronic and sensory data – This may include audio, electronic, visual, thermal, olfactory, or similar information (e.g., pictures, a recording of a customer service call, security video surveillance footage, video recording of website sessions).	Affiliate or business partners Service providers Payment processors and financial institutions
Professional or employment-related information.	Affiliate or business partners Service providers
Inferences – drawn from any of the information listed above to create a profile	Affiliate or business partners Service providers Data analytics providers Advertising networks Social networks

 

Any personal information that SmarterChoice holds will be shared with applicable government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law.

Privacy Rights Specific to California Residents

Under the California Consumer Privacy Act, California residents have specific rights regarding their personal information. This section describes Californians’ rights and explains how California residents can exercise those rights.

California residents have the following specific rights under the California Consumer Privacy Act.

• Right to Access. You have the right to request that we disclose certain information to you about our collection, use and disclosure of your Personal Information over the past twelve (12) months. Any disclosures we provide will only cover the 12-month period preceding the receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
• Right to Data Portability. You have the right to a “portable” copy of your Personal Information that you have submitted to us. Generally, this means you have a right to request that we move, copy or transmit your Personal Information stored on our servers or information technology environment to another service provider’s servers or information technology environment.
• Right to Delete Your Data. You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete your Personal Information from our records, unless an exception applies.
• Right to Non-Discrimination for the Exercise of Your Privacy Rights. You have the right not to receive discriminatory treatment by us for exercising your privacy rights conferred by the California Consumer Privacy Act.

Exercising Your Rights

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

• Our online Privacy Portal at: www.smarterchoice.com.com/ccpa-request/
• Email at: [email protected]smarterchoice.com
• Call: (888) 969-4367

Upon receiving your request, we will send you an email receipt confirming your request.

Before responding to your request, we may need to obtain additional information to locate you in our records, verify that you are a California resident, and/or verify your identity depending on the nature of the request. If you are submitting a request on behalf of a household, we may need to verify each of those included as well.

Authorized agents may exercise rights on your behalf, but at a minimum, we will require evidence of the agent’s identity, proof of registration with the California Secretary of State, and at least one of the following evidencing proof of their legal authority to act: a written authorization signed by you; or a Certified copy of a Power of Attorney granted under Probate Code.

We will respond to requests within 45 calendar days, unless we need more time (in which case we will notify you), and may take up to 90 calendar days in total to respond to your request(s).

In some cases, our ability to uphold these rights for you may depend upon our obligations to process Personal Information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, listed below, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request. We may deny your deletion request if retaining the information is necessary for us or our service providers to:

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