Effective Date: January 1, 2020
Last Revised on: December 26, 2019
The Company’s Website collects 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”). In particular, the Company’s Website has collected the following categories of Personal Information from Website Users in the past twelve (12) months:
|A. Identifiers||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.||YES|
|B. 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, medical information, or health insurance information. Some Personal Information included in this category may overlap with other categories.||YES|
|C. Protected classification characteristics under California or federal law||Age (40 years or older), race, color, ancestry, 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, genetic information (including familial genetic information).||YES|
|D. Commercial information||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||YES|
|E. Biometric information||Genetic, 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.||NO|
|F. Internet or other similar network activity||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|G. Geolocation data||Physical location or movements.||YES|
|H. Sensory data||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment-related information||Current or past job history or performance evaluations.||YES|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))||Education 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.||YES|
|K. Inferences drawn from other Personal Information||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||YES|
Personal Information does not include:
The Company obtains the categories of Personal Information listed above from the following categories of sources:
The Company may use or disclose the Personal Information it collects from Website Users for one or more of the following business purposes:
The Company will not collect additional categories of Personal Information or use the Personal Information it collected for materially different, unrelated, or incompatible purposes without providing Website Users with notice.
The Company may disclose a Website User’s Personal Information to a third party for a business purpose. When the Company discloses Personal Information for a business purpose, it enters into a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.
The Company shares Personal Information with the following categories of third parties:
In the preceding twelve (12) months, the Company has disclosed the following categories of Personal Information from Website Users for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category D: Professional or employment-related information.
Category F: Internet or other similar network activity.
Category G: Geolocation data.
Category I. Professional or employment-related information
Category J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))
Category K: Inferences drawn from other Personal Information.
The Company discloses Personal Information for a business purpose to the following categories of third parties:
In the preceding twelve (12) months, the Company has not sold any Personal Information. The Company does not and will not sell Personal Information. If, in the future, the Company anticipates selling your Personal Information to any party, the Company will provide you with the opt-out and opt-in rights required by the CCPA.
The CCPA provides California residents who access this Website with specific rights regarding their Personal Information. This Section IV describes your CCPA rights and explains how to exercise those rights.
Please note that the Company engages solely in business-to-business transactions that entail providing working capital to small and medium-sized businesses for business or commercial purposes. The Company does not provide any goods or services to consumers in their individual capacities, namely, the Company does not provide capital to individual consumers for personal, family, or household purposes. Please be advised that pursuant to Section 1798.145 of the CCPA, as amended by Assembly Bill No. 1355, the rights and choices set forth in this Section IV of the Notice do not apply to a Website User’s Personal Information reflecting a written or verbal communication or a transaction between the Company and a Website User, where the Website User is a natural person acting as an employee, owner, director, officer or contractor of a company, partnership, sole proprietorship, non-profit, or government agency and whose communications or transaction with the Company occur solely within the context of the Company conducting due diligence regarding, or providing or receiving a product or service to or from such Website User’s company, partnership, sole proprietorship, non-profit, or government agency.
Additionally, please be advised that pursuant to Section 1798.145 of the CCPA, as amended by Assembly Bill No. 25, the rights and choices set forth in this Section IV of the Notice do not apply to a Website User’s Personal Information that is collected by the Company where the Website User is a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of the Company, to the extent that the User’s Personal Information is collected and used by the Company solely within the context of the User’s role or former role as a job applicant to, employee of, owner of, director of, officer of, medical staff member of, or a contractor of the Company. The rights and choices set forth in this Section IV of the Notice likewise do not apply to Personal Information that is:
(1) collected by the Company that is emergency contact information for such User, to the extent that the Personal Information is collected and used solely by the Company within the context of having an emergency contact on file; or
(2) necessary for the Company to retain to administer benefits for another natural person relating to such User, to the extent that the Personal Information is collected and used solely within the context of administering those benefits.
Please note that Company employees, independent contractors, dependents and beneficiaries of employees, emergency contacts for employees, and job applicants, who reside in the state of California, will receive a separate CCPA Privacy Notice at or before the point their Personal Information is collected by the Company.
Website Users have the right to request that the Company disclose certain information about its collection and use of the User’s Personal Information over the past twelve (12) months. Once the Company receives and confirms the Website User’s verifiable consumer request, the Company will disclose:
Website Users have the right to request that the Company delete any of the User’s Personal Information that the Company collected and retained from the User, subject to certain exceptions. Once the Company receives and confirms a User’s verifiable consumer request, the Company will delete (and direct its service providers to delete, as applicable) the User’s Personal Information from the Company’s records, unless an exception applies.
The Company may deny a Website User’s deletion request if retaining the Personal Information is necessary for the Company or its service providers to:
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to the Company by either:
53 State Street
Boston, MA 02109
Only you, or someone legally authorized 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:
The Company cannot respond to your request or provide you with Personal Information if the Company 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 the Company. The Company will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
The Company endeavors to respond to a verifiable consumer request within 45 days of its receipt. If the Company requires more time (up to 90 days), the Company will inform you of the reason and extension period in writing. If you have an account with the Company, the Company will deliver its written response to that account. If you do not have an account with the Company, the Company will deliver its written response by mail or electronically, at your option. Any disclosures the Company provides will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response the Company provides will also explain the reasons that the Company cannot comply with a request, if applicable. For data portability requests, the Company will select a format to provide your Personal Information that is readily useable and should allow you to transmit the Personal Information from one entity to another entity without hindrance.
The Company does not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If the Company determines that the request warrants a fee, the Company will tell you why it made that decision and provide you with a cost estimate before completing your request.
The Company will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, the Company will not:
The Company reserves the right to amend this Notice at its discretion and at any time. When the Company makes changes to this Notice, the Company will post the updated Notice on its Website and update the Notice’s effective date. Your continued use of the Company’s Website following the posting of changes constitutes your acceptance of such changes.
53 State Street
Boston, MA 02109